Creating, Managing & Disclosing Business Information

CODE PRINCIPLES

The business information we create or receive is valuable and must be managed and protected much like any other Albemarle asset.

  • We create business information that is clear, accurate, complete and in accordance with applicable policies, laws, accounting rules and practices.
  • We ensure that business information accurately reflects the underlying transaction or event.
  • We correctly classify the type and sensitivity of our information to ensure appropriate information security protection is applied.
  • We do not falsify, alter, destroy or tamper with business information to misrepresent or conceal a transaction or event.
  • We treat Albemarle’s business information with care and take appropriate steps to protect it from unauthorized access or disclosure.
  • We do not disclose Albemarle business information to other employees, contractors or third parties unless authorized to do so.
  • We do not use Albemarle’s business information for personal benefit.

Our Code Principles in Action

  • Return all business information prior to leaving the Company.
  • Obtain authorization in accordance with the Global Information Security Policy before transmitting confidential information, crown jewel information or personal data to third parties.
  • Comply with non-disclosure agreements, both during and after employment, that are signed with the Company, your former employer or other third parties.
  • Preserve business information and communications if you are instructed to do so by the Legal Department.
  • In accordance with this Code (Speaking Up), immediately report any business information that you suspect has been falsified, altered, destroyed or tampered with.
  • In accordance with the Data Breach Procedure immediately report all inappropriate, accidental or unauthorized disclosure, access or use of personal data or Albemarle business information to databreach@albemarle.com
  • Secure confidential information or personal data in accordance with the Global Information Security Policy.

DEFINED TERMS

Business Information

May include marketing plans; proprietary perspectives on the market; cost data; details of negotiations with individual customers or suppliers; current or recent terms of sale or purchase; strategic information relating to asset expansion, joint venture or M&A activity; salaries and other terms of employee remuneration; innovation plans and intellectual property; production, export, sales and purchase data and any other financial data or forecasts.

Personal Data

Any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Particularly sensitive personal data often has additional restrictions on its processing and use, and includes data relating to:

  • racial or ethnic origin;
  • health; or
  • trade union memberships.
Crown Jewel Information

Data containing information where unauthorized access or distribution can cause material loss and significant harm to the company. The following categories are considered crown jewels:

  • conception records;
  • lab notebooks;
  • research & development documentation;
  • research & development project reports;
  • experimental results;
  • product and process know-how;
  •  partner IP;
  • custom built models; and
  • manufacturing knowhow.

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