Westlake is committed to conducting all of its business activities pursuant to the highest ethical standards and in compliance with all applicable laws and regulations, including those that prohibit bribery or corruption. The integrity of Westlake’s business dealings and relationships is critical to maintaining the trust of all stakeholders and investors, as well as business partners and suppliers. Westlake’s Code of Conduct articulates our commitment to ethics and compliance, safety, and environmental safeguards. Westlake expects that its employees will adhere to the anti-bribery and anti-corruption standards established in this Code.
Laws and Regulations
Westlake is committed to adhering to the laws governing our business activities, including strict compliance with the U.S. Foreign Corrupt Practices Act, U.K. Bribery Act and other anti-bribery and anti-corruption laws wherever we conduct business.
Global Code of Conduct
Westlake’s Code of Conduct applies to all employees, directors, and officers. It guides individual behavior and ethical practices for company actions, and it contains specific prohibitions against bribery, corruption, kickbacks and other favors which could be illegal or improper. It also includes specific direction relating to the acceptance of gifts, favors, entertainment or even rebates or discounts from suppliers or customers which could conflict with the Company’s interest. All Westlake employees, including its eight Executive Officers and eleven Board members, are trained in compliance with the Code of Conduct and are expected to abide by the Code.
Anti-Corruption Compliance
Westlake’s Anticorruption Policy strictly forbids the use of bribes, kickbacks, and all other forms of corruption to win new business, keep existing business, or obtain any other business advantage. The policy describes the compliance program in place at Westlake to prohibit bribery and corruption in Westlake’s business activities. This includes providing anti-corruption compliance training to employees, conducting due diligence on third parties with whom Westlake does business, establishing expenditure standards and approval requirements for activities involving government officials, and requiring adherence to financial and accounting controls.
Supplier Expectations
Westlake’s Suppliers’ Code of Conduct applies to its suppliers and their manufacturing facilities, including any subcontracting and packaging facilities. It explicitly sets forth Westlake’s expectation of compliance with applicable laws and regulations including, but not limited to, those related to labor, immigration, health and safety, and the environment. Conflicts of interest, bribery, corruption, unfair wages and any form of forced labor or human trafficking are expressly prohibited. Westlake expects its suppliers to conduct business in an ethical and responsible manner and reserves the right to terminate the supplier relationship if they fail to do so.
Compliance Reporting and Monitoring
Westlake has multiple mechanisms available for employees and suppliers to report any concerns regarding ethical business practices, including suspected violation of anti-bribery and anti-corruption laws. Employees who observe or become aware of possible improper conduct are encouraged to report their concerns to their direct supervisor, another manager, a Human Resources representative, or the Legal Department. Alternatively, suspected misconduct can be reported by employees, suppliers, or any Westlake business partner through Westlake’s confidential, 24-hour multilingual reporting system, EthicsPoint. It is operated by a third-party company specializing in workplace incident reporting for multi-national companies. Westlake does not tolerate retaliation against anyone who reports a concern.