CODE OF CONDUCT
Introduction
We at FP-Pigments must act according to our company values and the code principles and comply with
company policies, laws, and regulations. FP-Pigments is committed to carrying out its business in a
sustainable way. The company strives to maintain the highest legal and ethical standards in all its
business practices to promote the long-term interests of FP-Pigments and its stakeholders. This
code applies to every employee, manager, and our Board of Directors; it governs every decision we
make as part of our daily work.
Safety and Good Working Conditions
Safety and Well-Being
We are committed to providing safe and healthy working conditions for our employees and contractors
in all locations. We put safety first in all our actions. All of us must contribute to the safety
and well-being of the workplace by encouraging a behavior-based safety culture, being alert and
aware of the policies, standards, and procedures, and reporting any incidents and unsafe
conditions. Each employee is responsible for complying with the safety instructions, using personal
protection equipment when required, and reporting on any shortcomings regarding safety instructions
or protection measures.
Fair Employment Practices
FP-Pigments promotes freedom from discrimination based on race, ethnic or national origin, color,
gender, family status, sexual orientation, creed, disability, age or political beliefs, or other
characteristics protected by law. FP-Pigments fosters equal opportunity, and employees are selected
and treated based on their abilities and merits.
FP-Pigments does not accept any form of discrimination, harassment, or bullying from its employees.
Respect and Harassment-Free Environment
We all at FP-Pigments must maintain a work environment where people are treated with dignity,
decency, and respect. That environment is characterized by mutual trust and the absence of
harassment, intimidation, oppression, and exploitation. FP-Pigments does not permit any form of
forced or compulsory labor or the use of child labor.
Freedom of Association
We respect freedom of association and collective bargaining.
FP-Pigments employees have the right to choose whether to be represented by a trade union for
collective bargaining.
Business Practices
Our Commitment to Customers, Suppliers, and Markets
We adhere to all applicable laws wherever we conduct business and treat everyone in the marketplace
with fairness and integrity. This encompasses our customers, agents, distributors, competitors,
suppliers, and contractors.
Product Safety and Quality
We aim to ensure that our products are made and developed to the highest ethical and safety
standards and delivered to our customers according to our promises. We follow the applicable laws
and regulations on chemical product safety.
Fair Competition
We compete vigorously, yet fairly, ethically, and within the framework of applicable competition
laws. Each FP-Pigments employee must adhere to competition laws, regulations, and FP-Pigments
policies. We respect others' valid intellectual property and confidential information.
Trade Compliance
We operate our business in an international trade environment requiring importing and exporting of
products, other goods, services, and information, from one country to another. We comply with
applicable laws and regulations that affect our operations. Regulations include but are not limited
to, embargoes and sanctions, customs import and export regulations, export controls, customs
valuation, country of origin, and preferential trade.
Anti-Bribery and Corruption
All employees are required to adhere to the FP-Pigments' Anti-Bribery and Corruption Policy and
must not engage in any form of bribery or corruption. This includes, but is not limited to,
offering, giving, receiving, or soliciting anything of value to influence the actions of an
individual in a position of trust. Failure to comply with the ABC Policy will result in
disciplinary action, up to and including termination of employment.
Business Partners
We deal only with business partners who conduct business ethically and responsibly. We seek
productive, ethical, and transparent relationships with our suppliers, agents, distributors,
customers, and contractors. We expect our partners to follow all applicable laws and regulations,
and share the principles expressed in our code.
Anti-Money Laundering
We do not accept, facilitate, or support money laundering. We comply with all laws prohibiting
money laundering or financing for illegal or illegitimate purposes.
Being a Good Corporate Citizen
We stand with our employees ready to respond ethically and with integrity to the needs of our
surrounding communities and society.
Human Rights
FP-Pigments supports and respects the protection of human rights as defined in the United Nation's
Universal Declaration on Human Rights. No employee is allowed to take any action that violates
these human rights principles, either directly or indirectly, and we expect our suppliers and
business partners to share these principles.
Dealing with Governments
We follow high ethical standards and interact transparently with governments and public officials.
We are honest and accurate and follow FP-Pigments policies and procedures and any applicable laws
in our dealings with governments and public officials.
Environmental Responsibility
We seek to lower the environmental footprint in our value chain. We identify and look for
opportunities to reduce any adverse environmental impacts of our manufacturing or products during
production and their lifecycle.
Political Activity
We observe neutrality about political parties and candidates for public office. We do not
participate in political activities nor make corporate donations to political parties or
candidates. Neither the names nor the assets of FP-Pigments shall be used to promote the interests
of political parties or candidates.
Creating Sustainable Growth
Our Commitments to the Investors
Acting responsibly and transparency goes hand-in-hand with protecting shareholder value. Each
employee creates value for our shareholders and other investors by putting our company's interests
first, maintaining accurate business records, and protecting and properly using company resources,
information, and property.
Company Assets and Information Security
At FP-Pigments, we use resources honestly, efficiently, and solely for legitimate business
purposes.
We must protect our resources from theft, loss, damage, or misuse. Resources include physical
property, such as facilities, supplies, equipment, machinery, raw materials, finished products,
vehicles, and company funds. They also include intangible assets, such as company time,
confidential distribute FP-Pigments proprietary or confidential information according to our policies and
actively protect our intellectual property. Any non-public information that suppliers, customers, or other
business partners entrust to FP-Pigments must be managed in accordance with applicable legal and
contractual requirements.
Conflict of Interests
FP-Pigments expects complete loyalty from its employees. Employees must avoid situations where
their interests may conflict with those of FP-Pigments. We must always disclose any potential or
actual conflict of interest to the relevant management.
Accuracy of Accounting Records
FP-Pigments accounting records must be accurate and reliable in all material respects. Unrecorded
funds are prohibited. The documents cannot contain any false, misleading, or artificial entries.
Reporting Violations
Channel to Report Concerns
Every employee must raise any concern or activity that could violate this code, company policy or
law to his/her superior or manager or use the FP-Pigments Whistler Blower Channel. Each manager
must forward all reports to the head of the local legal entity without any delay. A person who
reports misconduct in good faith will not be retaliated against for making such a report.
Regardless of position, any person who engages in retaliatory behavior will be subject to
disciplinary action.
Investigating Code Violations
All allegations of potential violations of this code made in good faith will receive a fair and
comprehensive investigation conducted with relevant internal and/or external assistance. Any
reporting of potential code violations will be treated confidentially and anonymously to the extent
possible. Violations of our code, including failing to promptly report a known code violation or
making a false report of a violation, may result in disciplinary action, up to and including
termination of employment.