CODE
of conduct

responsible enterprise

human responsibility

*Health and Safety:

The safety of people is one of Parex USA's key values.

Fully integrated into the management of the company, it is built around three axes:

Respect by all of 5 essential rules:

• Wearing personal protective equipment;
• Compliance with traffic rules on sites;
• Safe practices for lifting heavy weights;
• A place for everything and everything in place;
• Implementation of logout/tagout procedure before working on equipment.

Each manager has the duty to train, supervise and support his/her teams in living up to this responsibility, playing a hands-on role in safety.

Reporting, analysis and prevention of accidents:

Each accident, with or without lost time, involving permanent staff, temporary staff or contractors must be notified within 24 hours by the local General Manager to the CEO and the Safety Director.

For each accident, a root cause analysis is set up in order to implement corrective and preventive actions.

To strengthen accident prevention, Parex USA has developed reporting and analysis for near misses and first aid situations.

Parex USA strongly encourages its employees to report any accident or incident. To set up corrective actions, neglected, delayed or incomplete reports are not in the company's interest.

Sharing good practices:

The Parex USA Safety Coordinators Community, led by the Safety Director, brings together the heads of Safety of each country and is responsible for:

• sharing Safety culture at all levels;
• sharing best practices among Parex USA.

*Labor and Social Standards:

Human rights:

Parex USA is committed to supporting fundamental and worldwide recognized human rights as it conducts its operations throughout the world.

We respect and support the dignity, well-being and rights of our employees, their families and the communities in which they live.

We are particularly committed to the abolition of all forms of child or forced labor.

Diversity and equality:

One of Parex USA's strengths is the diversity of its workforce between genders, nationalities and backgrounds working together and sharing common objectives.

Thus we prohibit any discrimination based on one's race, religion, gender, nationality or age or any other characteristic protected by local or international law.

We support fair employment practices and offer equal opportunities in the hiring and career development of our employees.

Harassment:

Fostering a harassment-free working environment requires mutual respect.

We expect all our employees to treat each other and any third parties such as customers, vendors or visitors in a professional, respectful, trustworthy manner and to foster individual dignity.

Trade union and personnel representatives:

Parex USA strives to build fair, transparent and constructive relationships with its employees and their representatives.

We do not tolerate any discrimination or harassment against employees based on their membership or lack of membership to a trade union. We do respect the rights of our employees to freely decide to join trade unions or not and enter into collective bargaining agreements.

environmental responsibility

business integrity

Compliance with Laws and Internal Rules

The Parex USA policy is to comply with applicable legislation and regulations both domestically and when we operate internationally.

It is our collective and individual responsibility to know and apply the laws, regulations and requirements relating to our job. It is our collective and individual responsibility to strive to never expose Parex USA in any unlawful activities.

We also have internal policies, directives and guidelines at global and local levels, and employees are also expected to comply with these. In the event of ambiguity, the strictest rules must be applied.

fair competition

Parex USA relies on the quality of its products and services to sustain its expansion. Our success is closely linked to our way of doing business, which excludes all types of unfair competition and discriminatory practices.

Our policy is to promote fair competition. Therefore, all employees are required to rigorously adhere to applicable laws and regulations concerning antitrust, competition and fair trade in each country and region Parex USA conducts business.

Although these regulations may vary from one country to another, Parex USA excludes, as a general rule, any agreements or business relations with third parties that fix prices, divide markets, limit production or undertake any concerted practice with its customers or competitors, or abuse a dominant position.

international trade control

Parex USA is committed to complying with international trade control ("ITC") laws when engaging in international trade.

Employees responsible for export or import operations of goods and services must follow the guidelines provided in the PAREX ITC handbook. They must take the necessary precautions to prevent prohibited transactions with countries or individuals under sanctions.

anti-bribery

Parex USA's policy is to refuse all forms of bribery under any circumstances.

Nothing can justify non-recorded payments to any business partner or public authorities to obtain a business advantage.

Employees are requested to turn down any proposal for an indirect payment and to report it immediately to their managers, who will take the necessary actions. This policy applies to any direct or indirect payments in cash, kickbacks, advantages, benefits, etc.

Employees must ensure with their business partners that no such practices are undertaken by a third party on account of Parex USA.

gifts & hospitality

Gifts and hospitality are part of business life. However, they should meet international and local legal requirements.

In particular, close attention should be paid to relations with public officials to avoid situations that could be interpreted as bribery intention or corruption.

Parex USA entities should implement, publish and enforce rules in writing to further specify what is acceptable under this Code of Conduct, taking into account (i) the customary business environment of the local entity and (ii) the following principles that must be respected by all Parex USA entities.

Gifts

Parex USA employees are allowed to accept gifts of low value for specific occasions such as the New Year or an opening ceremony. It is recommended to have such presents made to the company and not to an individual.

Business partners may be offered gifts when the value of the gift remains within the limit of lawful local practice.

Gifts must be made in an open manner so everybody can witness the normality of the practice (for instance, a present should be delivered to a business address and handed over openly, never home delivered.)

Hospitality

Parex USA may handle travel, meal or entertainment expenses.

These should always be lawful, closely related to a business activity and appropriate to the purpose they are serving.

Expenses related to gifts and hospitality should be recorded using explicit wording.

money laundering

Money laundering is the use of business transactions to conceal the origin of illegal funds. It makes funds appear as legitimate, whereas they actually originate from unlawful activity.

It is the responsibility of each employee to question the source of payment if there is supposition that the funds stem from illegal activity.

Where suspicious financial transaction involving transfers of cash or cash equivalents are requested, prior review by and approval from the finance department is required to detect and prevent any irregularities. If necessary, a process of due diligence to check the integrity of the doubtful

payments can be carried out.

conflict of interest

Parex USA employees must prevent situations involving potential conflicts of interests.

Parex USA employees must inform their manager of any existing or potential conflict of interest. The manager will then decide what appropriate steps should be taken.

For example, doing business with a company, association or organization in which a relative or friend is employed is likely to create a conflict of interest because it may affect the objectivity of the decisions made by the Parex USA employee and thus be detrimental to Parex USA's interest.

confidential business information

Parex USA employees have access to sensitive information pertinent to Parex USA, and whose disclosure may hurt Parex USA interests.

This may be financial information, a marketing plan, an organization chart, a strategic plan, customer lists, information regarding technology and know-how, etc.

Employees are required to keep such information confidential, and not to communicate information outside of the company unless prior written approval has been obtained from the line of management and/or a confidentiality agreement has been entered into with the party receiving confidential information.

Similarly, information from our business partners that is identified as confidential should be dealt with in the same manner.