Recording Business & Financial Transactions

CODE PRINCIPLES

We make good decisions and maintain the trust of our investors if the Albemarle financial information provided to them is accurate and complete. Albemarle maintains internal controls to ensure that our books and records fully and objectively reflect our business and financial transactions and their underlying business purpose in a materially accurate manner.

  • We only execute transactions in accordance with this Code, applicable policies and laws. It is our personal responsibility to know those requirements.
  • We only approve transactions within the scope of our delegated authority.
  • We validate transactions and the source, destination and transmission of funds through appropriate supporting documentation.
  • We do not intentionally create false, incomplete or misleading entries in our books or records.
  • We do not use Albemarle funds or assets in violation of our Code or applicable law.
  • We do not establish or maintain undisclosed or unrecorded Company funds or assets.
  • We record all intercompany transactions at arm’s length, and in accordance with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
  • We are honest, transparent and timely in our engagement with auditors and tax authorities.
  • We immediately report concerns with the accuracy of our books and records, the integrity of our internal controls or any suspected fraud.
  • We collect and understand documentation about prospective business partners to ensure that they are involved in legitimate business activities and that their funds come from legitimate sources.

Our Code Principles in Action

  • Ensure all expenses are correctly assigned to the correct General Ledger account.
  • Employees outside of Treasury who undertake treasury/banking-related activity must be approved, in writing, by either the Treasurer or Chief Financial Officer.
  • All foreign exchange transactions must be undertaken in accordance with the Financial Price Risk Management Policy.
  • Provide Treasury with appropriate documentary evidence, and contact details for the payee, to support the transmission of funds.
  • Familiarize yourself with the Guidance Notes on the Effective Monitoring of Third- Party Sales Representatives and Customers and the Effective Monitoring of Vendors. Check for red flags such as:
    • overly complicated deal structures;
    • requests from a business partner for cash payments;
    • payments from payors that appear unrelated to the payee;
    • unusual fund transfers to or from countries unrelated to the transaction;
    • transactions that have been structured to evade recording or reporting requirements; or
    • other suspicious payment terms.

DEFINED TERMS

Books & Records

U.S. law requires companies such as Albemarle to make and keep books, records, and accounts that, in reasonable detail, accurately and fairly reflect the company’s transactions and disposition of assets.  Such books and records include: any document or record that describes financial information (e.g. profit & loss statements, balance sheets, journal entries, expense claims); business transactions (e.g. tender/bid documentation, purchase orders, invoices, price authorizations, contracts); operations (e.g. maintenance records); individual activity (gifts & hospitality approval requests forms, conflicts of interest disclosure forms, timesheets, telephone records); or regulatory submissions (e.g. tax filings).

Internal Controls

The processes used by companies to provide reasonable assurances regarding the reliability of financial reporting and the preparation of financial statements.  U.S. law requires companies such as Albemarle to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that transactions are executed in accordance with management’s authorization, unauthorized payments are not made, and the company can prepare its financial statements in accordance with generally accepted accounting principles.

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