Anti-Corruption Policy

July 2024
PublicAnti-Corruption Policy

1. Purpose
Our integrity dictates that we stand firm against bribery and support global efforts toeradicate corruption. Chemours is a global company, doing business in many countries. We
do what’s right for customers, colleagues, and communities − always. Bribery and corruption
are contrary to this principle. Corruption is an obstacle to the rule of law, depletes national
wealth and corrodes the social fabric of society. Our Employees, including officers, directors
and agents, must never engage in illegal, improper or unethical conduct. This Policy isintended to provide a clear statement of Chemours’ commitment to carrying out business
openly and honestly in order to avoid any action that may impugn the Company’s reputation
for integrity. Additionally, this Policy provides guidance and awareness about applicableanti-bribery laws such as the U.S. Foreign Corrupt Practices Act (“FCPA”), the U.K. Bribery
Act, and other legislation addressing bribery, kickbacks, conflicts of interest, or other corrupt
activities applicable in jurisdictions in which Chemours does business (collectively “AntiCorruption Laws”), so that we may avoid inadvertent violations and recognize and prevent
potential issues before they become real problems.
Employees must avoid any activity that creates even the appearance of impropriety and areencouraged to discuss any questions regarding specific facts or circumstances that may
implicate this Policy with their managers, Ethics Champion, or any member of Chemours
Legal or Ethics & Compliance. Additionally, Employees can contact the Ethics Hotline, whichis available 24-hours a day, confidential and, where allowed by law, can be anonymous.
2. Scope
This Policy is mandatory and applies to all directors, officers, and employees (collectively“Employee(s)”) of Chemours. It applies globally to Chemours and all its subsidiaries,
affiliates, partnerships, joint ventures and other business associations that are controlled byChemours, directly or indirectly (“the Company”). The principles and prohibitions under thisPolicy also apply globally to every partner, distributor, agent, contractor, representativeconsultant, reseller, freight forwarder, and/or other third parties acting or providing serviceson Chemours’ behalf (collectively “Third Parties”).
It is the responsibility of each Employee to act in accordance with the legal standards andrestrictions applicable to their assigned duties, including the FCPA and other applicable
Anti-Corruption Laws. A violation of an Anti-Corruption Law may subject an Employee to civil
as well as criminal penalties. Violations of this Policy may result in disciplinary action, up toand including termination, subject to applicable law.

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Anti-Corruption Policy

3. Policy Statementa. No Employee or Third Party of the Company shall give, offer, promise, authorize or pay
anything of value to any government official or any other person or entity including thosein the private or commercial sector to induce the recipient to misuse his or her position or
to obtain an improper business advantage.
b. No Employee shall request or accept a bribe.
c. No gift giving or receiving, including cash and cash equivalents, is permitted except asprovided in the Chemours Gift & Entertainment Policy.
d. No facilitation payments, as discussed in section 8 below, are permitted.
e. No Employee will suffer negative consequences for refusing to pay a bribe.
4. Definitions
For purposes of this Policy:
a. “Anything of value” includes, but is not limited to:
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cash and cash equivalents (as defined below)
gifts
travelmeals and/or entertainmentuse of vehicles or property
accommodations or valuable favors (such as educational and employment
opportunities for friends and relatives)loans

A “thing of value” under this Policy has no minimum value. Even a small gift is a “thing ofvalue.”b. “Bribe” is an offer, request, promise, authorization to pay, or payment or receipt of“anything of value” to or from or any person or entity, which is intended to induce therecipient to misuse his or her position or to obtain an improper “business advantage.”c. “Business advantage” is broadly defined. It includes obtaining or retaining business,
obtaining preferential treatment or securing political or business concessions, including
favorable tax or customs treatment, receiving permits or regulatory approvals, orbypassing laws or regulations.
d. “Cash equivalents” require compliance with the same procedures set forth for cash andinclude, for example:•••••

stocks, bonds, and other securities
precious metals or jewelry
gift cards or certificates that are exchangeable for goods or services
event tickets (e.g., sporting events, concerts, etc.)
anything that can be easily converted to cash

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Anti-Corruption Policy

e. “Government official” is broadly defined to include:
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any officer or employee of any government entity, department or agency
any employee of a state-owned enterprise
any political party or official thereof
any candidate for political officea public international organization, such as the United Nations or World Bank, or anydepartment or agency thereof
any person acting in an official capacity on behalf of a government entity

A “state-owned enterprise” is a business enterprise where the government or state hassignificant control through full, majority, or significant minority ownership.

5. Gifts & Entertainment
As a standard business practice, the Company does not encourage receiving or giving gifts.
Any gift or entertainment involving a non-U.S. government official must be pre-approved inwriting by Chemours Legal and relevant country management.
The Chemours Gifts & Entertainment Policy provides that all gifts and entertainment, bothgiving and receiving, must meet all of the following criteria:
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Is consistent with customary regional business practices;
Has a clear business purpose;
Cannot be perceived as a bribe or improper payment;
Is not offered to improperly influence a business relationship;
Does not violate applicable laws, ethical standards or Company policies;
Would not embarrass the Company or the Employee if publicly disclosed.

Employees must be familiar with the Gifts & Entertainment Policy. Stricter guidelines may
apply at local levels. Employees should check with their country management for any
additional guidelines.
Gifts to U.S. government officials are not permitted, except as provided in the U.S.
Government Business Gifts & Gratuities Policy.
6. Travel & Lodging of Non-U.S. Government Officials
For business reasons, it can be useful for non-U.S. government officials to visit Chemours
facilities to promote and demonstrate Chemours products. In these situations, it ispermissible for the Company to cover reasonable and limited meal, travel andaccommodation expenses for a government official’s visit provided such expenditures are:••••permitted by, and meet the requirements of, the laws/regulations of the specificcountries involved;
reasonable and bona fide expenditures that are directly related in time and place tothe promotion, demonstration, or explanation of Company products, services, orprocesses, or the execution or performance of a Company contract with a foreign
government or agency (i.e., directly to/from a Company facility, provision of nearby
lodging and/or meals with no additional or unrelated sightseeing or side trips);
appropriate, not extravagant, consistent with local customs (i.e., equivalent to whatthat government would authorize if it were to pay directly);
for the relevant officials only (i.e., no family or friends);

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Anti-Corruption Policy••
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for government officials appointed or chosen by their agency or office and not by
Chemours;
paid, when possible, to the service providers directly by Chemours and not to theindividual official;paid, when possible, to the foreign government and not the individual traveler wherereceipts are provided to Chemours by the government official for legitimate travelrelated expenses;
accompanied by clear communication to the government officials from Chemoursthat the provision of such expenditures is not intended to influence any officialactions;
reported to that government official’s agency as required; andin compliance with the Chemours Code of Conduct, Chemours authorization andrecordkeeping requirements, and the Non-U.S. Government Officials Travel ApprovalProcess.

Chemours Legal must pre-approve in writing any offers to pay travel and lodging expenses
for any non-U.S. government official. Employees must submit a request for approval throughthe Non-U.S. Government Officials Travel Approval Process.
Paying of travel or sponsoring of visas for any government official is otherwise prohibited.
7. Books & Records
The Company maintains a system of internal accounting controls and keeps its books andrecords in a manner providing reasonable details that accurately and fairly reflecttransactions and dispositions of assets.
••••••All payments and other entries must be properly recorded in the Company’s books
and records;
False, misleading or incomplete entries in the Company’s books, records and otherbusiness documents are prohibited. No transaction should ever be entered into that
requires or contemplates the making of false or fictitious records, in whole or in part;No undisclosed or unrecorded funds or accounts may be established for any
purpose;Circumventing or evading, the Company’s internal accounting controls, or any
attempt to do so, is prohibited;
All payments on behalf of the Company must be approved and supported withappropriate documentation;
No payments shall be made with the intention or understanding that all or any part ofthe payment is to be used for any purpose other than the specific purpose describedby the documents supporting the payment.

These requirements apply to all transactions regardless of financial materiality.

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Anti-Corruption Policy

8. Facilitating Payments
Facilitating payments are prohibited under this Policy. Facilitating payments are relatively
small payments paid to non-U.S. government officials to expedite or facilitate nondiscretionary actions or services, such as:•••••

obtaining an ordinary license or business permit;
processing government papers such as visas;providing police protection;
providing telephone, power or water service; orloading or unloading of cargo

9. Extortionate Demands
Should an Employee encounter a situation involving imminent and serious risk to personalsafety or the safety of Chemours personnel or facilities if a demand for payment is notsatisfied, such payment would not constitute a prohibited bribe under this Policy. Employeesmust exercise their best judgment in such situations and must contact Chemours Legal or
Global Security as soon as possible to report the incident. If necessary, Global Security willtake appropriate actions to ensure the safety of Chemours Employees, their families and/or
Chemours facilities. Chemours Legal will determine any additional actions to be taken andwill work with Finance to ensure that any payment is appropriately recorded in theCompany’s books and records.
Mere economic coercion, however, does not amount to extortion or duress. Employees may
not use a claim of extortion or duress as a pretext to justify an otherwise improper payment.
For example, a demand for payment by a government official as a price to market entry or toobtain a contract does not equate to extortion or duress. The fact that the payment isrequested by the recipient does not alter the corrupt purpose on the part of the person
paying the bribe. Employees can and must refuse such demands.
If you have any doubt or question about the legality of a payment or expenditure,
immediately contact a member of Chemours Legal, Ethics & Compliance or your Ethics
Champion for advice.
10. Third Parties
Payments that the Company, or its Employees, are prohibited from making, promising orreceiving directly under this Policy cannot be made, promised or accepted indirectly througha Third Party. “Third Parties” (also discussed in section 2 above) may include agents,lobbyists, distributors, resellers, consultants, contractors, and freight forwarders.
The Company should not enter any relationship with a Third Party who will have substantive
interaction with government officials on behalf of the Company without first examining theThird Party’s background, qualifications and reputation. Chemours has implemented
integrated global processes to identify and assess Third Parties on a risk-based basis.
Third Party relationships that may involve contact with government officials must be reduced
to a written contract that includes appropriate language regarding compliance with applicable
Anti-Corruption Laws as well as Chemours expectation of ethical business practices.
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Anti-Corruption Policy

11. Non-U.S. Charitable Contributions
For purposes of this Policy, a charitable contribution is a gift of money, product or service toa non-U.S. charitable organization or community fund, such as school or educational
projects or funds, community or social organizations, or infrastructure projects.
Charitable contributions must be consistent with Chemours’ Policy on PhilanthropicDonations, Charitable Contributions, & Gifts. Employees should consult Corporate
Communications before using Company funds or resources to support a charitableorganization or cause. To ensure that non-U.S. donations cannot be interpreted as bribes,
Legal must be consulted and issue written approval before Employees or Third Parties offer
or make any such non-U.S. charitable contribution on behalf of Chemours.
12. Political Contributions
Political contributions intended to influence or obtain a business advantage from agovernment official are prohibited. Employees must seek approval from Chemours
Government Affairs before using Company funds or resources to support politicalcandidates, engaging in lobbying activities, or using Company locations or other assets forpolitical purposes. The Company may sponsor employee political committees or funds andincur reasonable expenses in connection with their establishment and administration, aspermitted by applicable law and Company policies and guidelines.
13. Money Laundering
Money laundering means concealing or disguising the existence of an illegal source ofincome to make it appear legitimate. Use of proceeds generated by unlawful conduct may
give rise to liability in countries in which the Company operates. Employees should
immediately contact Chemours Legal if they know or suspect that a transaction might
involve the payment or the receipt of proceeds of any illegal activity. Alternatively,
Employees can contact the Ethics Hotline to raise concerns confidentially and/oranonymously.
14. Training
Each Employee is responsible for knowing and understanding this Policy, the Chemours
Code of Conduct and other relevant policies and procedures referenced herein. TheCompany will provide and require specified Employees to complete anti-corruption training
and/or certification. For more information on available training, contact your Ethics
Champion, a member of the Ethics & Compliance team, or Chemours Legal. Internet-based
training is always available to Employees on Workday Learning.
15. Auditing
The Company will conduct periodic audits of relevant Company operating units to help
ensure compliance with this Policy and applicable Anti-Corruption Laws.

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16. Hiring
Decisions to hire Chemours Employees, contractors, interns, or Third Parties are to bemade based on merit and applicable Chemours Human Resource policies and practices.
Offers or promises of employment may not be extended with the intent to obtain an improper
business advantage from a government official or agency. This includes, for example, thehiring of current or former government officials, their associates or relatives as aninducement to obtain preferential treatment for the Company.
17. Exceptions
Any exceptions to this Policy must be pre-approved in writing by Chemours Legal.
18. Speaking Up
We all have a duty to protect our culture of integrity. Everyone must be prepared to saysomething if violations of our Code of Conduct are known, seen or suspected. We also
speak up when we have questions or concerns. We talk to each other and to our managers,
and if we need to, we use the Ethics Hotline for confidential assistance.
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We raise a concern if we believe there has been a possible violation of the Code ofConduct or of any law or regulation.
We do not tolerate threats, intimidation, or retaliation against anyone who in goodfaith raises a concern or reports suspected misconduct.
We expect all contractors, agents, distributors, and other business partners to upholdthe principles of the Chemours Code of Conduct when working with or on behalf ofChemours.

There are many resources available to us to raise concerns, including:•••••Supervisors
Business, Function, or Site Leadership
Legal, Finance, or HR representatives
Compliance Officers or Ethics ChampionsThe Chemours Ethics Hotline

19. Related Internal Resources & Links•••Chemours Code of Conduct
Anti-Corruption Policy & Resources Page
Additional Policies, Procedures, and Reference Materials

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