November 14, 2023

Update on the Kallo case

Borealis’ response to claims regarding unpaid workers employed by subcontractors at propane dehydrogenation plant construction site in Kallo, Belgium

Borealis is committed to upholding a culture of ethics and compliance based on honesty, integrity and in accordance with all applicable legal requirements. Since the events of last year, we have taken several steps, clearly exceeding our actual responsibilities, to increase oversight of our Propane Dehydrogenation (PDH) plant construction site in Kallo, Belgium.

Borealis’ response to claims regarding unpaid workers employed by subcontractors at propane dehydrogenation plant construction site in Kallo, Belgium

Borealis is committed to upholding a culture of ethics and compliance based on honesty, integrity and in accordance with all applicable legal requirements.

Since the events of last year, we have taken several steps, clearly exceeding our actual responsibilities, to increase oversight of our Propane Dehydrogenation (PDH) plant construction site in Kallo, Belgium. As a result, we are aware of a number of issues with workers of Randridge International, a subcontractor of Equans, a subcontractor at this site.

Given the size and complexity of the world-scale PDH construction project in Kallo, we engaged Tecnimont as an EPCm (Engineering, Procurement & Construction Manager) for the overall management and communication with all contractors. One of these contractors is Equans, who have sub-contracted Randridge International. The contracts with our contractors for the Kallo PDH construction project have payment terms that are fully in line with Western European standards. We have no direct contractual relationship with our sub-contractors. As a consequence, and taking into consideration the restrictions of the General Data Protection Regulation (GDPR) requirements, the employer is the primary point of contact to ensure these obligations are met. It is the primary responsibility of the direct employer, Randridge, to ensure that all legal and contractual obligations are met for all of their employees. Borealis, as owner of the site, follows up on all cases brought to its attention with its contractors, until they are clarified.

We have received notifications about alleged payment irregularities on the side of Randridge International via our ethics hotline, a tool available in 24 languages which is open to all Borealis employees as well as external personnel working on our sites to report unethical behavior.

We regularly and swiftly follow up on all alerts received via this hotline. For all Randridge-related alerts, we have followed up on each alert individually, keeping issuers of alerts informed. We have urged our main contractor, Equans, to ensure their subcontractor Randridge timely and correctly pays their workers, and to issue written payment commitments to all workers earlier employed at our Kallo construction site. Meanwhile, first confirmations of payments have been received. Given the amount of whistleblowing alerts received, we have launched additional social compliance audits for sub/contractors involved.

Furthermore, we are in regular contact with the Belgian Social Security authorities and fully support their work.

END

For more information:
Borealis’ approach to Ethics and Compliance
About the Kallo case (comprehensive summary published in January 2023)

This publication is also available in Dutch and German language.

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