Stahl Statement onModern Slavery
The Stahl Group (“Stahl’) conducts its business with thehighest standards of integrity and ethical behavior. Thisstatement sets out the steps taken by us to mitigate therisk of slavery and human trafficking (“Modern Slavery”)
in our supply chain. This statement is made in relation tosection 54 of the UK Modern Slavery Act 2015.
1. Stahl’s Business and Supply Chain overview
Stahl Lux 2 SA is the parent company of the StahlGroup with its Headquarters in the Netherlands. Asof 1 January 2018, we employ over 2,000 employees
at 13 Manufacturing Sites and 41 technical service
laboratory facilities and sales support offices in 24countries. Global presence, knowledge and commercial
excellence makes us a leading player in the field ofprocess chemicals for leather and other substrates
for the automotive (and other transportation), industrial
application, interior design, leisure & lifestyle andapparel & accessories industry amongst others. Stahl’sBusiness is divided in the following areas: Wet-End
Chemicals & Dyes, Leather Finish, Automotive Leather
Chemicals and Performance Coatings & Polymers.
In 2017 the Stahl Group reported net sales ofEUR 733 mln.

The Stahl Group has manufacturing sites in Brazil, China,France, Germany, India, Italy, Mexico, The Netherlands,Singapore, Spain and the USA. The procurement teamis led by the group director of Procurement. Localpurchasing managers report to the global team. The
global procurement team sets and monitors thepurchasing strategy, selects suppliers and negotiates
the prices for the Stahl Group globally. Local sites may
take responsibility for procurement in case of certain
small volumes, which is monitored by the global team.
Stahl has sales support offices/representatives offices,
application labs and warehouses around the world to
support the sale of its products and services
2. Stahl’s Policy on Modern Slavery
Modern slavery, or any form of forced or compulsory
labour, is a violation of human rights. We take a strong
stance against modern slavery. We condemn any formof modern slavery and child labour, and shall notparticipate in the trafficking, recruitment, or receipt ofany persons, by means of threat or abuse of power. We
allow employees to resign from their position at any time.
By behaving ethically and honestly with all its partners,
we are committed to ensuring that modern slavery does
not occur elsewhere and strives only to do business withorganizations who uphold similar principles.

We commit to the UN Global Compact’s Ten Principles
and strive to conduct its business with the highest
standards of integrity and ethical behavior. This means
operating in ways that, at a minimum, meet fundamental
responsibilities in the areas of human rights, labor,
environment and anti-corruption.

To ensure a high level of understanding of the risks
of modern slavery and human trafficking and to give
guidance on behavior, we train all relevant Stahlemployees via e-learning courses on modern slavery,anti-bribery and corruption. 1,100 employees have been
trained to date, which is 97% of the targeted employees.

We implemented a Code of Conduct and Whistleblower
rules reflecting these high standards of integrity andethical behavior, plus we appointed a Compliance
Officer. The Code of Conduct and Whistleblower rules
apply to all to its employees. These Code of Conductand Whistleblower Rules are distributed through thelocal HR departments. Every new employee needs tosign this Code of Conduct and Whistleblower rules.

In 2018 we will start a pilot project to introduce a
supplier audit protocol based on the risks associatedwith modern slavery, bribery and corruption.

We pay close attention to the companies with whom wecooperate, such as agents, distributors and suppliers.
We require these business partners to sign the Business
Partner Code of Conduct or, if the business partner has
its own similar Code of Conduct, to provide a copy ofsuch Code of Conduct. In the unfortunate case that thebusiness partner does not comply with the Code ofConduct, we can, if necessary, immediately discontinue
the business relationship with such business partner.

This statement has been approved by our Boardof Directors.

In the fourth quarter of 2017, we amended the Stahl
Code of Conduct for our employees and business
partners adding more specific wording on ModernSlavery.
3. Due diligence Processes for Modern Slavery
The Stahl Code of Conduct is regularly discussed during
meetings with the respective business partners. Suchdiscussions are confirmed in reports and/or e-mails.
the Code of Conduct is also discussed during theQuarterly Executive Control Group meetings. Everyyear, the respective business directors and local
regional managers need to complete a Code of Conduct
compliance questionnaire about the Code of Conduct
with respect to employees and business partners. We
refer to the Stahl Compliance Report as published on
the Stahl website www.stahl.com.

We will continuously work to further develop andstrengthen our efforts to promote the UN Global
Compact’s Ten Principles, including the eliminationof all forms of forced and compulsory labor.

Huub van BeijerenChief Executive Officer