Speaking on Behalf of Albemarle

CODE PRINCIPLES

When talking about Albemarle or sharing Company information we act as brand ambassadors of the Company and our Core Values. We protect Albemarle’s reputation by speaking with clarity, accuracy, integrity and transparency.

  • We are strategic and thoughtful when identifying opportunities to speak on behalf of Albemarle.
  • We comply with public disclosure laws and stock exchange rules, and disclose material non-public information only through authorized spokespersons.
  • We do not publicly communicate in any way that is false, misleading or would damage our personal reputation or Albemarle’s reputation.
  • We do not use our public communications to inappropriately disclose information to or otherwise illegally coordinate with competitors.
  • We do not disclose publicly proprietary or other confidential information of Albemarle or our business partners without appropriate authorization.
  • We do not use the intellectual property of others in our public communications, unless authorized to do so by the owner.

Our Code Principles in Action

  • Follow the Albemarle Identity Guidelines when preparing any public communications.
  • Only use authorized imagery, logos & templates (available at Brand Central) in your public communications.
  • Contact the Legal Department if you know or suspect business information of Albemarle or its business partners is about to be disclosed in the public domain without authorization.
  • Ensure that our business partners follow the Code of Conduct for Albemarle Business Partners if they are intending to issue public communications that relate to, or otherwise affect, Albemarle.

DEFINED TERMS

Competitors

Albemarle competes with third parties in several different ways and each falls into its own category of competitor. The competitor categories include:

Producers and resellers of competing products

Albemarle competes with other producers of lithium, bromine and catalyst products. This includes companies like FMC, Tianqim SQM, Grace, BASF, Lanxess and ICL.

Albemarle also competes with companies engaged in the resale or trading of lithium, bromine and catalyst products, whether those products are produced by Albemarle or a third-party.

Procurement of goods, services and land

The list of Albemarle competitors in the procurement market is potentially much broader than speciality chemical producers.

For example, Albemarle might compete with contractors such as Wood for the procurement of vehicles suitable for our sites.

Broader still is the class of competitors for accounting and legal services, which nearly all companies procure to varying degrees.

Hirers of employees and contractors

Albemarle also competes with a broad range of companies in recruitment and remuneration of employees and contractors

Intellectual Property

includes intangible assets such as processes, compositions of products, other technologies, customer lists, production strategies, and the like, which are trade secrets known only to Albemarle, and provide Albemarle with a competitive advantage. Patents, copyrights and trademarks, which Albemarle has the right to exclude others from using, are also intellectual property. Any aspect of daily operations at Albemarle, in an office lab or manufacturing facility, should be considered to be Albemarle’s intellectual property.

Material Non-Public Information

“Non-public” information is any confidential information concerning Albemarle or its affairs (extending to customers, suppliers and business transactions). Information is considered to be “material” if a reasonable investor would be likely to take the information into account when deciding whether to buy, sell or hold Albemarle securities. Any information that could be expected to affect the price of Albemarle securities, whether it is positive or negative, should be considered material. There is no bright-line standard for assessing materiality; rather, materiality is based on an assessment of all of the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight.

By way of example, material non-public information can include information about topics such as sales, earnings, projections, corporate developments, new products, research projects, impairments, layoffs, acquisitions, divestitures, financings, joint ventures, threatened or actual litigation, and other business matters concerning customers, suppliers or other companies with whom the Company does business or has relationships.

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