California Supply Chain Transparency
California Transparency in Supply Chains Act Disclosure
(Cal. Civ. Code §1714.43)
Koch Supply & Trading ("KS&T") is committed to conducting business lawfully and with integrity. KS&T's commitment to integrity includes, among other things, an expectation that our suppliers will adhere to similarly high expectations for integrity. Our general practice is to require suppliers to confirm compliance with applicable laws when producing the products they provide to KS&T, and such compliance would also include any prohibitions on the use of forced labor in any of its forms, human trafficking, and slavery.
Our compliance and ethics expectations are set out in our Code of Conduct and in training and other communications (such as internal compliance policies and expectations) we provide to some of our suppliers and other third parties, and to our employees with direct responsibility for supply chain management. Failure by an employee to meet our compliance and ethics standards may subject an employee to disciplinary action, including up to termination.
KS&T selects and assesses all suppliers with care and seeks to perform appropriate diligence before conducting business with each supplier. KS&T will act to discontinue relationships with those suppliers and other third parties who fail to meet its high standards for lawful and ethical conduct.
United Kingdom Disclosure Statements
Koch Metals Trading Limited (KMTL), Koch Commodities Europe Limited (KCEL), Koch Energy Europe Limited (KEEL) and Koch Supply & Trading Company Limited (KSTL) are U.K. registered companies numbers GB 3320973, GB 6858997, GB 6715779 and GB 1144618 with the group VAT registration number GB 341 4539 69, each with its registered address at 20 Gresham Street, London, EC2V 7JE. KMTL and KEEL are authorized and regulated by the Financial Conduct Authority and appear on The Financial Services Register under numbers 184882 and 497283.
KMTL Remuneration policy
Koch Metals Trading Limited operates a remuneration policy which complies with the requirements of the FCA’s Remuneration Code at SYSC 19A. Its policy is intended to be consistent with and promote sound and effective risk management. The policy is subject to annual review and approval by the board of directors. Having regards to the applicable proportionality framework, KMTL considers itself to be a Tier 3 firm.
Section 4.3A.11R of the FCA’s Handbook, Senior Management Arrangements, Systems and Controls (“SYSC”), requires us to explain on our website how we comply with the requirements of SYSC 4.3A.1R to SYSC 4.3A.3R and SYSC 4.3A.4R to SYSC 4.3A.11R.
The Koch Metals Trading Limited (KMTL) board of directors has overall responsibility for the firm and defines, oversees and is accountable for the implementation of its governance arrangements including those necessary to ensure compliance with SYSC 4.3A.
KMTL has a diversity policy to promote diversity on the board of directors. It considers a broad set of qualities and competences when appointing directors, including but not limited to the factors set out in SYSC 4.3A.3R. Members of the KMTL board of directors undergo regular training and induction, and have an experienced and extensive support organisation to assist them in fulfilling their management and supervisory functions. KMTL has established procedures to ensure that members of its board of directors do not hold more directorships than is appropriate taking into account individual circumstances and KMTL’s activities.