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INVISTA is committed to conducting business lawfully and with integrity. INVISTA’s commitment to integrity includes, among other things, an expectation that its suppliers not use forced labor in any of its forms, including human trafficking and slavery, to produce the products they provide to INVISTA.

Verification

INVISTA assesses and selects its suppliers with care and seeks to perform appropriate diligence and on-going oversight of INVISTA's international supply chain. INVISTA will act to discontinue relationships with those suppliers and other third parties who fail to meet its high standards for lawful and ethical conduct, including prohibitions on the use of forced labor in any of its forms, such as human trafficking and slavery.

Other than the steps and practices described below, INVISTA does not have a separate, comprehensive verification process for evaluating and addressing the risks of human trafficking and slavery.

Supplier Audits

INVISTA typically reserves the right to audit and assess performance and requires that third parties comply with all applicable laws and regulations. Audits are performed based on a variety of risk factors. Using this approach, announced audits are performed using internal, and at times, external resources. In the event an audit reveals supplier non-conformance with our standards and guidelines, depending on the circumstances, we would either require that suppliers establish corrective action plans and report on the implementation of such plans, or we would terminate the relationship with that supplier.

Direct Supplier Certification

While many of our commercial agreements require supplier compliance with applicable laws and regulations, INVISTA does not have a direct supplier certification process specifically focused on human trafficking and slavery.

Internal Accountability

INVISTA's compliance and ethics expectations are set out in INVISTA’s Code of Conduct, training materials and other communications (such as internal compliance policies and INVISTA’s Third Party Expectations) that it provides to some of its suppliers and other third parties, as well as its employees with direct responsibility for supply chain management.  Non-compliance with our standards regarding human trafficking and slavery – whether by a supplier or an employee – will result in corrective action, up to and including termination of the relationship, depending on the circumstances. Internal auditors and business representatives would work with suppliers, employees and possibly third-party resources to resolve any instances of non-compliance. INVISTA promotes a Code of Conduct identifying numerous avenues for reporting compliance concerns, including on an anonymous basis (where allowed by law). Such concerns are objectively investigated under the guidance and direction of our compliance or legal departments. INVISTA prohibits retaliation against anyone who, in good faith, raises a concern.

Training

Although INVISTA does not have a comprehensive, mandatory training program focusing on human trafficking and slavery, INVISTA does provide training to those employees who are directly responsible for human resources, procurement and supply chain management on the subjects of human trafficking and slavery, particularly with respect to mitigating risks within the supply chain. These employees receive training on company policies and procedures designed to support a supply chain free of any type of coerced labor and on the methods available for reporting concerns. INVISTA trains these employees on the employee Code of Conduct and the Third Party Oversight Compliance Standard, which addresses prohibition of coerced labor. The training is periodically provided through a variety of delivery methods, including live classroom training, small team meetings and computer-based training.