Supply Chain Transparency

The California Transparency in Supply Chains Act of 2010 (SB 657) requires companies that manufacture or sell products and operate in the State of California to provide information regarding their efforts to eradicate slavery and human trafficking in their direct supply chains. The law was designed to increase consumers’ knowledge about products they buy and the companies they choose to support.

Rentech, Inc. and its subsidiaries (“Rentech”) are committed to complying with applicable law wherever we operate and conducting all business activities in accordance with the highest ethical standards. We expect the same of the parties with which we do business. Our ethical standard is reflected in our Code of Business Conduct and Ethics (“Code”) and our Employee Handbook (“Handbook”) which outline our expectations of ethical conduct and compliance with all laws from our employees, agents and other representatives.

In addition to receiving our Code and Handbook, employees involved in procurement are provided with additional ethics and compliance training. Rentech maintains (i) a 24/7 whistleblower hotline where employees can anonymously submit any concerns of possible ethics and compliance violations, including slavery and human trafficking, and (ii) an employee concern program established to address employee concerns openly and in an objective manner. Every concern that is submitted under either program is reviewed and handled accordingly. Any employee or contractor who is found to have violated the Code or Handbook is subject to disciplinary action, up to and including termination of employment or contracts, as the case may be, and referral to appropriate legal authorities.

Rentech expects its suppliers to comply with legal requirements and operate consistently with the principles of the Code when working on our behalf. Accordingly, we consider these issues when we assess potential suppliers and typically require suppliers to represent in the applicable supply agreement that their performance under such agreement will be in compliance with all applicable laws and regulations. While Rentech does not have a formal verification program, we do perform periodic audits of suppliers to evaluate and address issues relating to compliance with laws and regulations and Rentech’s policies, processes and procedures.