Tenneco has prepared and made public this Statement in furtherance of the California Transparency in Supply Chains Act and the UK Modern Slavery Act. These laws are designed to increase the amount of information made available by subject companies regarding their efforts to address the issue of slavery and human trafficking.
Tenneco is committed to conducting its business in an ethical and responsible manner that supports and respects the protection of human rights. Tenneco’s compliance and ethics expectations are set forth in Tenneco’s Code of Conduct (available online, here: https://www.tenneco.com/governance/code_of_conduct/), Tenneco’s Supplier Manual (available online, here: http://suppliermanual.tenneco.com/), training materials, and other communications that Tenneco provides to its employees and suppliers. Tenneco supports a safe and healthy working environment for all workers, and seeks in all instances to provide working conditions that meet or exceed applicable laws and standards.
In addition to Tenneco’s own commitment to fair working conditions, a guiding principle of Tenneco’s Code of Conduct states, “Tenneco respects the human rights of all people and expects our suppliers and other business partners to follow the same high standards of social responsibility.” Tenneco views compliance with this commitment to human rights as an important responsibility of every Tenneco employee and supplier. Employees review and accept compliance with the Code of Conduct annually and suppliers are required to abide by Tenneco’s Code of Conduct as a condition of doing business with Tenneco. Employees that violate the Code of Conduct may be disciplined or dismissed, depending upon the nature of the violation.
Tenneco further seeks to enforce its commitment to human rights through the publication, distribution, and enforcement of Tenneco’s Supplier Manual. Each supplier wishing to do business with Tenneco is required to abide by the principles outlined in Tenneco’s Supplier Manual, which states:
“Tenneco opposes the use of child labor and expects our suppliers to support this value. The age of employment should be in accordance with local labor law. Tenneco expects our suppliers to oppose any form of forced or compulsory labor, and ensure that their workers are able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment. Tenneco expects our suppliers to support zero tolerance of harassment or discrimination against their employees in any form. Tenneco supports a safe and healthy working environment for all workers that meets or exceeds applicable standards for occupational safety and health and expects the same from our suppliers.”
Tenneco assesses and selects its suppliers with care and seeks to engage only those suppliers that comply with all applicable laws, as well as the principles embodied in Tenneco’s Code of Conduct and Supplier Manual.
Tenneco conducts internal training concerning forced labor and fair working conditions, and relevant training materials are available on Tenneco’s employee intranet site. Tenneco also requires that each direct material supplier maintain a training program concerning Tenneco’s commitment to forced labor and working conditions. Tenneco endorses and encourages suppliers to complete the training and Global Working Conditions Self- Assessment provided by the Automotive Industry Action Group. As Tenneco expects its suppliers to conduct internal audits and self-assessments as a condition of contracting with Tenneco, Tenneco does not independently audit suppliers, although it reviews some of the self-assessments completed by suppliers. To the extent that ethics or compliance issues are noted in the context of any interaction with a supplier, Tenneco has procedures in place to take appropriate and necessary action to address and resolve such issues.
To promote accountability, Tenneco is committed to taking appropriate actions to discontinue relationships with 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. Tenneco maintains an Ethics and Compliance Hotline and multiple reporting channels through which any concerns or potential deviations from Tenneco’s expected values can be reported. Such reports are promptly investigated and appropriate actions taken.