Response to California Transparency in Supply Chains Act of 2010

Cabot Corporation is committed to conducting its business with integrity and in accordance with the highest ethical standards.

As stated in Cabot’s Code of Business Ethics, Cabot believes in doing business with suppliers and others who demonstrate high standards of ethical business behavior. Cabot also supports and values human rights and is committed to complying with all applicable laws and standards related to labor practices and human rights in all of Cabot’s operating locations. This includes laws pertaining to child and forced labor.

In 2010, Cabot implemented a Supplier Code of Conduct that has been distributed to over 10,000 suppliers worldwide in 14 languages. The Supplier Code expressly prohibits Cabot’s suppliers from using forced labor of any kind. In particular, with respect to Labor Practices and Discrimination, the Supplier Code states:

Suppliers are required to be in compliance with any local or national labor laws regarding compensation and working hours. Cabot values diversity and respects equal opportunity in employment. Cabot will not tolerate any supplier who engages in unlawful employment discrimination, child labor or forced labor practices.

To ensure Cabot’s supplier policies are understood, implemented and enforced, Cabot conducts in-person training and review of the Supplier Code of Conduct with key suppliers on a regional basis. Cabot also uses an internal supplier qualification process for new suppliers and periodically re-qualifies current suppliers. Cabot’s standard purchase order terms and conditions expressly require supplier compliance with the Supplier Code of Conduct and reserve Cabot’s right to conduct audits of supplier compliance. As stated in the Supplier Code of Conduct, Cabot reserves the right to terminate its business relationship with any supplier that violates the principles set forth in the Supplier Code of Conduct, including provisions related to illegal human trafficking or forced labor.

All Cabot employees receive periodic training on Cabot’s Code of Business Ethics. Cabot’s purchasing function conducts additional training for its members responsible for supplier management on the importance of Cabot’s supplier qualification processes and ensuring that Cabot only engages with suppliers who demonstrate they meet Cabot’s standards, and also conducts training on topics of human trafficking and slavery.

Supplier Code of Conduct Policy