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California Transparency in Supply Chains Act of 2010

Disclosure Statement

ZEON Chemicals L.P. ("ZEON," or "ZCLP”), wherever it operates around the world, is committed to operating at the highest ethical standard. ZEON strives to be not only a growing, productive and profitable company, but also a world-class corporate citizen, treating all people with dignity and respect and complying with applicable laws, regulations and treaties. ZEON is also committed to protecting and promoting human rights globally.

ZEON has established a Corporate Social Responsibility Code of Conduct (CSR). The ZEON philosophy is that we will contribute to the preservation of Earth and the human race. We will accomplish that by abiding by our Corporate Social Responsibility Code of Conduct.

We will not tolerate illegal child labor, forced labor or any use of force or other forms of coercion, fraud, deception or abuse of power within our company, by our contractors, by our tollers or by our suppliers. ZCLP endorses international principles of human rights, including but not limited to those expressed in the United Nations (U.N.) Universal Declaration of Human Rights, the Trafficking Victims Protection Act of 2000 (as amended – Public Law 106-386, Division A) and the California Transparency in Supply Chains Act of 2010. We comply with employment laws of every country in which we operate, and expect those with whom we do business to do the same.

The California Transparency in Supply Chains Act of 2010 (the "Act”) requires retail sellers and manufacturers doing business in California with over $100 million in worldwide gross receipts to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. Accordingly, the Act requires ZCLP to disclose, at a minimum, the following:

Verification. ZEON routinely assesses risk related to its supply chain. This assessment includes supplier quality performance, price comparison, chemical regulatory compliance, a business continuity plan (BCP) and other relevant business and legal criteria. ZEON follows the trade laws of the United States and applicable laws of countries in which we operate. ZEON has a written Purchasing Policy that requires ethical conduct in procurement, and prohibits any supplier relationship that may actually or potentially be detrimental to the best interests of ZEON, including violation of our Corporate Social Responsibility Code of Conduct. We believe that our suppliers and their products, personnel and services are a natural extension of ZEON's own resources. ZEON shall implement a Supplier Code of Conduct that will specifically state the expectation that our suppliers comply with laws governing human trafficking and slavery. ZEON reserves the right to investigate any discovered instances of noncompliance. ZEON will not knowingly do business with any supplier or contractor who violates an equal opportunity, fair labor or human trafficking law. Other than the foregoing, ZEON has no formal process for verification of product supply chains to evaluate and address risks of human trafficking and slavery.

Auditing. ZEON includes audit rights in its critical supply contracts that permit ZEON to audit a supplier’s compliance with the terms of the contract. While ZCLP has certain contractual rights to audit its suppliers, and has conducted routine audits or assessments of supplier performance, those assessment methodologies do not include intentional assessments of human trafficking and slavery. Nonetheless, ZEON has reserved the right to investigate actual or alleged instances of noncompliance with human rights laws and principles, including instances of noncompliance with laws governing human trafficking and slavery.

Certification. ZEON's expectation is that all suppliers and contractors comply with anti-discriminatory and human rights protection laws, including those laws and principles prohibiting involvement in human trafficking and slavery. After establishing a Supplier Code of Conduct, we will update our purchasing terms and conditions so that when a supplier accepts our purchase order and/or enters into a contract with ZCLP, it is acknowledging and consenting to comply with our Supplier Code of Conduct. Currently, the ZEON formal supplier certification process does not address risks of human trafficking and slavery.

Internal Accountability. ZEON's employees, as a condition of employment, are expected to follow all laws of the countries in which they operate, and adhere to ZEON's Corporate Social Responsibility Code of Conduct and all related internal policies and standards. Employees who violate laws, policies or standards – especially those that infringe on human rights, discriminate or include unfair employment practices – are subject to disciplinary action, including discharge. ZEON suppliers are expected to conduct business with this same integrity and commitment to protection of Earth and the human race. ZEON will terminate relationships with suppliers who fail to comply with laws protecting human rights, including human trafficking or slavery.

Training and Awareness. ZCLP regularly trains its employees in the standards of ethical behavior. All employees receive annual training on the Corporate Social Responsibility Code of Conduct and related internal policies and standards. As appropriate, we will update the CSR and related internal documents to include information regarding human trafficking and slavery. At this time, ZCLP has no formal training curriculum related to human trafficking and slavery.

Last Updated 4/24/2015