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Governance

Deliberate Ethics™ guides everything we do at Solenis

Our Commitment to Ethics and Compliance

Goal: All employees complete Code of Conduct Training 

Solenis is firmly committed to conducting business throughout the world in accordance with the highest legal and ethical rules and principles. Our Global Standards of Business Conduct, available to our employees in 22 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. 

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. 

Additionally, anyone can raise concerns confidentially and anonymously, if desired, with our Legal Department and our Office of Ethics and Compliance via our online portal  “Share Your Concern”.  

As an alternative, concerns can be shared via the phone following the instructions below and, for further details, review our Reporting Policy. 

  • U.S. / Canada – Use toll-free number (833) 203 3981 

Please note that Solenis takes your data protection seriously. To find out more about how Solenis processes personal data when reporting of suspected misconduct through our internal reporting channels, please review Solenis Whistleblowing Privacy Notice. 

Placing people and the planet first with sustainable practices

<p><span class="TextRun SCXW46409934 BCX8" lang="EN-US" xml:lang="EN-US" data-contrast="auto"><span class="NormalTextRun SCXW46409934 BCX8">We create value for customers &mdash; and all our stakeholders &mdash; by aligning our everyday business practices with the highest legal, </span><span class="NormalTextRun SCXW46409934 BCX8">ethical</span><span class="NormalTextRun SCXW46409934 BCX8"> and operating practices. From stewardship that fully manages each product&rsquo;s life cycle to </span><span class="NormalTextRun SCXW46409934 BCX8">demonstrating</span><span class="NormalTextRun SCXW46409934 BCX8"> social responsibility performance recognized by </span></span><a class="Hyperlink SCXW46409934 BCX8" href="/link/2af4df408d7e4916ab993633a9e0da48.aspx" target="_blank" rel="noreferrer noopener"><span class="TextRun Underlined SCXW46409934 BCX8" lang="EN-US" xml:lang="EN-US" data-contrast="none"><span class="NormalTextRun SCXW46409934 BCX8" data-ccp-charstyle="Hyperlink">EcoVadis</span></span></a><span class="TextRun SCXW46409934 BCX8" lang="EN-US" xml:lang="EN-US" data-contrast="auto"><span class="NormalTextRun SCXW46409934 BCX8">, Solenis is fully committed to operating principles that </span><span class="NormalTextRun SCXW46409934 BCX8">comply with</span><span class="NormalTextRun SCXW46409934 BCX8"> applicable environmental guidelines and provide solutions that help customers meet or exceed their own sustainability goals.</span></span><span class="EOP SCXW46409934 BCX8" data-ccp-props="{}">&nbsp;</span></p>

Human Rights
<h3>Governance Policies &amp; Topics</h3> <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>
ANTI-CORRUPTION 

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.

ANTI-HARASSMENT 

Solenis does not tolerate unwelcome conduct, whether verbal, nonverbal or physical, that is based on a person’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.

ANTITRUST AND COMPETITION LAWS 

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.

DATA PROTECTION GOVERNANCE 

The Solenis digital security program 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. 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 ISO 27001 certification which underscores our commitment to ensuring the highest level of information security.  

ISO 27001 certification
DATA PROTECTION IMPACT ASSESSMENT 

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.

GLOBAL TAX STRATEGY 

Solenis is committed to being globally compliant with all relevant tax laws and regulations. Our Global Tax Strategy necessitates strong governance and consideration of our global business reputation, while delivering value to all stakeholders.

GLOBAL TAX STRATEGY
REPORTING AN ETHICS CONCERN 

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.

WORPLACE VIOLENCE 

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.

SEDEX (SUPPLIER ETHICAL DATA EXCHANGE) 

As a member of Sedex since 2017, Solenis utilizes the Sedex secure and confidential online database to share information with our customers. This allows us to demonstrate our own sustainability performance while simultaneously enabling our customers to meet their own sustainability targets. Every Solenis production site supplying a product to a particular customer must complete a self-assessment questionnaire. This questionnaire was recently updated by Sedex and aligns with the Sedex Members Ethical Trade Audit (SMETA) pillars: Labor, Health and Safety, Business Ethics and Environment. In 2020, Solenis manufacturing sites that are current Sedex members (currently 68%) complied with the new questionnaire to include how our sites operate and what systems are in place to manage social and environmental challenges. Solenis intends to register the remaining manufacturing facilities as Sedex members in the near future. As a result, our customers will have full transparency to all Solenis manufacturing plant data in support of the four SMETA pillars.

Risk Management – Operations

Solenis operates facilities in the United States that are subject to the U.S. EPA’s Risk Management Plan (RMP) regulations. Under 40 CFR 68.210, Solenis is required to make the following information available to the public to comply with the Chemical Hazard Information section of the regulations: 

We understand that we must achieve these goals to maintain our relationships with our customers. 

RMP Chemical Information 

  • Name of RMP-regulated substance(s)
  • Safety data sheet(s) (SDS) for regulated substance(s) 

RMP History and Planning 

  • 5-year RMP accident history
  • List of scheduled exercises
  • Emergency response plan summary information 

RMP Emergency Response Details 

  • Whether the stationary source is a responding stationary source or a non-responding stationary source
  • Name and phone number of local emergency response organizations with which the owner or operator last coordinated emergency response efforts
  • For stationary sources subject to 40 CFR 68.95, procedures for informing the public and local emergency response agencies about accidental releases 

RMP Community Information 

  • Local emergency planning commission contact information
  • How to access information on community preparedness 

Regulatory Essentials

Key Assets For Compliance Success

<p>Get the key resources to streamline your compliance process.&nbsp;</p>

Risk Management Plan Request Form
Finland Risk Management Plan
German Seveso Directive Information
Explosives
Sedex Certificate
Documents and Polices

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