Human Rights Policy
We are committed to conducting business in an ethical manner that respects human rights. It is our policy that Ecovyst and its vendors, suppliers, contractors, consultants, and agents must comply with all applicable human rights laws and not utilize any form of forced labor, human trafficking or modern day slavery. Any allegations of violations of this policy will be thoroughly investigated and, if appropriate, corrective actions will be taken.
We adhere to UK Modern Slavery Act 2015 and California Transparency in Supply Chains Act 2010 and other representative regulations and encourage our supply chain to take active measures to do the same.
Code of Conduct
We maintain a robust Code of Conduct that sets forth the guiding ethics and compliance principles all of employees must adhere.
Labor Policy (EEO)
Ecovyst is an Equal Opportunity Employer, and we are committed to our long-standing values of inclusiveness and anti-discrimination practices. Ecovyst does not discriminate based on race, color, religion, sex, sexual orientation, pregnancy, gender identity and expression, national origin, disability, age (40 and above), ancestry, veteran status, genetic information, marital status or any other classification prohibited by applicable law. These values run true throughout our organization, subsidiaries, and affiliates, underpinning our Equal Employment Opportunity Policy Statement.
We believe in the ongoing training and development of our people across all facets of the organization. We have regular training across health, safety, environment and security (HSES); ethics; Code of Conduct; and cybersecurity. We also have a robust leadership training program and training for all HR policies on an ongoing basis to promote excellence across the organization and provide opportunities to our team members. All employees must take Code of Conduct training within the first two weeks of hire, and as of 9/30/21, we had over a 99% completion rate across our employees.
Additionally, Ecovyst conducts HSES training using several different formats ranging from face-to-face and on-the-job training to the use of customized digital technology. In 2020 and earlier in 2021, during periods of increased remote work due to Covid, we increased the use of multiple digital and video training systems. Due to the pandemic, we used these unique technology-based systems for our remote employees or in situations where we were unable to hold larger group in-person meetings to extend compliance throughout our enterprise.
Sarbanes Oxley Compliance (SOX)
Ecovyst management is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act. Applying the criteria for effective internal control over financial reporting described in the “Internal Control Framework” (2013) set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO), management continuously assesses the Company’s internal controls and reports the results of those assessments in our periodic filings with the SEC. Our effectiveness assessments are audited by PricewaterhouseCoopers LLP, an independent registered public accounting firm. Their opinion is also included in our periodic filings with the SEC.
Ecovyst has set up a comprehensive policy for employees to report perceived ethics violations or other wrongdoing at the company. Employees are trained, via the Ecovyst Code of Conduct, in-person training and other communications, that they must report violations to the Chief Administrative Officer, the Chief Compliance Officer, or anonymously through the Ecovyst Concern Line, a dedicated hotline what is operated by an independent third-party organization. All cases reported either directly to company management or through the Ecovyst Concern Line are thoroughly investigated and, when necessary, corrective actions are instituted in a timely fashion.
Complaint Investigation Process
We have had our Ecovyst Concern Line in place since 2004. It is comprised of dedicated phone lines, both domestic and international, and an email that allows employees to have a risk free and anonymous way to express concerns or identify activities that may be a violation of company policies, local laws, or the company’s Code of Conduct. We believe our complaint investigation process supports our express interest in providing a safe and fair environment for all employees, no matter where they work within our organization.
Data Privacy and Cybersecurity
Our data privacy policies are kept up-to-date and are shared with all employees. Additionally, we have detailed cybersecurity measures in place, along with distinct reporting requirements, to protect company intellectual property during employee travel to regions considered a higher risk for loss of intellectual property. The policies apply to all electronic media and devices hosting company data and to all employees, contractors, consultants, temporaries, and agents operating on behalf of the company.
Our employees also are required to maintain the secrecy of third-party confidential information that may be provided to the Company and also to protect the personally identifiable information of individuals in accordance with the EU’s General Data Protection Regulation and other applicable laws.
We also have a Cybersecurity Incident Response Policy in place that establishes standards for responding to any kind of cybersecurity incident. We are dedicated to protecting personal identifiable information and the company’s daily operations. And finally, we have internal policies in place to provide timely responses to any form of cybersecurity incident/ breach to protect the company’s intellectual property, as well as abide by all relevant local laws.