Making Political Contributions on Behalf of Albemarle

CODE PRINCIPLES

At Albemarle, we only make political contributions to advance and protect the legitimate interests of our Company, not those of any one individual. These political contributions are only made if they are authorized and permitted under Company policy, applicable laws and regulations.

  • We do not make political contributions with the intent of improperly influencing any person in order to gain business or an improper advantage.
  • We do not provide sponsorships, charitable donations or other payments to circumvent applicable laws or Company policies relating to political contributions.
  • We do not use or allow others to use Albemarle assets or resources for any personal political campaign, political party, political candidate, elected official or any of their affiliated organizations.
  • We do not require or pressure employees to support any political party or politician, make personal political expenditures or take any retaliatory action against employees who decide not to contribute.

Our Code Principles in Action

  • Whenever you engage with politicians, political parties or affiliated bodies (e.g. think tanks) always consider whether your engagement could be viewed as some form of political contribution on the part of Albemarle. Contact Government Affairs or the Legal Department if you are unsure.
  • Consult with Government Affairs if you believe that the Company should make a political contribution.
  • Obtain approval in accordance with the Political Contribution Policy before making a political contribution on behalf of the Company in or outside of the US.
  • Follow this Code if you are contemplating engaging in personal political activity (Engaging in Personal Political Activity).
  • Follow this Code if you are considering offering anything of value, including gifts or hospitality, to a government official (which is defined to include a political party, party official or candidate for political office).

DEFINED TERMS

Anything of Value

is broadly defined to include any type of benefit to the recipient, such as:

  • money (all currencies including bitcoin, and method of delivery such as cash, check, wire, electronic, mobile transfer);
  • cash equivalents such as gift, store, discount, mobile phone or stored value cards
  • Gifts;
  • meals, entertainment and other hospitality;
  • travel, including flights and accommodation;
  • offers of employment or an internship;
  • a contract for the procurement or sale of goods or services;
  • a contract for the procurement, sale or lease of property;
  • a charitable donation or contribution to a community project;
  •  a commercial sponsorship;
  • confidential information;
  • investment opportunity; and
  • any other form of personal favor.
Government Official

Defined broadly, and can include:

  • an officer, employee or anyone acting on behalf of any government body including a department or agency at any level (national, regional, or local). Examples include a government minister, regulator, judge, city mayor, police officer, soldier, customs official or chemistry professor at a public university;
  • an employee of public international organizations such as the United Nations and World Bank;
  • an employee of state-owned or controlled enterprises, such as refineries;
  • a political party, party official or candidate for political office; and
  • a person holding an appointment, position or office created by custom or convention, such as, an indigenous community leader or member of a royal family.

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