Compliance

For Archroma, there is no other way to do business than in a sustainable and responsible way. Archroma is therefore committed to act with integrity and in strict compliance with the law.

Archroma has a Code of Conduct for employees, signed by the Chief Executive Officer and publicly available, which sets out the binding rules and guidelines to the employees and officers of Archroma. This enables employees to rely on the Code as a navigation guide, and one another’s good judgement, to uphold a high standard of integrity for the individual and Archroma.

Each employee is required to give a personal commitment to meeting the Code of Conduct; and in the reporting period, all employees were trained on the Archroma Code of Conduct, followed by a questionnaire requiring 80% pass rate. Archroma will conduct re-training on a regular basis.

Archroma takes responsibility for its employees, its customers, its suppliers, its other stakeholders and the environment in order to achieve profitable long-term business development. Archroma commits maintaining ethical and sustainable operation and business development in all activities according to its own Code of Conduct and Responsible Care®.

The Archroma Code of Conduct links all Archroma employees around the world in a collective commitment to integrity and excellence in all they do, by providing tools that will guide them in making consistent, sustainable decisions.

Additionally, Archroma request all vendors to ensure that they, including their employees and subcontractors, will follow our high ethical standards set forth in Archroma’ Suppliers Code of Conduct.

In particular, Archroma strictly prohibits all forms of corruption and any business conduct that could create the appearance of improper influence. Archroma is subject to numerous laws, both U.S. and non-U.S. that prohibit bribery in every kind of commercial setting. These principles are summarized in three rules:

1. No bribery under any circumstance;

1. Do not accept or offer kickbacks, even if moderate in value;

1. Third parties hired by Archroma are subject to these above principles.

Archroma also has a whistleblowing policy in place that allows the anonymous reporting of any suspicious situation of violations of our Code of Conduct or the law.

In addition, Archroma and its affiliated companies are committed to integrity and an open culture where everybody feels secure in seeking advice or raising concerns, and has confidence that reports are handled in a professional and transparent way. To help in its ability to provide advice and enable employees to report concerns or misconduct, the Archroma Code of Conduct and Whistleblower Policy are essential element of integrity in the commitment to an open culture where people feel secure in seeking advice and in raising concerns. Archroma ensures a retaliation-free environment to anyone who comes forward in good faith to ask questions or report violations.

It is a duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this policy. According to the company’s Code of Conduct and Whistleblower Policy, employees shall immediately disclose to the company any knowledge or suspicion of plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the company.

We also invite our employees and any third party to report confidentially to us any incident or concern pertaining to compliance at Archroma contrary to our Code of Conduct or the law by reporting it for proper investigation on the Archroma Whistleblowing Portal. The platform is a safe space for our employees and any interested parties to speak up. It is powered by NAVEX EthicsPoint a recognized provider for 24/7/365 reporting systems.

Whistleblowers will be able to submit a report by phone or in writing in their own native language. The system makes it easy to report incidents or concerns and reports are forwarded instantly and discreetly to our Group Compliance Officer for review and proper handling, and the whistleblower can opt for follow-up after submission. Although you will be allowed to decide the appropriate level of anonymity when reporting an issue, we encourage you to disclose your identity for a more accurate investigation.

There are several ways of reporting a violation or concern on the Archroma Whistleblowing Portal (NAVEX Ethicspoint):

• NAVEX One Compliance Hub: https://archroma.navexone.eu/peoplehub
• Web Intake Site URL: archroma.ethicspoint.com
• Mobile Intake Site URL: https://archroma.navexone.eu

Archroma has set up a Compliance Council and a Compliance Officer holding regular meeting and responsible for investigating any potential violations in a professional and consistent manner, while safeguarding fundamental legal principles such as confidentiality, fairness and objectivity.

Any breach of the Code of Conduct is reported to the Compliance Council, investigated and if necessary prosecuted according to the company’s disciplinary procedure and/or criminal action, should the case apply.

Regular internal audits are performed. The audit plan is based, in addition to other elements, on the Corruption Perception Index, that is published annually by Transparency International.