Supply Chain Transparency Statement
Disclosure under the California Transparency in Supply Chains Act of 2010 (Senate Bill 657) (the “Act”)
On January 1, 2012, the Act went into effect in the State of California. This law was designed to increase the amount of information made available by manufacturers and retail sellers regarding their efforts (if any) to address the issue of slavery and human trafficking thereby allowing consumers to make more informed choices regarding the products they buy and the companies they choose to support.
Western Refining, Inc., and its affiliated companies, including, but not limited to, Western Refining Company, L.P. (together “Western Refining”), are an independent crude oil refiner and marketer of refined products. Western Refining’s supply chain includes acquiring crude oil for processing into finished products and other materials and services necessary for the operations of its refinery. In Western Refining’s experience, this type of supply chain is not inherently susceptible to violations of slavery and human trafficking laws. Notwithstanding this limited risk, Western Refining recognizes and respects all laws designed to protect its and its suppliers’ employees, including, but not limited to, those laws that require it and its suppliers to treat workers fairly, to provide a safe working environment and to protect the quality of the workers’ work environment. Western Refining is committed to ensuring that its supply chain reflects Western Refining’s standards for business ethics, integrity and values, and respect for human rights.
1. To ensure that Western Refining’s supply chain reflects its standards for business ethics, integrity and values, Western Refining’s corporate policy provides that Western Refining’s relationships with its suppliers shall be based on efficient and fair practices. Western Refining relies on suppliers who are required by contract to comply with all laws, which may include, among others, laws that require them to treat workers fairly, to provide a safe and healthy work environment, and to protect environmental quality. Western Refining may verify a supplier’s prior record for compliance with laws by engaging a third-party to complete a global background check on the supplier.
2. At this time, because Western Refining’s supply chain is not inherently susceptible to violations of slavery and human trafficking laws, it does not audit its suppliers to evaluate compliance with slavery and human trafficking laws. Western Refining’s contracts with its suppliers, however, require the suppliers to comply with all laws, which may include, among others, laws that require them to treat workers fairly, to provide a safe and healthy work environment, and to protect environmental quality.
3. Western Refining requires its suppliers to agree that they will comply with all laws, which may include, among others, laws pertaining to human rights, anti-slavery and anti-human trafficking; at this time, it does not separately require them to certify compliance with these laws.
4. Western Refining maintains accountability procedures for suppliers regarding compliance with Western Refining’s standards for business ethics, integrity and values. Western Refining is committed to ensuring its suppliers engage in responsible and ethical business practices, and reserves the right to exercise its contractual rights against any supplier found to be in violation of applicable laws. At least annually, Western Refining reminds existing suppliers of the importance of its Code of Business Conduct and Ethics (the “Code of Conduct”).
Western Refining also maintains accountability procedures and demands commitment to its standards for business ethics, integrity and values from its directors, officers and employees and relies on a robust Code of Conduct to set forth expectations for every member of its Board of Directors, officers and employees. Western Refining also has an additional Code of Ethics that applies to its Chief Executive Officer, the Chief Financial Officer and the Principal Accounting Officer. Under the Code of Conduct, Western Refining’s officers and directors are required to annually certify compliance with the Code of Conduct and Code of Ethics. In addition, each and every employee is trained on the Code of Conduct and annually is required to acknowledge the Code of Conduct. Officers, directors and employees who violate the spirit or letter of the Code of Conduct, or Code of Ethics, as applicable, are subject to disciplinary action up to and including termination of their employment.
5. Western Refining conducts training on its values, Code of Conduct and Code of Ethics, with a particular focus on mitigating risks to employees. Western Refining employees are trained on health, safety, and labor and employment best practices, and are trained to report deviations. This includes suspicious activity, including, but not limited to, the treatment of workers and the quality of the worker’s work environment. Western Refining takes seriously all potential legal and Code of Conduct and Code of Ethics violations, and encourages all persons subject to its Code of Conduct to preserve Western Refining’s standards for business ethics and integrity by reporting suspected Code of Conduct violations and comments, complaints and concerns regarding safety, the environment, human resources, and ethics to their supervisors, human resources representatives, regulators or through the Western Refining Employee Hotline at 1-800-799-6214.