Speaking Up – Raising Code of Conduct Concerns

CODE PRINCIPLES

Speaking up about potential concerns helps Albemarle to improve understanding, prevent harm, manage risk and promptly address issues.

  • We demonstrate humility by asking questions when we are unsure and letting others know when we get things wrong.
  • We show care and courage by speaking up when we see something that concerns us, however minor.
  • We raise ethics or compliance concerns in good faith.
  • We respect the privacy, and secure the personal data, of those who are affected by an investigation
  • We preserve the anonymity of those who report concerns, if they have so chosen and where possible.
  • We cooperate with any internal or government investigation and answer questions honestly.
  • We prohibit any direct or indirect acts of retaliation against someone who reports a potential violation of this Code or applicable laws.

Do you have an ethics or compliance concern?

Speak up if you see or suspect activity that may be a violation of this Code or applicable law. You do not need to have all of the facts; it does not have to affect you personally; and you should never assume that someone else will report it. Speaking up demonstrates care for your Company and co-workers.

You are encouraged to speak with your supervisor or local site leader first

Do you feel uncomfortable speaking to your supervisor, or that your concern is not being properly addressed?
You can always speak to your HR Representative, Regional Compliance Manager or a member of the Legal Department.

You can also contact:
· The Chief Compliance Officer
· Global Ethics & Compliance via integrity@albemarle.com
· The General Counsel
· The Chair of the Audit and Finance Committee of the Albemarle Board of Directors

You can also contact The Integrity Helpline

The Integrity Helpline is operated by an independent company, and can be contacted 24 hours a day, 7 days a week, in multiple languages by various means – phone, online or text message (in the US).

The Helpline is operated in a manner consistent with the laws of the countries where we operate. To ensure that a focused and timely investigation can be undertaken, to facilitate communication and to ensure your protection as a reporter, you are encouraged to provide your name, contact information and as much detail as you feel comfortable providing. A report may be made anonymously should you prefer.

Due to local privacy laws in certain countries and the European Union, the Integrity Helpline may permit only specific types of report, such as accounting, financial, auditing and bribery matters. In those countries, contact your HR Representative, Legal Department or Global Ethics & Compliance to report other issues.

Supervisors: Responding to Someone Who Speaks Up

Supervisors have a special responsibility to listen and act. Handling concerns appropriately is critical to preserving trust and protecting Albemarle.
If someone raises a concern, you should do the following:
  • Thank the person for having the courage to speak up.
  • Remove distractions and listen carefully.
  • Take notes, free of subjective opinion.
  • Respond respectfully and take every concern seriously, even if you disagree.
  • Assure the employee that you – or someone else – will follow up with them in relation to the matter.
  • Contact HR, Global Ethics & Compliance or the Legal Department – do not attempt to conduct the investigation yourself.
Contact HR, Global Ethics & Compliance or the Legal Department – you should never attempt to conduct the investigation yourself

Investigating a Concern

Investigations are taken very seriously at Albemarle. All investigations are conducted in accordance with our Investigation Policy, our Investigations Procedure and reviewed periodically with the Audit & Finance Committee. Any violation of the Code, company policies or applicable laws may result in disciplinary action up to and including termination of employment, in accordance with our Global Discipline Policy and Global Discipline Procedure.

Nothing in this Code, the Investigation Policy, Investigation Procedure or supporting processes prevents you from communicating with government agencies about possible violations of law or seeking legal advice as to your rights.

Non-Retaliation Policy

We will not tolerate any direct or indirect acts of retaliation against an individual who in good faith reports a concern or suspected violation of this Code or applicable laws. This includes retaliation against anyone for participating in an investigation of suspected misconduct, whether conducted by Albemarle or any government agency. We will investigate all allegations of retaliation. Individuals who have engaged in retaliation will be disciplined, up to and including termination of employment.

DEFINED TERMS

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.
Retaliation

Any adverse action threatened or taken against a person because the individual has filed, supported, or provided information in connection with a complaint. An adverse action is one that would discourage a reasonable person from reporting an allegation or participating in an investigation.

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