Anti-Slavery and Human Trafficking Policy Statement

1. Anti-Slavery and Human Trafficking Policy Statement

   Valero is committed to carrying out its business in a fair, ethical, honest and lawful manner, including promoting ethical and lawful employment practices, both within its own workforce and, to the extent applicable, within its various supply chains amongst its numerous Business Partners.

   Because Valero is also a U.S. government contractor, Valero is subject to enhanced anti-trafficking requirements, and must ensure its Employees and applicable Business Partners who perform services or provide supplies in support of Valero's performance of a U.S. government contract do not engage in any of the prohibited activities listed in this Policy Statement.

   Valero prohibits human trafficking and forced labor within its own organization and encourages its Business Partners to place equal importance on prohibiting such activities.

   1. Prohibited Activities

      All Employees and applicable Business Partners, who perform services or provide supplies in support of Valero's performance of a U.S. government contract, are expressly prohibited from engaging in the following activities:

      • Engaging in human trafficking;

      • Procuring commercial sex acts;

      • Using forced labor in the performance of work for Valero;

      • Destroying, concealing, confiscating, or otherwise denying access by an Employee to the Employee's identity or immigration documents, such as passports or drivers' licenses, regardless of issuing authority;

      • Using misleading or fraudulent practices during the recruitment of Employees or offering of employment, such as: failing to disclose, in a format and language accessible to the worker, basic information (or making material misrepresentations) during the recruitment of Employees regarding the key terms and conditions of employment, including but not limited to: (a) wages and fringe benefits, (b) the location of work, (c) the living conditions, housing and associated costs (if employer or agent provided or arranged), (d) any significant cost to be charged to the Employee, and, if applicable, (e) the hazardous nature of the work, and (f) using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;

      • Charging Employees recruitment fees;

      • Failing to provide return transportation or pay for the cost of return transportation upon the end of employment:

        1. For an Employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of

           working for Valero (for portions of contracts performed outside the U.S.); or

        2. For an Employee who is not a U.S. national and who was brought into the U.S. for the purpose of performing contract services at Valero, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the Employee (for portions of contracts performed inside the U.S.); except in the case of:

           1. An Employee legally permitted to remain in the country of employment and who chooses to do so; or

           2. An Employee exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation.

        3. Except where b.1 or b.2 apply, an Employee that is a victim of trafficking in persons and seeking victim services or legal redress in the country of employment will still receive return transportation or payment of the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity.

      • Providing or arranging housing that fails to meet the host country housing and safety standards; and

      • Failing to provide an employment contract, recruitment agreement, or other required work document timely, in writing, and in a language the Employee understands, if required by applicable law and regulations.

        Valero's Business Partners who do not perform services or provide supplies in support of Valero's performance of a U.S. government contract are encouraged to also abide by the foregoing prohibitions.

   2. Duty to Cooperate

      Valero has a duty to cooperate with FAR 52.222-50 and expects its Employees and Business Partners to assist the Company in fulfilling its duty to cooperate fully in providing timely and complete responses to requests for information and documentation and in permitting reasonable access to facilities and staff to allow Valero, any U.S. government contracting agency, and any other responsible U.S. government agency to conduct audits, investigations, or other actions to ascertain compliance with the Trafficking Victims Protection Act of 2000 (22 U.S.C. chapter 78), Executive Order 13627, or any other applicable law or regulation establishing restrictions on trafficking in persons, the procurement of commercial sex acts, or the use of forced labor.

2. Violations and Disciplinary Actions

   Valero takes seriously the enforcement of this Policy Statement. Any Employee found to be in violation of this Policy Statement shall be subject to discipline, up to

   and including immediate termination of employment. Any Business Partner found to be in violation of this Policy Statement shall be subject to suspension of contract payments until appropriate action is taken and, where appropriate, immediate for-cause contract termination. Offending Business Partner personnel are subject to immediate removal from the Valero facility.

3. Compliance Resources and Reporting Channels

Employees must immediately report to Valero any information received from any source that alleges violations of this Policy Statement by a Valero Employee or any Business Partner.

Employees should report suspected violations and are encouraged to ask questions regarding this Policy Statement by contacting the Compliance Department or by contacting the confidential Ethics Helpline, available at EthicsHelpline.Valero.com or by calling toll free 855-219-2495 (within the U.S. or Canada, if calling from outside the U.S. or Canada, use the telephone numbers listed on the website). In addition, alleged violations of this Policy Statement can be reported to the National Human Trafficking Hotline at 1-888-373-7888 or by texting HELP to 233733.