Kennametal Anti-Corruption andAnti-Bribery Training
Training For: 3rd Parties© 2018 Kennametal Inc. l All rights reserved. l Proprietary and Confidential

Introduction:Anti-Corruption and Anti-Bribery Training for Business Partners
As a responsible global organization and consistent with our core values, we arecommitted to conducting business to the highest ethical and legal standards
wherever we operate in the world. This includes full compliance with the U.S.
Foreign Corrupt Practices Act (FCPA), U.K. Bribery Act and all applicable anticorruption and anti-bribery laws wherever we do business. We expect all ourpartners, including all sales agents and distributors to share our commitment toethics and integrity, while also ensuring full compliance with all applicable laws
wherever they operate, including the FCPA. We expressly prohibit employees
and partners from engaging in bribery in any form or for any purpose, anywherein the world. Kennametal’s Global Anti-Corruption and Anti-Bribery Procedure
applies to all third parties. Please review this procedure and comply with therequirements. We value your partnership and thank you for taking the time tocomplete this informational training program.

Requirements for Doing Business with Kennametal•

As a representative of Kennametal in the market place, we havecertain requirements related to your business operations. (These items
are part of your agreement with Kennametal):– Compliance with our “Code of Conduct”.
– Compliance with all applicable laws and regulations.
– We strictly prohibit the use of bribery or corruption in any form to gain orretain business. No exceptions.
– Bribery is illegal and contrary to Kennametal’s values (you must complywith our Global Anti-Corruption and Anti-Bribery Policy).
– Compliance with United States export regulations and other applicable
export regulations that may apply to the transaction.

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Promptly investigate and remediate ethics and compliance concernsthat may arise in your business operations.
Always operate with the highest ethical standards© 2018 Kennametal Inc. l All rights reserved. l Proprietary and Confidential l 2

What is the Foreign Corrupt Practices Act and How Doesit Apply to Your Business?
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Bribery and corruption is illegal under the U.S. Foreign Corrupt Practices
Act (FCPA)The FCPA applies to you wherever you operate because Kennametal is aU.S.-based corporation.
Businesses and individuals can be personally prosecuted for engaging inbribery or corruption.
Even alleged violations can seriously damage reputations:-- Diminish our standing in the industry-- Negatively affect customers’ perceptions-- Impair our ability to succeed, as individuals and as companies

The reputations of both companies are at stake!

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Who is Covered Under the FCPA?
The FCPA applies to:– U.S. Companies• Foreign subsidiaries and affiliates of U.S. companies[Examples include: KMT India Ltd., KSSPL, KMT Korea, Ltd., KMT (Xuzhou) CompanyLtd., KMT Hardpoint Shanghai Ltd., KMT Singapore Pte Ltd., KMT Australia Pty, KMTMalaysia Sdn Bhd, KMT (Thailand) Co. Ltd.]• Employees, Distributors and Third Party Agents of suchcompanies

Kennametal’s distributors must comply with the FCPA!

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Who is a “Foreign Government Official” Under theFCPA?
Under the FCPA, the term “foreign government official” includes:•Any officer or employee of a government or any department, agency,or instrumentality of the government.

•Any person acting in an official capacity for or on behalf of any foreign
government, department, agency or instrumentality.

•Officers and employees of public international organizations (e.g.
World Bank, United Nations).

•Political party officials and candidates for public office.

Always “KNOW” the party you are dealing with. Who do they work for?

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What is “Bribery”?
A bribe is the giving or promising to give something ofvalue (regardless of amount) to gain an improper
advantage.
A few examples of bribes are cash, gift cards, sharing ofcommissions, vacations, extravagant gifts, employment
opportunities in return for business gains…etc.
It is not just the value of the gift, but that it was given with
the intent of getting a favorable decision or treatment inreturn, or to gain or retain business.
Business gifts and entertainment are generally permissiblewhere they are reasonable in value, they are tied to a clear
business purpose, and are not being offered in return for
gaining or retaining business.
The giving or receiving of gifts, entertainment, or anythingof value with a government official is strictly prohibited.

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What is an “Improper Advantage”?
Includes the following:
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obtaining or retaining business;directing business to any person or firm;
obtaining a tax break;realizing a break on customs duties through reclassification or undervaluation;
extending an existing contract;
obtaining permission to secure real estate;rendering a favorable judicial or regulatory decision, or waiver ofpenalties; andgranting a license or concession.
When in doubt, ask questions and do not proceed!

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Raising Compliance Questions or Concerns•

You can report Kennametal-related compliance questions andconcerns to our Office of Ethics and Compliance.
– K-corp.ethics@Kennametal.com– (1) 412-248-8275•Our confidential Helpline System is available to our partners 24/7 – ifyou file a report, provide as much detail as possible to allow us toproperly investigate.

•See Kennametal’s Ethics and Compliance page on Kennametal.com
for more information.

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