Heraeus
Code of Conduct
VERSION 10/2018

1. PREAMBLE
The Heraeus Group (“Heraeus”) is a highly-respected, family-owned international company that enjoys
an excellent reputation throughout the world. Its
operations are governed by this Code of Conduct(“Code”), which is an integral part of our responsibilityconscious management structure. This Code applies
to the employees, officers and directors (“Employees”)
of all Heraeus organizations worldwide. Compliancewith the principles described in this Code ensures andpreserves our long-term business success.
Furthermore, compliance with all binding statutory
requirements at national and international level,with the Universal Declaration of Human Rights andwith the regulations of the organizations of which
Heraeus is a member, forms the basis of all corporate
and business activities at Heraeus.
It is the Employees‘ responsibility to know and understand the laws and internal rules applicable totheir job responsibilities, to comply with the letterand spirit of these laws and rules and to performtheir activities in an ethical manner. Furthermore,
Heraeus expects its Employees to critically examine
if their behavior could be considered as unethicalor harmful to the reputation of Heraeus.
Failure to comply with this Code will not be tolerated
and may result in appropriate disciplinary action bythe employer.
2. ENSURING FAIR COMPETITION
Heraeus expects its Employees to comply with theapplicable laws for the protection of fair and opencompetition. The applicable statutory provisions generally prohibit agreements with competitors on prices and conditions, agreements with competitors forthe purpose of market or customer allocation, concerted actions with competitors with respect to prices, conditions, markets or customers, as well as
unfair practices. As a general rule, the exchange ofsensitive market information, in particular strategic
information, with competitors is also prohibited.
3. THE FIGHT AGAINST CORRUPTION
Heraeus is convinced of the quality of its products
and services and of the performance and skills of its
Employees. Heraeus strictly prohibits all forms ofdirect or indirect bribery of business partners andpublic officers. Consultants and distributors mustnot be taken advantage of for granting undue favors
to business partners or public officers.
The Guideline for the Prevention of Bribery in Commercial Transactions and the Guideline for the Conclusion of Consultancy and Distribution Agreements
contain principles for the granting of business courtesies and the conclusion of consultancy and distribution agreements which all Employees must observe. Heraeus Medical Employees must observe
supplementary rules when dealing with doctors andHeraeus Code of Conducthospitals which are laid down in the Heraeus Medical
Code of Conduct.
Employees of Heraeus are prohibited from demanding or receiving business courtesies or from accepting the promise of such business courtesies as consideration for the purchase of products or services.
The Guideline for the Procurement of Products andServices contains rules of conduct for the acceptance of business courtesies from business partners.
4. THE FIGHT AGAINST MONEY LAUNDERING AND TERRORISM
FINANCING
Compliance with the national and international provisions on the prevention of money laundering andterrorism financing and the responsible handling ofprecious metals throughout the entire supply chain(upstream and downstream) are of high importancefor Heraeus. Heraeus has issued the Guideline forthe Prevention of Money Laundering as well as theSustainable Sourcing Guideline which set standards for the selection and monitoring of customers. Heraeus regularly engages auditors to confirm
Heraeus‘ compliance with the standards laid downin the London Bullion Market Association Responsible Gold Guidance.
Heraeus is determined to prevent itself from being
exploited for illegal purposes, in particular for money
laundering, criminal tax evasion or any other fiscaloffenses. Heraeus has established adequate standards and processes to reduce the risk of exploitation
for illegal purposes and to provide appropriate
training and support to its Employees.
5. AVOIDANCE OF CONFLICTS OF INTERESTAll Employees have an obligation to act in the bestinterests of Heraeus. Employees should avoid any
activity, interest, or association outside of Heraeus
that could impair their ability to perform work objectively and effectively or that could give the appearance of interfering with their responsibilities performed on behalf of Heraeus or its clients. Employees
must reveal existing or potential conflicts of interest
to their supervisors, the relevant HR department or
the responsible Compliance Officer.
Secondary employment at companies of competitors, customers or suppliers, as well as financial
investments in such companies which exceed alimit of one percent (1%) are subject to the express
written consent of the Group Management Board.
Financial investments (greater than 1%) by closefamily members must be notified to the GroupManagement Board.
Favoritism to specific business partners undertaken
for the furtherance of private interests, in particularfavoritism to family members, is prohibited. Even
the appearance of favoritism for the furtherance ofprivate interests must be avoided.

6. COMPLIANCE WITH THE BASIC PRINCIPLES OF NATIONALAND INTERNATIONAL TRADE
Heraeus adheres to all national, multinational andsupranational foreign trade regulations. All Employees are obligated to adhere in particular to theapplicable export and import prohibitions, official
approval requirements as well as the applicableduty and tax requirements.
7. HUMAN RIGHTS
Heraeus guarantees the observance of universallyrecognized human rights and has issued theHeraeus Human Rights Policy which supplements
this Code.
Heraeus also expects its suppliers to ensure safeand fair working conditions. Suppliers are selectedand monitored in accordance with the provisions ofthe Heraeus Sustainable Sourcing Guideline.
Heraeus is committed to protecting its Employees
and to creating and maintaining a safe and attractive
work environment for its Employees. Heraeus seeks
to provide fair remuneration and reasonable working
hours to its Employees in each country, and rejects
all forms of forced labor and child labor.
Heraeus reasonably ensures that tantalum, tin,tungsten and gold contained in the products manufactured by Heraeus do not directly or indirectly
finance or benefit armed groups that are perpetratorsof serious human right abuses in the Democratic
Republic of the Congo or any adjoining country.
Heraeus exercises due diligence with respect todetermining the source and chain of custody ofthese minerals and makes its due diligencemeasures available to customers upon request.
8. CREATING AND MAINTAINING SAFE WORKING CONDITIONS
Heraeus seeks to preserve and promote the healthof its Employees and therefore aims at maintaininga high level of occupational safety at all Heraeus
production locations. Heraeus expects its Employees, especially its executives, to be committed toensuring occupational safety at all times.

sound business decisions on the basis of risk-benefit
analyses. This also includes the careful verificationof the integrity of Heraeus business partners and theprivate individuals who support the business partners‘ companies. Heraeus also places great value on
the integrity of its Employees. Depending on the typeof business and an Employee‘s work location or function, it may be necessary to review the Employee‘sfinancial situation and personal integrity.
All documents of Heraeus, including in particularfinancial reports, research reports (external use)
and accounting documents and invoices (internaluse), must reflect the relevant facts correctly andtransparently.
Unless expressly otherwise provided in their employment agreement or authorized by a supervisor, Employees are not permitted to use business resources
for personal purposes. In particular, Employees are
not allowed to use Heraeus IT systems to view, store,
or forward unlawful, offensive or other inappropriate
pages or messages.
10. ENVIRONMENTAL AND PRODUCT SAFETY; USE OF NATURALRESOURCES
Heraeus‘ activities are based on compliance with theapplicable regulatory requirements for environmental
protection and workplace safety. Heraeus has established processes and standards for ensuring legal
compliance as part of its responsibility management.
Heraeus is committed to a respectful treatment of
the resources of nature. With its innovative products
for environmental protection, Heraeus makes animportant contribution to the long-term protection of
the foundation of human life. Heraeus regularly
publishes Sustainability Reports on the achieved
sustainable growth. Heraeus places the highest
requirements on the quality and safety of its products over their entire lifecycle.

9. PROTECTION OF COMPANY ASSETSThe commercial success of Heraeus is based on theinnovative ability of its Employees and the knowledge acquired over many decades.
Proprietary and confidential information generated
and gathered in connection with our business operations is a valuable asset. All Employees are required toensure that business or trade secrets of Heraeus andof its business partners do not become known outsideof Heraeus. The unauthorized disclosure of businessor trade secrets to third parties or their unauthorized
use for personal purposes is not permitted.
Heraeus expects its Employees to treat the assets ofHeraeus responsibly, and to make commercially
Heraeus Code of Conduct

11. PREVENTION OF DISCRIMINATION
Heraeus expects its Employees to respect different
outlooks on life and cultural or country-specific characteristics when dealing with other Employees (including former Employees), applicants and business
partners. Heraeus strives to provide a workplace anda working environment in which discrimination andsexual harassment are not tolerated, and where everyone has an equal opportunity to work, advance, andcontribute to our success. Heraeus selects, develops,
promotes and compensates Employees, including
former Employees, applicants and business partners
based on objective and comprehensible criteria, without distinction or discrimination on account of age,color, national origin, race, religion, gender, physicalor mental disability, or any other legally protected
personal characteristic.
12. DATA PROTECTION
Heraeus respects the personal rights of its Employees and business partners. Heraeus collects, processes and uses personal data of its Employees andbusiness partners only in accordance with the applicable data protection regulations. Personal dataare kept safe and are appropriately protected against
unauthorized access. Heraeus expects its Employees
to observe the applicable rules on data protection.
13. DEALING WITH THE MEDIA
The provision of information to the public, including
the media, in a transparent and consistent manner
facilitates dialog and strengthens the world-wide
image of Heraeus. Official statements on behalf ofHeraeus, in particular statements to the media, may
only be made by authorized Employees. Further rules
for the interaction with the media are laid down in
the Guideline for Public Relations and for the Use ofthe Intranet (Heraeus Portal).

Heraeus Holding GmbH
Heraeusstraße 12–14
63450 Hanau

14. HERAEUS COMPLIANCE SYSTEMThe Group Management Board has appointed Compliance Officers (COs) for the individual companiesof the Heraeus Group. In addition, a chief Heraeus
Compliance Officer (HCO) has been appointed whoassists the COs of the individual companies in theimplementation and monitoring of the Code. TheHCO directly reports to the CEO.
The Responsibility Office, which was established in2016, supports existing organizations such as EHS,Global Trade Compliance, Data Protection and
Supply Chain Management in establishing reliableand efficient structures and processes and ensures aregular exchange between the Group Management
Board, the HCO, the COs and the heads of EHS,Tax, Customs and Export Control, Global TradeCompliance, Data Protection and Internal Audit.
Heraeus has introduced a uniform training concept
throughout the Group with the intention to inform
Employees in an appropriate way about the Heraeus
compliance system and to make them aware of thelegal provisions and internal guidelines relevant for
their respective field of activity.
Employees may direct any inquiries about the content or interpretation of the Code or any reports ofviolations of the Code to their respective supervisorsor the responsible CO. In addition, they have theoption to contact the HCO, Mr. Bernhard Reckmann,directly by telephone (telephone hotline: +49 (6181)
35-5500) or by e-mail in their native language(e-mail: heraeuscomplianceofficer@heraeus.com) orto contact the external ombudsman of theHeraeus Group, Dr. Rainer Buchert (telephone hotline: +49 (6105) 921355) or by e-mail (e-mail:dr-buchert@dr-buchert.de). Any reprisal or retaliation against any person who has in good faith reported
a violation or suspected violation of the Code isprohibited.