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Heraeus Code of Conduct

1.

Preamble
The Heraeus Group ("Heraeus") is a highly-respected, family-owned international company thatenjoys an excellent reputation throughout the world. Its operations are governed by this Code ofConduct ("Code"), which is an integral part of our responsibility-conscious management structure.
This Code applies to the employees, officers and directors ("Employees") of all Heraeusorganizations worldwide. Compliance with 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 and with the regulations of the organizationsof 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 applicableto their job responsibilities, to comply with the letter and spirit of these laws and rules and toperform their activities in an ethical manner. Furthermore, Heraeus expects its Employees tocritically examine if their behavior could be considered as unethical or harmful to the reputationof Heraeus.
Failure to comply with this Code will not be tolerated and may result in appropriate disciplinary
action by the employer.

2.

Ensuring Fair Competition
Heraeus expects its Employees to comply with the applicable laws for the protection of fair andopen competition. The applicable statutory provisions generally prohibit agreements withcompetitors on prices and conditions, agreements with competitors for the purpose of market orcustomer allocation, concerted actions with competitors with respect to prices, conditions,markets or customers, as well as unfair practices. As a general rule, the exchange of sensitivemarket 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 skillsof its Employees. Heraeus strictly prohibits all forms of direct or indirect bribery of business
partners and public officers. Consultants and distributors must not be taken advantage of for
granting undue favors to business partners or public officers.
The Guideline for the Prevention of Bribery (Entertainment & Gifts) and the Guideline for theConclusion of Consultancy and Distribution Agreements contain principles for the granting ofbusiness 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 and hospitals which are laid down in the Heraeus Medical Code of Conduct.
Employees of Heraeus are prohibited from demanding or receiving business courtesies or fromaccepting the promise of such business courtesies as consideration for the purchase of products
or services. The Guideline for the Procurement of Products and Services 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 launderingand terrorism financing and the responsible handling of precious metals throughout the entire
supply chain (upstream and downstream) are of high importance for Heraeus. Heraeus has issued
the Guideline for the Prevention of Money Laundering as well as the Sustainable Sourcing

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Guideline which set standards for the selection and monitoring of customers. Heraeus regularlyengages auditors to confirm Heraeus' compliance with the standards laid down in the London
Bullion Market Association Responsible Gold Guidance.
Heraeus is determined to prevent itself from being exploited for illegal purposes, in particular formoney laundering, criminal tax evasion or any other fiscal offenses. Heraeus has establishedadequate standards and processes to reduce the risk of exploitation for illegal purposes and toprovide appropriate training and support to its Employees.

5.

Avoidance of Conflicts of Interest
All Employees have an obligation to act in the best interests 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 a limit of one percent (1%) are subject to theexpress written consent of the Group Management Board. Financial investments (greater than1%) by close family members must be notified to the Group Management Board.
Favoritism to specific business partners undertaken for the furtherance of private interests, inparticular favoritism to family members, is prohibited. Even the appearance of favoritism for thefurtherance of private interests must be avoided.

6.

Compliance with the Basic Principles of National and International Trade
Heraeus adheres to all national, multinational and supranational foreign trade regulations. AllEmployees are obligated to adhere in particular to the applicable export and import prohibitions,
official approval requirements as well as the applicable duty and tax requirements.

7.

Human Rights
Heraeus guarantees the observance of universally recognized human rights and has issued theHeraeus Human Rights Policy which supplements this Code.
Heraeus also expects its suppliers to ensure safe and fair working conditions. Suppliers areselected and monitored in accordance with the provisions of the Heraeus Sustainable Sourcing
Guideline.
Heraeus is committed to protecting its Employees and to creating and maintaining a safe andattractive work environment for its Employees. Heraeus seeks to provide fair remuneration andreasonable working hours to its Employees in each country, and rejects all forms of forced laborand 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 areperpetrators of serious human right abuses in the Democratic Republic of the Congo or any
adjoining country. Heraeus exercises due diligence with respect to determining the source andchain of custody of these minerals and makes its due diligence measures available to customers
upon request.

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8.

Creating and Maintaining Safe Working Conditions
Heraeus seeks to preserve and promote the health of its Employees and therefore aims at
maintaining a high level of occupational safety at all Heraeus production locations. Heraeus
expects its Employees, especially its executives, to be committed to ensuring occupational safety
at all times.

9.

Protection of Company Assets
The commercial success of Heraeus is based on the innovative ability of its Employees and theknowledge acquired over many decades. Proprietary and confidential information generated andgathered in connection with our business operations is a valuable asset. All Employees are
required to ensure that business or trade secrets of Heraeus and of its business partners do not
become known outside of Heraeus. The unauthorized disclosure of business or trade secrets tothird parties or their unauthorized use for personal purposes is not permitted.
Heraeus expects its Employees to treat the assets of Heraeus responsibly, and to makecommercially sound business decisions on the basis of risk-benefit analyses. This also includes
the careful verification of the integrity of Heraeus business partners and the private individuals
who support the business partners' companies. Heraeus also places great value on the integrityof its Employees. Depending on the type of business and an Employee's work location or function,
it may be necessary to review the Employee's financial situation and personal integrity.
All documents of Heraeus, including in particular financial reports, research reports (external use)
and accounting documents and invoices (internal use), must reflect the relevant facts correctly
and transparently.
Unless expressly otherwise provided in their employment agreement or authorized by asupervisor, 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 Natural Resources
Heraeus' activities are based on compliance with the applicable regulatory requirements forenvironmental protection and workplace safety. Heraeus has established processes andstandards 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 an important 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.

11.

Prevention of Discrimination
Heraeus expects its Employees to respect different outlooks on life and cultural or country-specificcharacteristics when dealing with other Employees (including former Employees), applicants andbusiness partners. Heraeus strives to provide a workplace and a working environment in which
discrimination and sexual harassment are not tolerated, and where everyone has an equal
opportunity to work, advance, and contribute to our success. Heraeus selects, develops,
promotes and compensates Employees, including former Employees, applicants and business
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account of age, color, national origin, race, religion, gender, physical or 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 and business partners only in accordancewith the applicable data protection regulations Personal data are 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 MediaThe provision of information to the public, including the media, in a transparent and consistentmanner facilitates dialog and strengthens the world-wide image of Heraeus. Official statementson behalf of Heraeus, 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 of the Intranet (Heraeus Portal).

14.

Heraeus Compliance SystemThe Group Management Board has appointed Compliance Officers (COs) for the individualcompanies of the Heraeus Group. In addition, a chief Heraeus Compliance Officer (HCO) has
been appointed who assists the COs of the individual companies in the implementation andmonitoring of the Code. The HCO directly reports to the CEO.
The Responsibility Office, which was established in 2016, supports existing organizations such
as EHS, Global Trade Compliance, Data Protection and Supply Chain Management inestablishing reliable and efficient structures and processes and ensures a regular exchange
between the Group Management Board, the HCO, the COs and the heads of EHS, Tax, Customs
and Export Control, Global Trade Compliance, Data Protection and Internal Audit.
Heraeus has introduced a uniform training concept throughout the Group with the intention toinform Employees in an appropriate way about the Heraeus compliance system and to make themaware of the legal 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 reportsof violations of the Code to their respective supervisors or the responsible CO. In addition, they
have the option to contact the HCO, Mr. Bernhard Reckmann, directly by telephone (telephonehotline: +49 (6181) 35-5500) or by e-mail in their native language (e-mail:heraeuscomplianceofficer@heraeus.com) or to contact the external ombudsman of the Heraeus
Group, Dr. Rainer Buchert (telephone hotline: +49 (6105) 921355) or by e-mail (e-mail: drbuchert@dr-buchert.de). Any reprisal or retaliation against any person who has in good faithreported a violation or suspected violation of the Code is prohibited.

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