California Supply Chains Act Disclosure

Verification
In furtherance of that commitment, we require our direct suppliers to register with a third-party verification company prior to our engagement with them.  In addition, we maintain a Supplier Code of Conduct, which, among other things, states: “Air Liquide does not accept any practice on the part of its suppliers that is incompatible with the rights outlined in the Convention on the Rights of the Child (UN resolution of November 20, 1989). . . .  Air Liquide expects its suppliers to forbid any and all forced labor and involuntary prison work.  All work, including overtime, must be performed on a voluntary basis, and employees must be free to leave their jobs provided they give reasonable notice.”

Certification
When contracting with suppliers, we require that they: (1) agree to comply with the Supplier Code of Conduct and all applicable laws and regulations, including applicable labor laws and regulations, in all aspects of their performance of work on our behalf (including the manufacture, transportation, and delivery of their goods) and (2) certify that their products are, and will at all times, remain in compliance with all applicable laws, including applicable labor laws and regulations.

Audit
The Supplier Code of Conduct requires suppliers to verify compliance with its requirements at any time we request and in any form we choose.  We regularly conduct audits of our suppliers, both with prior notice and without, using internal resources to verify compliance with contractual requirements.  In addition, a select number of suppliers are identified each year to undergo an audit conducted by a third-party to assess and rate the supplier’s performance in the following four areas of corporate social responsibility: the environment, labor practices, fair business practices, and sustainable procurement.

Internal Accountability
In addition to the requirements we impose on our suppliers and their subsuppliers, we also require all employees to abide by a Code of Conduct as a condition of their employment, which states, “The Company has always conducted and will continue to conduct its business in compliance with all applicable federal and state statutes and regulations governing the manufacturing, distribution, importation and exportation of products. In particular, all requirements of the federal . . . Occupational Safety and Health Administration (OSHA) must be observed.”  We provide company employees both internal and third-party avenues to confidentially and, if desired, anonymously report violations of the Code of Conduct.  Employees violating the Code of Conduct are subject to disciplinary action, up to and including termination. 

Training
Our employees are trained annually on the requirements of the Code of Conduct and the available avenues to report violations, including the option to report anonymously to a third-party.  These requirements and reporting obligations are further emphasized using posters conspicuously placed in company workplaces throughout the year.
In addition, supply chain management personnel regularly undergo specialized procurement training on all company policies, practices, and procedures, including the Supplier Code of Conduct.  They are trained to ensure that appropriate clauses are included in all of our agreements with suppliers, including those that require suppliers to comply with all laws and the Supplier Code of Conduct.