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Corporate Governance

Deliberate Ethics™ guides everything we do at Solenis.

Results

95%

Of all employees completed training.

Our Commitment to Ethics and Compliance

Goal:All employees complete Code of Conduct Training

<p>Solenis is firmly committed to conducting business throughout the world in accordance with the highest legal and ethical rules and principles. Our&nbsp;<a href="/link/5ca399b82c534ed6a719054c973f64f2.aspx">Global Standards of Business Conduct</a>, available to our employees in 15 languages, is the cornerstone of this commitment and sets expectations for every employee when interacting with each other, customers, business partners and people in the communities where we do business. In addition, any business partners acting on behalf of Solenis in any country, including agents, consultants, contractors, distributors or other third-party representatives, are provided a copy of the guide and required to acknowledge compliance.</p> <p>While many laws have international application, Solenis recognizes the importance of observing diverse local customs and the laws of the countries where we do business. If compliance with the Global Standards of Business Conduct or other corporate policies or procedures appears to conflict with local laws or regulations, employees are directed to discuss their concerns with our Legal department.</p> <p>Additionally, anyone can raise concerns confidentially and anonymously, if desired, with our Legal department via our on-line portal &nbsp;<u><a href="https://www.lighthouse-services.com/solenis">&ldquo;Share Your Concern&rdquo;</a></u>.&nbsp; As an alternative, concerns can be shared via the phone.</p> <ul> <li>U.S. / Canada &ndash; Use toll-free number (833) 203 3981</li> <li>Outside the U.S./Canada &ndash; <span style="background-color: rgb(255, 255, 255);"><a href="/link/4ce48a2601db40c7b7544cb758df0851.aspx" target="_blank" rel="noopener">Click here for language instructions</a>.</span> Obtain your&nbsp;<span style="background-color: rgb(255, 255, 255);"><a style="background-color: rgb(255, 255, 255);" href="https://www.business.att.com/collateral/access.html"><u>access codes,</u></a>&nbsp;and then</span>&nbsp;dial 800 603 2869 to connect to the hotline.</li> </ul>

Results

95%

Of all employees completed training.

<h2>Governance Policies</h2> <p>While the Global Standards of Business Conduct is the basis of our worldwide compliance program, an international committee of senior leaders provides executive oversight and direction. The group reviews and endorses activities including training and education, completion of compliance assessments and audits, and driving personal accountability through communication and awareness initiatives. Each year, employees receive the Global Standards of Business Conduct questionnaire and acknowledgment certification form, asking if they are aware of any violations of our standards or company policies, or of any actual or potential conflict of interest involving an employee.</p>
<p>Solenis is committed to profitably growing our business based solely on the merits of our portfolio of offerings and the capabilities of our team. We comply with anti-bribery and anti-corruption laws applicable where we operate, including, but not limited to, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Solenis employees and third-party representatives are strictly prohibited from the payment of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. Yearly certification is conducted to ensure employee compliance and we keep books, records and accounts that accurately and fairly reflect in reasonable detail our foreign and domestic transactions.</p>
<p>Solenis does not tolerate unwelcome conduct, whether verbal, nonverbal or physical, that is based on a person&rsquo;s age, disability, gender, genetic characteristic, national origin, race, color, religion, sexual orientation, veteran status or other protected group status. This includes unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal or physical conduct of a sexual nature. We do not tolerate harassment of our employees by co-workers, supervisors or anyone they encounter while conducting business.</p>
<p>We are committed to full compliance with U.S. and European Union antitrust and competition laws, and similar laws of the other countries where we do business. Employees must learn the legal requirements of the jurisdiction where they work by seeking the advice of our Legal department and/or from other policies and training materials. Our representatives may not engage in price-fixing, bid-rigging, market or customer allocation or any other activity that violates applicable laws.</p>
<p>The Solenis digital&nbsp;security program&nbsp;assures that we have the correct information structure to protect our operations and the reliability and confidentiality of business and individual data. This includes employing the latest technologies, understanding and identifying potential vulnerabilities and educating our employees and third-party partners as to their roles and responsibilities.</p> <p>Internal and external information technology assessments are conducted multiple times per year by industry recognized third parties. All identified risks are reported to our Operating Council, quickly remediated, and retested. Solenis has achieved <a href="/globalassets/resources/sustainability--regulatory-library/iso-27001-2013.pdf">ISO 27001 certification</a> which underscores our commitment to ensuring the highest level of information security. &nbsp;</p>
<p>Our process allows us to consider data privacy risks from the outset of a project, build in privacy controls and apply the principles of privacy by design and default. Data processing projects are designed with privacy compliance in mind and the most private options are selected by default. The process continues throughout the development and implementation of a project.</p>
<p>Solenis is committed to being globally compliant with all relevant tax laws and regulations. Our <a title="Global Tax Strategy" href="/en/global-tax-strategy/">Global Tax Strategy</a> necessitates strong governance and consideration of our global business reputation, while delivering value to all stakeholders.</p>
<p>Each Solenis employee has the responsibility to report or share in good faith any concerns about actual or suspected violations of our Global Standards of Business Conduct, policies and procedures or any laws or regulations governing our operations. We encourage employees to use our hotline, Share Your Concern, a global internet and telephone information and reporting service, to make a confidential report. All are investigated and no adverse actions can be taken against any employee who acts in good faith. Share Your Concern is available 24 hours a day, seven days a week and a translation service is available for callers who do not speak English.</p>
<p>Solenis has zero tolerance for any threatened or actual workplace violence, whether onsite at our facilities or anywhere that an employee is conducting our business. This includes conduct that is threatening, intimidating, abusive, harassing, or otherwise violent whether verbal, non-verbal, physical or written. Employees who know or suspect a transaction or relationship may be in violation of this policy must report such concern immediately.</p>

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