CRODASupplier Code of Conduct
Croda International PLC

Revision: December 2022

CRODA
Dear Valued Supplier to Croda:
These past two years have been particularly challenging for all of us, with Covid-19 healthconcerns, supply disruptions, supply chain challenges, and overall difficulties in securing thematerials needed to meet the needs of our customers. I would like to use this opportunity tosay THANK YOU for your hard work and dedication in meeting the needs of Croda.
During these difficult times, Croda has been able to maintain its high focus on sustainablesupply chains. We have set ambitious targets towards our aim to be Climate, Land, andPeople positive, and we want to continue this journey with our supplier partners who sharethese similar values.
During the upcoming year, we will be conducting engagement sessions with suppliers tocontinue our focus on sustainable sourcing for which we have made the following publiccommitments:•Supplier Assessments – By the end of 2024, all key suppliers will be required toachieve a minimum of the average score from EcoVadis (or equivalent) or will havean action plan with timelines to close gaps.

•Supplier Carbon Reduction Targets – By the end of 2024, key suppliers representing
at least 50% of our raw material volumes will be required to sign up publicly to SBTior equivalent carbon reduction targets.

•Transparent and Certified Sustainable Supply Chains – By the end of 2024, suppliersof crop-based raw materials will be required to provide supply chain transparency ina fully traceable and certified sustainable manner.

•Sustainable Innovation – By 2030, over 75% of our organic raw materials by weight
will be bio-based, absorbing carbon from the atmosphere as they grow.

•Croda Science Based Targets (SBTs) for Climate – By 2030, we will have achieved
our SBTs, reducing scope 1 and 2 emissions by 46.2% from a 2018 baseline, in linewith limiting global warming to 1.5°C, and reducing upstream scope 3 emissions.
Thereafter, by 2050 we will be a net zero organisation.

Measurement of Scope 3 carbon is a challenge for all organisations. Croda is a member ofTogether for Sustainability (TfS), and TfS has worked with the WBCSB and the GHG Protocolto develop Scope 3 metrics specific to the chemicals industry. You will receive more
information regarding this new Product Carbon Footprint (PCF) methodology from Croda, ourTfS partners, and the WBCSD in the upcoming year.
Thank you again for your continued support of Croda and our sustainable sourcing ambitions.
Kind regards,

Michelle Fargen
Global Head of Procurement and Sustainable Sourcing

CRODA Supplier Code of Conduct, Revision Date: December 2022

Supplier Code of Conduct
As an international business with suppliers and representatives throughout the world, Croda
International Plc and its subsidiaries accept that we have an important role to play in trading
responsibly with honesty and integrity at all times.
We therefore must ensure that those organisations with whom we interact, including oursuppliers and their representatives, live up to our values and standards and share thisresponsibility. Our use of the term “suppliers” not only refers to our suppliers of raw materials,goods, and services, but also contractors, consultants, agents, distributors, and all other thirdparties within Croda supply chains.
In addition to this Supplier Code of Conduct, any third parties performing services for or on
behalf of Croda are also required to comply with our corporate Code of Conduct.
This revision of our Supplier Code of Conduct provides further guidance regarding Croda
supplier requirements and expectations and also highlights how suppliers can achievepreferred status and access to increased business with Croda. Our Supplier Code of Conduct
as well as our corporate Code of Conduct can be found on our website using this link: Policies
and procedures | Croda.

Sustainability
Our Commitment is to be the most sustainable supplier of innovative ingredients. We will
create, make, and sell solutions to tackle some of the biggest challenges the world is facing.
By 2030 we will be Climate, Land and People Positive. Our delivery of positive impacts andmeasurable contribution to the UN SDGs will be further amplified through our work within oursupply chains. Therefore, we expect our suppliers to be fully aligned and partner with us toachieve our stated objectives.
Climate Positive
We will continue to reduce our carbon footprint and increase our use of bio-based raw
materials, whilst the benefits in use of our ingredients will enable more carbon to be saved
than we emit through our operations and supply chain.
Reducing Emissions
We will achieve our science-based targets (SBTs) by reducing our emissions in line withlimiting the global temperature rise to 1.5°C above pre-industrial levels, maximising the use ofrenewable energy in our operations.
Because a majority of our carbon emissions are from Scope 3 upstream purchased goods andservices, it is critical that we partner with suppliers who have signed up to SBTi or have similar
publicly announced carbon reduction targets. Suppliers will be required to provide us with theScope 3 carbon associated with the products and services sold to Croda. This joined up
approach will enable suppliers, Croda, and Croda customers to work closely together toachieve our carbon reduction ambitions.
Sustainable Innovation
We will accelerate the transition to bio-based products, moving away from fossil/petrochemical
feedstocks. We are actively seeking bio-based alternatives to our petrochemical based raw

CRODA Supplier Code of Conduct, Revision Date: December 2022

materials, and we want to partner with suppliers in their efforts in exploring these newinnovations.
Land Positive
Our products will enable more land to be saved than is used to grow our bio-based raw
materials. Our innovation will help customers to protect biodiversity and to mitigate the impactof climate change and land degradation, increasing the availability of land suitable for growing
crops.
We want to partner with suppliers who can help us better understand the overall biodiversity
impacts of the crop based raw materials sold to Croda, as well as the work they are doing tomitigate negative impacts and improve nature conditions.
Crop Science Innovation
We will invest in innovation projects and partnerships to support crop and seed enhancementin mitigating the impact of a changing climate and land degradation. We are happy to explore
these opportunities with suppliers to Croda.
People Positive
We will apply our innovation to increase our positive impact on society. We are improving thelives of our own employees and people around the world by developing ingredients to improvehealth and wellbeing as well as encouraging and promoting diversity.
Fundamentals
Our social licence to operate is built on trust and is the foundation of everything we do. We
consider all stakeholders in our ecosystem and strive to adopt best practices in environment,labour and human rights, ethics, and sustainable procurement.
Sustainable Sourcing and Supplier Partnerships
We will ensure that all our key suppliers are operating safely, ethically, and responsibly, andwill promote the equitable sharing of benefits within the supply chain. All temporary andpermanent Croda employees are paid a living wage, and we also expect this also from ourpreferred suppliers.
We have implemented a sustainable sourcing scorecard to measure the performance of oursuppliers against our stated requirements. These scorecards will be a key consideration whenawarding future business to supply Croda. We would also like to work with suppliers to improve
performance and achieve our mutual sustainability goals.
Scorecard Key Criteria:
1. EcoVadis assessment
oMinimum score of 45o

Work to address Corrective Actions, if requiredoContinuous improvement

2. CDP assessment scores for climate, water, and forests
3. Carbon reduction targets approved by SBTi or equivalent
4. Provision of Product Carbon Footprint (PCF) data for products sold to Croda

CRODA Supplier Code of Conduct, Revision Date: December 2022

5. Transparent and certified sustainable supply chains (crop based RMs)o

Supply chain transparency data provided to Transitions (palm, soya)oThird party certification (i.e. RSPO for palm)

6. NDPE No Deforestation, No Peat, No Exploitation (palm)oPublic commitment to NDPEo

Established grievance policy and procedures

Key Principles
Croda requires that all suppliers respect the Key Principles of this Supplier Code of Conduct
and adopt practices within their operations and supply chains that are aligned with ourrequirements.
Legal Requirements
Croda requires our suppliers to abide by all applicable local, regional, and international laws,
regulations, and standards in the markets where they operate. Where local laws or standards
differ from this Supplier Code of Conduct, we expect suppliers to comply with the more
stringent standards and principles.
Conflict of Interest
Supplier must avoid conflicts of interest that may influence business relationships.
Human Rights
Suppliers must adopt policies that are consistent with the International Labour Organisation(ILO) Declaration on Fundamental Principles and Rights at Work, the UK Modern Slaverylaws, and similar local laws. Such policies include:•No Discrimination – There must be no discrimination in hiring, compensation, accessto training, promotion, termination, or retirement based on race, national origin,religion, age, disability, gender, marital status, sexual orientation, union membershipor political affiliation.

•Child Labour Shall Not be Used – There shall be no recruitment or use of child labour.

•Employment is Freely Chosen – There shall be no forced or compulsory labour in
any form, including bonded, trafficked or prison labour. Workers are free to leave workand terminate their employment upon reasonable notice without penalty andemployers must not retain any personal identification, travel documents or wages asconditions of employment.

•No Harsh or Inhumane Treatment is Allowed – Physical abuse or discipline, thethreat of physical abuse, sexual or other harassment and verbal abuse or other formsof intimidation are prohibited.

•Living Wages are Paid – Wages and benefits paid for a standard working week mustmeet national legal standards or industry benchmark standards. In any event wages
should be enough to meet basic needs and to provide some discretionary income. Allworkers shall be provided with written and understandable information about
employment conditions in respect to wages before they enter employment.

CRODA Supplier Code of Conduct, Revision Date: December 2022

•Working Hours are Not Excessive – Working hours must comply with national laws
and benchmark industry standards, whichever affords greater protection.

•Freedom of Association and the Right to Collective Bargaining – Workers havethe right to join or form trade unions of their own choosing and to bargain collectively.

Health and Safety
Suppliers must manage the working environment to ensure safe and hygienic working
conditions, while continuously striving to eliminate accidents and injury to health.
•Working Conditions – A safe and hygienic working environment shall be provided
with access to clean toilet facilities and potable water.

•Employee Training – Policies and Procedures regarding the prevention of ill healthand injury must be implemented through the training of all employees to a level relevantto their role. Worker training shall be regular and recorded.

•Performance Monitoring – Health and safety performance shall be continually
measured, and systems must be in place to manage and mitigate risk.

Environmental Management
An environmental management system (EMS) with the applicable statutory and international
standards regarding environmental protection must be in place to maximise resource
efficiency, whilst minimising risk and negative impact. Suppliers and representatives willcontinually strive towards improving the efficiency and sustainability of their operations. SuchEMS must manage, but is not limited to:•Emissions•Water use and discharge•

Waste•

Energy usage•

Raw materials sourcing

Bribery and Corruption
Suppliers shall adhere to the highest standards of ethical requirements to prohibit bribery andcorruption. The offering, paying, soliciting or acceptance of bribes including facilitation
payments is strictly prohibited. At a minimum, suppliers and their representatives must complywith the standards outlined in the UK Bribery Act of 2010 and the U.S. Foreign Corrupt
Practices Act of 1977 (FCPA), as applicable.
•Bribes – A bribe may involve giving or offering any form of gift, consideration, reward,
hospitality, kickbacks, favours, gratuities, or any other advantage to someone inbusiness or government to obtain or retain a commercial advantage.

•Facilitation Payments – Facilitation payments are payments or fees requested bygovernment officials to speed up or facilitate the performance of routine government
action (such as the provision of a visa or customs clearance).

•Corruption – There will be no engagement in commercial espionage, covert
surveillance of competitors, or other activities that would lead to an unfair competitive
advantage or breach of anti-trust legislation.

CRODA Supplier Code of Conduct, Revision Date: December 2022

Tax Evasion
Suppliers, who perform services for or on behalf of Croda must comply with the standard
outlined in the UK Criminal Finances Act 2017 including implementing reasonable proceduresfor the prevention of the facilitation of tax evasion.
Conflict Minerals
Suppliers shall take reasonable efforts to avoid in its products the use of raw materials which
directly or indirectly finance armed groups or organisations that violate human rights.
Animal Welfare
Animal testing, also known as animal experimentation, animal research and in vivo testing, isthe use of non-human animals in experiments that seek to control the variables that affect thebehaviour or biological system under study.
Suppliers should not undertake or commission the use of vertebrate animals in determining
safety or toxicological data for Croda supplied raw materials except where there is a regulatory
requirement, and no alternative methods exist.
Suppliers are required to answer and provide data on any animal testing performed. The
minimum data required is:•Species•

Date of test•

Test method•

Concentration of test substance•Reason for testing

If the supplier has a reference number for the testing this should be recorded alongside theminimum data above.
Confidentiality
The confidentiality of information exchanged during business must be respected and shall not
be used for questionable purposes or for individual gain. False information must not beprovided during commercial negotiations.
Quality
Suppliers must ensure that any goods supplied shall be without fault and of the best available
design, quality, material, and workmanship.
Any services supplied shall be provided by appropriately qualified and trained personnel withdue care and diligence.
Reporting Violations
Suppliers shall report any violations or suspected violations of applicable laws, regulations,and this Supplier Code of Conduct to Croda. Suppliers may report a violation confidentiallyusing the Croda Speak Up Hotline.

CRODA Supplier Code of Conduct, Revision Date: December 2022

Audit and Termination of Agreements
Croda will seek assurance that its suppliers adhere to the principles of this Supplier Code ofConduct and that they take responsibility to ensure compliance within their own supply chains.
•Assessments & Audits – Croda reserves the rights to verify supplier andrepresentative compliance with this Supplier Code of Conduct. This will include
requiring suppliers to report information to EcoVadis, our sustainability reporting
partner.

•Remediation – Where assessments or audits demonstrate shortcomings in any areas,
the supplier and representatives must communicate and implement a time-boundprogramme of improvement leading to conformance.

•Termination – In the event that a supplier or representative fails to meet therequirements of this Supplier Code of Conduct and there are no actions made toward
remediation, Croda reserves the right to terminate the supplier agreement and takeother actions as outlined by law or contractual language.

Additional Resources
Additional resources for topics critical to doing business with Croda can be found at thefollowing links (click the link to access the web page):
Croda Sustainability Reports
Policies and Procedures | Croda
Croda Modern Slavery Statements
Croda Statement on Grievances in the Palm Sector

Supplier Acknowledgement
Croda would like to ensure that our suppliers receive, review, and understand our Supplier
Code of Conduct requirements. We aspire to partner only with suppliers who share our ethics,values, and commitments to being Climate, Land, and People positive.
As a recipient of this information, we would like to ask that you share this Supplier Code ofConduct with the appropriate individuals within your leadership, sales, procurement, andoperational teams.
We will retain all records of electronic transmissions from Croda to supplier companies.
Save as amended by this notification and acknowledgement, the terms of any Frame
Agreement between your organisation and Croda shall remain in full force and effect. This
notice shall be governed by and construed in accordance with English Law or other local
country law, as applicable.
This Supplier Code of Conduct may be updated from time to time. The most current versionof the Code can be found on the Croda website at www.croda.com.

CRODA Supplier Code of Conduct, Revision Date: December 2022