Code of Conduct and Ethics

CODE OF Conduct and Ethics

Management Letter

Code of Conduct and Ethics

Code of Conduct and Ethics objectives

Our values and ethical principles

Conduct and Performance

1. Application of the Code of Conduct and Ethics

2. Conduct and Performance

Governing body of the Code Our code is your code

Management Letter

ELIX Polymers is pleased to share with all our stakeholders our Code of Conduct and Ethics.

ELIX Polymers, a member of Sinochem International, is a leading manufacturer of Acrylonitrile-Butadiene-Styrene (ABS) resins and derivatives in Europe.

Operating from its head office in Tarragona, Spain, and with Sales support teams in all key markets, the company is a specialist provider of tailor-made solutions for high quality thermoplastics applications. With a 45-year track record, ELIX Polymers is an expert in ABS polymers, and it has the resources, the expertise and the experience to create value for its customers through tailor-made solutions, increasingly focusing on the sustainable management of resources.

Our values have accompanied us since the beginning, and have allowed us to gain the trust of our stakeholders, people, customers, the Company and society.

These values have been and are inherent to our daily work and relationships, and we want to share them in the form of this Code of Conduct and Ethics.

Large companies have a soul and a purpose, and that is why this Code not only addresses all matters related to our professional activity

and relationships with our stakeholders, but also reflects our way of being and doing, showing our identity and what drives us every day, with a clear commitment to comply with the national laws and regulations that apply to our equipment and services around the world.

We are convinced that the entire ELIX team is committed to complying with this Code, demonstrating a great capacity to fulfil our business activities in an ethical, transparent and responsible manner.

We invite you to read it and be part of it, since it defines the basic principles of our conduct and performance, as well as our corporate values; and it establishes the legal framework of how the company operates, an essential mechanism for ELIX’s sustainable success.

Code of Conduct and Ethics

ELIX’s Code of Conduct and Ethics is the instrument where we set out the values, principles and conduct that should guide the development of our professional activity and our relations with our stakeholders.

Our ethical principles should not only encompass the provisions of the legal regulatory framework, but define who we are and should be present in everything we do.

Ethics in our day-to-day business helps us gain the trust of our people, our customers, our suppliers and the society around us through ethical conduct and performance, and is therefore one of the keys to our success.

Code objectives

Furthermore, as leaders in our sector, we have the responsibility to be a benchmark and contribute to the maximum to development, progress and social welfare.

The internationalisation process that we have undertaken in recent years has involved encountering different scenarios, cultures, laws and regulations to which we have had to adapt. And although each country is different, our conducts and actions must remain and cross borders, to be valid in all of them.

This Code of Conduct and Ethics is applicable to all ELIX employees and collaborators and applies to all our activities and relationships. It is a public document, continuously revised and updated as required.

The objectives are:

• To make known the principles and values that build our identity.

• To make known the conduct and performance governing ELIX and guiding its activity.

• To reflect and express the commitment of all the people who are part of ELIX to comply with this Code.

• To strengthen confidence in our company, internally and externally.

• To ensure that our activities are carried out ethically.

• To serve as a guide to address any possible ethical challenges in the future.

• To spread our responsible conduct and performance to all our stakeholders, thus contributing to the development of society and the common welfare.

Our values and ethical principles

The following values and principles accompany us in our day-to-day work and are part of how we do things and from where we do them.

Values

Innovation

We are committed to continuous improvement, efficiency and excellence in all our actions. Therefore, our goal is always to meet the new needs, being open to new proposals and new points of view. We get involved in projects beyond our work and encourage our collaborators to propose improvements in the current processes, seeking and implementing new tools at all times. We adapt to changes and new challenges, not looking back.

Collaboration

We do not understand any other way of working than working in and for the team, with empathy and always sharing the necessary information and offering our help in an interested way, looking for agreements towards a common goal.

Integrity

For us, integrity means acting always and in all situations consistently with the Missions and with the rest of the values and principles. Being objective and impartial, rejecting any form of corruption, whether active or passive, and always explaining our actions.

Ethical principles

Diversity and Equal Opportunity

As an evidence of our commitment to gender equality and diversity in all its forms, we work to promote the inclusion of women and other disadvantaged groups in our industry. We treat all people equally, and reject any type of discrimination.

Sustainability

Sustainability at ELIX is a strategic principle, which affects our entire value chain, from the extraction of raw materials to the end consumer, with special attention to causing the least possible impact on the environment and our local surroundings, contributing to their protection and preservation. In addition to being a strategic principle, it is an opportunity for global improvement, open innovation and collaboration with our stakeholders.

Excellence

We are committed to continuous improvement and seek efficiency and excellence in all our actions. We get involved in projects beyond our work and we adapt to changes and new challenges without looking back, because we do not just want to accomplish good results, but we also want to achieve the best results.

Transparency

For ELIX, transparency is a principle of good governance, which is present in all our operations and communications, both those resulting from our work and those with our stakeholders. To guarantee this transparency, our information is available and accessible and we transmit it in our internal and external processes, whether through our communication channels, our accounts or annual reports, or through the different audits and/or certifications.

Commitment and Responsibility

Because of the impact that our activities may cause, both inside and outside the company, we demand maximum responsibility from ourselves, and we encourage the commitment of all our teams to our work and to the result, always respecting this Code and rejecting proposals that are contrary to it.

Conduct and Performance

All ELIX employees must adhere to our Code of Conduct and Ethics in order to protect both the company and themselves.

Compliance with the conduct and performance described below is essential to ensure the sustained success of our organisation and serves as a guide and aid both for our employees and for our external collaborators, external partners, or public or private entities with which we may have a commercial or business relationship.

1. Application of the Code of Conduct and Ethics

The conducts and actions described below apply to:

• All ELIX Polymers personnel: Directors, managers, officers and employees, whether permanent or temporary personnel.

• Business partners

• External and/or subcontracted personnel (subsidiaries and/or affiliates over which it may exercise control).

All ELIX Polymers personnel are required to comply with this Code of Conduct and Ethics. Failure to comply may result in the application of disciplinary actions, even dismissal, as well as criminal or civil penalties, both to ELIX Polymers and its employees, which may include fines or imprisonment, in those breaches of conduct and actions arising from anti-bribery, corruption, unfair competition and other laws.

The ELIX Management Team undertakes to fully support this Code of Conduct and Ethics, and is ultimately responsible for establishing and implementing it, as well as for monitoring and ensuring compliance with the conducts and actions contained herein.

2. Conduct and Performance

The following is a list of conducts and actions to which we should pay special attention:

Conflict of interest

As ELIX members, we must always act in the best interests of the company and avoid putting ourselves in a position where our personal interests conflict with those of the organisation. Our performance must always

be honest, upright, in good faith and ethically responsible. Our personal interests may include those of our family or other people with whom we have similar relationships.

Conflicts of interest compromise our personal integrity. They can arise in many different ways, but the following are some clear conflicts to avoid:

• Obtaining personal benefits (other than salary or remuneration and authorised profits) at the expense of the company.

• Engaging in or assisting in activities that compete with or are detrimental to ELIX Polymers’ business.

• Working for any ELIX Polymers customer or supplier.

• Having any interest in the ownership of a customer, supplier, distributor or competitor of ELIX Polymers (Note: Ownership of publicly traded securities at a level consistent with the incomes of an individual and other investments is acceptable if it does not provide influence or is not likely to be significantly influenced by business granted to or retained by ELIX Polymers).

• Using our position at ELIX Polymers to influence the salary or employment prospects of any member of our family or equivalent person employed by ELIX Polymers or by any customer or supplier of ELIX Polymers.

If at any time you are in a position that involves - or may appear to involve - a conflict of interest, you must inform your supervisor or area manager.

Bribery

A bribe generally involves paying, promising payment or offering money or something of value to someone in businesses or in the public sector in order to obtain or maintain an undue advantage. Likewise, it may also extend to the granting of favours of great value to the recipient, as well as luxurious or inappropriate gifts, hospitalities or presents that may influence a business decision that

obtains an undue advantage for our company. Bribery may also occur when the offer or payment is made by or through a third party.

Corruption, bribery or any other form of taking advantage of or favouring persons by means of a benefit in connection with the award, acceptance or execution of a contract is strictly prohibited.

Undue payments, kickbacks and other forms of bribery

ELIX Polymers has a zero tolerance policy towards bribery and corruption, which it extends to any country in which it intervenes and operates and in all business and transactions.

Therefore, any member or representative of ELIX Polymers, whether acting on his own behalf or on behalf of the company, is strictly prohibited the following:

• Offering, promising, giving or authorising, directly or indirectly, any bribe or kickback or for the benefit of any person (whether in a private or public capacity) for the purpose of obtaining any undue business or other advantage for ELIX Polymers, for himself or for his family, friends, associates or acquaintances.

• Offering, promising, giving or authorising, directly or indirectly, any bribe, kickback or for the benefit of any public official (or to any other person at the request of, or with the acquiescence of, a public official) with the aim of influencing such official in the performance of his or her public duties, whether or not such performance is to obtain any business or other advantage for ELIX Polymers, for themselves or for their relatives, friends, associates or acquaintances;

• Requesting, accepting or receiving (whether for the benefit of [the company], for their own benefit or for the benefit of their relatives, friends, associates or acquaintances) any bribe from any person (whether in a private or public capacity) in exchange for providing any improper business or other advantage;

• Otherwise using illegal or improper means (including bribes, favours, blackmail, financial payments, incentives, secret commissions or other rewards) to influence the actions of others;

• Acting as an intermediary for a third party in the request, acceptance of payment or offer of a bribe or commission.

In addition to complying with the specific prohibitions in this policy, any ELIX member must use common sense and judgement in evaluating whether any agreement could be perceived as corrupt or improper.

Facilitation payments

Facilitation payments are those payments intended to expedite or facilitate the performance of routine administrative or government actions carried out by an official. Such payments are usually demanded by low-level and/or low-income officials to obtain services that, under normal conditions, should be provided in any case. Facilitation payments are a form of bribery

and are prohibited in most countries. ELIX Polymers’ policy is strict with regard to such payments, which are prohibited, even if they are common in a given country. Upon any request to make a facilitation payment, the Ethic Compliance, or the CEO, or the Director of People, Culture and Communication in the absence of the CEO, must be informed immediately of such request.

Political and charitable contributions and sponsorships

ELIX Polymers does not make political contributions to any individual, political party or organisation in any country, as this may be considered an attempt to gain an improper business advantage. This refusal helps us operate independently and free of political ties.

This does not mean that our employees cannot exercise their personal right to participate in political and democratic processes.

In some circumstances, charitable donations can also be used as a cover for bribery, for example, when a donation is made to a “charity” that is controlled by a foreign public official who is in a position to make decisions affecting ELIX Polymers. These should not be

confused with support and donations to the community and local organisations, which may be carried out either through in-kind services, knowledge, exchange of services, or direct financial contributions. In any of these cases, special care must be taken to ensure through due diligence and transparency that charitable contributions and sponsorships do not constitute a bribe and are not aimed at obtaining an improper commercial advantage.

Gifts and hospitalities

ELIX Polymers does not allow any kind of corrupt behaviour among its employees.

Therefore, our employees must not accept or give gifts or hospitalities if they could influence a person’s business decision or gain an undue advantage for ELIX.

Modest gifts or entertainment may be considered a bribe or inducement under applicable law, but in certain situations during the normal course of business, our employees may sometimes offer or give small gifts or modest entertainment to others as deemed reasonable and common and in accordance with our internal

guidelines. Likewise, our employees may accept hospitalities or gifts when they are reasonable and not excessive, and at all times appropriate to the relationship in question. Any gift or hospitality (given or received) with a value of more than 150 euros must be notified to the People, Culture and Communication Department, which will proceed to enter it in a register set up for this purpose. Such register must expressly state the nature and purpose of the expenditure, as well as the donor/recipient of the business hospitality. These registers must be retained and regularly reviewed by the Ethic Compliance.

In relation to gifts and hospitalities, there are two prohibitions that leave no room for interpretation:

• Monetary gifts may never be offered, given, demanded or accepted.

• Gifts or other benefits must not be given under any circumstances to authorities or officials.

Hospitality and sponsored travel (business courtesies)

As with gifts and hospitalities, business courtesies should be reasonable and not excessive.

They may only be offered or accepted for the sole purpose of creating or maintaining a business relationship or offering a normal courtesy, and not for influencing the recipient’s objectivity when making a specific business decision. They should never be offered or received in exchange for something. If offered by ELIX Polymers, care

Competition law and foreign trade laws

At ELIX Polymers we fully comply with international legal procedures that support free enterprise and a competitive market. We watch at all times for compliance with competition laws to avoid interference in a fair and competitive market. We are all

must be taken to ensure that in no case do these business courtesies exceed the limits imposed by the recipient’s organisation.

They should be permitted by all applicable laws, rules and regulations in each of the countries in which they operate or where they occur.

Business courtesies that contravene these guidelines should be refused and the person in charge should be informed immediately.

individually responsible for knowing and complying with the specific laws that affect us, keeping in mind that the laws of some countries may apply outside their national borders. Penalties for non-compliance can be severe and may involve criminal offences.

ELIX Polymers does not allow actions that affect fair competition as described below, and expects the same from its business partners:

• Pricing agreements with competitors.

• Assignment of customers.

• Production capacity agreements.

• Allocation of geographic markets and/or market shares.

• Control of a customer’s resale price.

• Exchange of information with competitors about supply relationships, business strategies, or supply policies.

Financial and operational integrity

Integrity is one of ELIX Polymers’ core values. For this reason, and at all times, all people who are part of the organisation are required to comply with accounting rules and procedures in order to comply with current

legislation. This implies that all transactions must be duly authorised and properly and completely recorded. No record or document may be forged or misleading and no account, fund or asset undisclosed or unrecorded.

Procurement of goods and services

ELIX Polymers is strongly committed to conducting its business activities in a legal and ethical manner, including the contracting of suppliers or third parties who shall be committed to the same principles in order to ensure a long-term, sustainable and successful relationship for all parties. For that purpose, ELIX Polymers has developed the “Procurement Code of Conduct” document, which sets out the requirements and working methods that ELIX Polymers must apply together with the third parties in its upstream supply chain. ELIX Polymers requires all

suppliers to conduct their activities in accordance with the principles set out in this document.

All ELIX Polymers employees must act on the basis of this Policy in a fair and transparent manner.

Likewise, systematic non-compliance with this policy by the supplier, its subsidiaries, affiliates and subcontractors, with ELIX Polymers, may jeopardise the business relationship, even leading to its termination.

Governing bodies of the Code

The following is a description of the functions of the main subjects that make up the governing body of this Code:

· Designated ELIX person

It is the person appointed by the Management Team to ensure that the company and its employees comply with legal and regulatory requirements, as well as internal policies and by-laws.

The basic function of the Ethic Compliance is to promote ethical conduct and compliance with the rules, regulations and standard processes governing how these organisations should conduct their business.

Likewise, he/she is the person who receives, within the company, the possible cases that will be analysed together with the Ethics Committee. In addition to these basic functions, he/she shall also develop and maintain a culture of compliance with this Code, and shall ensure that there is up-to-date communication of measures and changes in relation to this Code.

· CEO

· PCC Management

· Ethic Compliance

This is the body that will thoroughly analyse the cases received by the Ethic Compliance. This body, if it considers it appropriate, and following the provisions of this code, will refer the decision to continue with further actions to the Management Team. The Ethics Committee may request external legal advice for the proper performance of its functions. The Ethics Committee is made up of the CEO, PCC Management, and the Ethic Compliance.

· CEO

· Senior team

It is the body that will issue a resolution to the case material received and analysed. It is represented by the CEO and members of the Senior team.

Ethic Compliance Ethics Committee Management Team Employees

· All ELIX Polymers personnel

· Business Partners

· External and/or subcontracted personnel

All persons involved in the operation of the business (ELIX personnel, business partners, external and/or subcontracted personnel)

Our Code is your code

Through its information and communication channels, as well as continuous training, ELIX Polymers will ensure that all persons who are part of its organisation receive, are aware of, and respect this code.

Furthermore, it is the responsibility of each director, manager or officer with person/s in charge to ensure that all their teams understand and comply with the provisions of this code.

Follow-up of procedures/registers

Our financial, accounting and/or procurement transactions must be complete, orderly and easily understandable. All registers and files must be maintained in a complete manner and in such a way as to permit delegation to a colleague at any time.

ELIX Polymers, as well as all its employees who may be involved in such transactions,

shall retain relevant items for as long as required by legal regulations or internal procedures, and under no circumstance shall documents classified as relevant to threatened or pending legal or official proceedings be destroyed.

Notification of suspicious situations/complaints

TAny ELIX employee who becomes aware of irregularities or reasonable grounds for suspicion in the course of his or her work must inform his or her superior, the Ethic Compliance or the Management of People, Culture and Communication.

ELIX Polymers provides its employees with a confidential and secure Direct Complaints Channel. All reports made in relation to conduct and actions covered by this code will be reviewed and investigated, even if made anonymously.

ELIX POLYMERS wishes to encourage open debate of the issues contained in this Code and therefore all its personnel should be assured that they will not be disadvantaged in any way by raising, in good faith, any questions or concerns about compliance with the Code.

Failure to comply with and/or infringements of this Code may result in disciplinary measures against those involved, including (where appropriate) dismissal, and may even result in criminal and civil exposure for both ELIX Polymers and its employees, including imprisonment and other severe penalties.

ELIX Polymers will not indemnify or reimburse fines imposed on individuals for infringements arising from this Code.

If you have any questions about the interpretation or application of this code, please contact the People, Culture and Communication Department or the Ethic Compliance.

Certification of the Code of Conduct and Ethics

All employees and collaborators of ELIX Polymers must read, commit to and sign this Code of Conduct and Ethics where all our values, our ethical principles, as well as the key behaviours and actions that support our business ethics and our relationship with suppliers and/or third parties are collected.

Our Code of Conduct and Ethics is public and is available to any person or entity that wishes to consult it on our web site.