The California Transparency in Supply Chains Act of 2010 (SB 657, which adds to California Civil Code Section 1714.43) requires certain retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains.
This disclosure is made by Castrol Lubricants USA Inc. (“Castrol”, “we”, “our” or “us”) in relation to its activities in California. Castrol separated from the bp group effective October 31, 2026, and is in the process of finalizing its own standalone policies, systems, and controls. This disclosure reflects the status of those efforts and will be updated as they are fully implemented.
Castrol’s Code of Conduct applies to all Castrol employees, directors and contracted staff worldwide. Third parties acting on Castrol’s behalf, including agents, distributors, suppliers and joint venture partners, are expected to act consistently with its standards. The Code of Conduct confirms Castrol’s commitment to respecting human rights across its operations and supply chains and states that suspected human rights violations in Castrol’s operations or supply chains must be reported.
Castrol utilizes risk-based assessment and verification activities in relation to labour rights and modern slavery where relevant risks are identified. Depending on the nature and level of risk, these activities may include supplier assessments, supplier audits, review of supporting evidence and other assessment approaches. These audit and verification activities are generally conducted through Castrol’s internal processes rather than by independent third parties, and audits are announced.
We do not require direct suppliers to certify that materials incorporated into the products they supply to Castrol comply with the laws regarding slavery and human trafficking of the country or countries in which they do business.
As of the date of this disclosure, Castrol requires its employees, directors and contracted staff to attest to the Code of Conduct. At this time, Castrol does not provide employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery. Castrol is considering its future training approach, including appropriate training on labour rights and modern slavery risks for personnel with relevant responsibilities.
Castrol maintains internal accountability standards and procedures for employees and contractors who fail to meet the Code of Conduct’s standards regarding slavery and trafficking, investigates suspected cases of non-compliance and may terminate contracts when a serious breach is found to have occurred.