Our Constitution
and Code of Conduct

Valuesand rules of conductOur Constitution
and Code of Conduct

Dear employees,
Blaser Swisslube has earned itself a good reputation ever since it was founded in 1936 –thanks to our expert staff, our proximity to customers and our high-quality products andservices. We want to take care of that.
Customers, business partners, shareholders, authorities and the general public place theirtrust in responsible and lawful conduct on the part of all of us. This trust is of great
importance for the reputation and success of our company.
Even though Blaser Swisslube is active all over the world today, we have a common
foundation – integrity. Our behavior is based on our corporate culture with its anchoredvalues and principles. We maintain fair and open dealings both internally and externally.
We are committed to upholding high ethical standards and applicable law.
Our core values are anchored in our Constitution. The Code of Conduct serves asa guideline for us to act correctly in our day-to-day business.
Each and every one of us contributes to the success of Blaser Swisslube. Thank you
for living our values so that we can all enjoy working for Blaser and be proud of
our company.

Marc Blaser
Chairman of the Board of Directors

Peter Blaser
Honorary President

We measure our success by thesatisfaction of our customers –thanks to following our corporate
philosophy in thought and deed.

We aspire to success forall stakeholders.

Our common goal is corporate success.
We aim at all times for profitability to enable
investments in the future, and for an appropriate
return on investment.
We create the conditions required for each one of
us to work fruitfully.

We measure our successby the satisfaction of ourcustomers.

We produce cutting fluids and lubricants ofoutstandingly high quality. We develop our products
in close contact with customers, and market them
globally.
We provide all the means required for ongoingproduct development. In this connection we also
leave room for unconventional solutions.
We develop new products in conformity withmarket needs and the specific requirements oftarget groups.
We take environmental concerns seriously at all
times both in thought and deed.

We reach our goals
by teamwork.

As team members we are all personally committed
to reaching the corporate goals with our entire
capabilities. Goals that also convince ethically.
We are loyal at all times both to the company andto our colleagues.
We all aspire to a good working atmosphere, basedon cooperation, trust, openness and mutual respect.
We discuss tensions and conflicts openly, identify
their causes and make every effort to solve them.
We are not afraid of criticism. It gives us theopportunity to make improvements. We learn
from mistakes.

45

Human resource
development
and coaching areimportant to us.

We believe in management by goal setting on anagreed basis.
We uphold personality development and coachingby on-the-job and off-the-job training.
We attach great importance to regular staff
appraisal interviews. They promote development
both on the employee and the management sides.
We give clear and regular information. We likepeople to ask questions.
We promote self-responsibility; that is why we
prefer self-control to supervision.

Our organization is clear
and understandable.

Our organization has to be kept simple and clear
to everyone. All competencies, rights and powers
within our organization are job-related.
We allow the greatest possible freedom of action,
to enable optimal entrepreneurialism at all levels.
Our job appointments are based on professional
capability and team competence.
The salary is according to their level of responsibility,
performance, capabilities and company results.
All our plant – the installations, equipment andbuildings are in harmony with the high quality
standard of our products.
Our constitution shows us the way to remain an
outstanding company.
We are all called upon to address any deviations
from the constitution.
We aspire to continuous improvement.
Let us go on.

6

7

1

Message, scopeand responsibilities

1.1 Message

We measure performance not only according to the results achieved but also by themanner in which such results are achieved. The Code of Conduct specifies with binding
effect what the company expects from us.
Business partners, customers, shareholders, authorities and the general public place theirtrust in us all acting in a responsible and lawful manner. This trust is of great importancefor the reputation and success of our company. We therefore expect all our employees toactively participate and take responsibility for implementing and complying with the Codeof Conduct. Integrity is an essential element of our corporate culture. Accordingly, ethicaland lawful behavior shapes our daily actions, the way we interact with each other andwith our external stakeholders.
We are determined and committed to conducting business in accordance with high ethicalstandards and the applicable law. Therefore, in case of doubt, compliance and integrity
always take precedence over any potentially critical business. Any unlawful or improper
conduct, even if committed just by a single employee, can seriously damage the reputationof our company which has been built over the years.

The Code of Conduct
supplements our Constitution
and provides us with the most

We attach a great deal of importance to a culture of personal responsibility, mutual trust,
openness and mutual respect. We are not afraid of direct criticism, which allows us tomake improvements. Every employee can make an active contribution by maintaining an
open dialog and through active participation. Everyone has a voice.

important rules of conduct
for correctly handling our
day-to-day business.
1.2 Scope of application

The Code of Conduct applies to the members of the Board of Directors, the members of
the Executive Team, superiors and employees (collectively referred to as «employees»)
worldwide and constitutes a minimum standard.

1.3 Responsibilities

The Executive Team is responsible for the introduction and monitoring of compliance.
Superiors must live up to their role model function and demonstrate a high level of socialand ethical competence. They are therefore responsible for ensuring that the Code of
Conduct is complied with and implemented in their area of responsibility. They promote a
culture of compliance within the company. They inform their employees about legal andcontractual obligations as well as internal regulations relevant to the performance of theirduties at the appropriate level. Annually, they ensure that every employee is familiar withthis Code of Conduct and its contents.
Each employee is personally responsible and obligated to know and comply with the external and internal provisions relevant to his work, to align his behavior with the Code of
Conduct and to contact colleagues, the respective direct superior or the person responsible
for the Code of Conduct in the event of questions or ambiguities and to speak about them
openly (cf. 5.1).

8

9

2

General guidelines

2.1 Compliance

We commit to comply with local, national and international laws, regulations, contracts
and internal company standards (such as policies, guidelines, directives and processes).
As an international company, we are expected to respect the basic local cultural conditions
and rules insofar as these do not contradict with this Code of Conduct.
It is also prohibited to induce third parties to carry out illegal activities or to knowingly
participate in such activities.

2.2 Personal responsibility
and reporting obligations
in case of misconduct

A Code of Conduct does not and cannot fully list all requirements for our behavior. If noclear requirements result from legal provisions, company standards or corporate practice,
we act to the best of our judgment and with common sense. The following questions
could be helpful:

We adhere to the Code

1. Is my behavior in compliance with legal provisions or with the Code of Conduct
or corporate standards?

of Conduct. In case of doubt,

2. Can my behavior lead to negative consequences for me, the company,
its employees or third parties?

we get advice and help.

3. How would I feel if my behavior would be published in the local newspaperor reported to the public prosecutor?
We are expected to seek advice and help directly from our superiors or, if necessary,from the person responsible for the Code of Conduct if there should be any doubt
regarding our own conduct or about legally or ethically dubious processes in our work
environment (cf. 5.1). Therefore, loyalty, openness and a sense of responsibility are ofessential importance. Repercussions will not be tolerated under any circumstances.

2.3 Accuracy of accounts
and reporting

10

Records and reports (internal and published) must be accurate, complete and true to thebest of our knowledge. Proper accounting and balance sheet principles must be adhered
to. In particular, every accounting entry must be based on documents that correspond to
the facts. In addition, all transactions must be recorded. All financial funds and assets mustbe listed on the accounts. Illegal funds and illegal accounts are strictly prohibited.

11

2

General guidelines

2.4 Confidentiality anddata protection

Among other things, we distinguish ourselves in the market due to our key assets:confidential information and intellectual property. These must be shielded from misuse
or unjustified disclosure.
We ensure that confidential information is only passed on internally to persons who needit to perform their duties and are also authorized to receive it. Also, when passing on
confidential information to third parties, a confidentiality agreement must be signed.
The confidentiality requirement, which remains in effect not only during the employment
relationship but also after its end, applies to internal confidential or protected informationof our company and our employees.
Confidential information from or about suppliers, customers, consultants or otherbusiness partners must also be protected according to the legal provisions and contractual
agreements if applicable. Any further use is only permitted after consultation and writtenconsent with the parties involved.

We handle data and assets
carefully and responsibly.

2.5 The protection ofcompany assets

12

We are committed to protecting the tangible and intangible assets as well as thefinancial resources of the company against theft, loss, misuse and squandering and tohandling them with care. All assets are generally and primarily intended for use inbusiness activities. Private use must be authorized in advance.

13

3

Conduct in thework environment

3.1 Cooperation

Employees should be able to perform their duties in a good working climate. Thisrequires employees to treat each other with trust, decency, openness and mutual respect(also when dealing with superiors and subordinates). We address tensions and conflicts
openly, explore and try to solve them. We also expect our employees to commit themselves
to working together and to assume full responsibility for the tasks assigned to them.

3.2 Workplace and equal
opportunities

We want to provide our employees with a safe and healthy workplace, offer themreasonable remuneration for their performance and ensure equal opportunities.
We strive to support all employees in their personal and professional development.

3.3 Harassment

Harassment, discrimination and other forms of intimidation are not tolerated andconsistently sanctioned.

3.4 Performance of duties in
offices and institutions

The company welcomes its employees assuming duties or offices in public service or social
institutions. If we intend to take on additional remunerable secondary employment (e.g.
as an employee, a member of the board of directors or a foundation board) or to accept
a political office, we must inform our direct superior in advance and have the projectapproved. This activity as well as honorary duties in an association or in other institutions
outside of the company must not conflict with the interests of the company or affect any
obligations under the employment agreement.

3.5 Private and business
expenses

Business and private expenses are to be strictly separated; they must not be mixed. Apartfrom the local company standards (expenses guideline) all business expenses are subject tothe principles of clarity, transparency and verifiability (receipts).

3.6 Communication

To ensure an open and effective communication on all levels, it has to be accurate,complete, truthful and timely. This applies regardless whether the communication inquestion is internal or external, and it applies to all relevant stakeholders, e.g. employees,
superiors, customers, business partners, the public and authorities.

We are committed to agood working atmosphere.
Our cooperation is based ontrust, openness and mutual
respect.

Social media (e.g. Facebook, LinkedIn, Instagram) make it possible to instantly communicate with a large group of recipients. In using these services, we must ensure that there are
no violations of any locally applicable labor and data protection regulations and that thecompany standards are adhered to.

14

15

4

Dealing with business
partners

4.1 Relationship with
suppliers and customers

Business partners must be selected after comparing price, quality, performance andsuitability based on objective criteria. Agreements with them must be made in a clear andunambiguous form and documented together with subsequent changes and additions.

4.2 Bribery/corruption/gifts

Corruption and bribery in dealing with business partners, particularly through intermediaries, are prohibited. We do not tolerate any forms of corruption and bribery (including
bribes/«facilitation payments»). It is also prohibited to agree in any way to affectdecision-making, including through illegal payment offers or by demanding or granting
undue advantages.
With the exception of the following paragraph, such advantages are considered to be
any gifts, invitations or other cash-equivalent advantages offered directly (or indirectly, i.e.
through intermediaries) by one of the office holders or third parties for ourselves or forthe benefit of other third parties (accepting advantages) or which we offer directly(or indirectly, i.e. through intermediaries) to an office holder or a private individual either
for personal benefit or the benefit of other third parties (granting advantages).

We are committed to faircompetition and do not accept
unfair business practices.

Minor, socially customary advantages, such as modest gifts and invitations in accordancewith local customs, are regarded as customary signs of courtesy between business partners
and are set out in the directive on gifts and entertainment.
4.3 Conduct in relation
to competitors

We are committed to fair competition in relation to competitors, customers and suppliers.
It is not permitted to spread untruths or rumors among customers or suppliers thatconcern them, their products or employees. We comply with the applicable competitive
and anti-trust laws such as but not limited to:• No agreements with competitors to fix prices or sales conditions;• No agreements with competitors to share markets and/or customers;• No agreements with competitors on waiving the submission of a bid, offeringa specific price or submitting a bid that is clearly less favorable than the offer
submitted by a competitor as part of a tender process;• No transmission of sensitive information to competitors such as current prices,
future price developments, price margins, costs, offers, market shares, sales practices,
terms, development or production plans, investments or other trade secrets;• No agreements on absolute territorial protection or agreements on minimum
or fixed prices;• No abuse of a dominant market position when reaching agreements withcustomers and suppliers.
Moreover, we accept and follow the relevant international trade restrictions andregulations of different countries and international organizations such as the United
Nations. If in doubt, planned actions or agreements that include provisions that could
impede competition or violate international trade restrictions must be reviewed
by a specialist.

16

17

4

Dealing with business
partners

4.4 Secondary employment/
shareholding

Any secondary employment with companies that are in competition with our company(customers, suppliers, partners, competitors) is prohibited. Any exceptions must be
approved by the members of the Executive Team.
Having any financial involvement in a competing company, in customers or suppliers
is not allowed (exception: companies listed on the stock exchange).

We disclose the situation when
personal interests influence ourbusiness activities.

4.5 Commissioning ofbusiness partners
for private purposes

In order to avoid a conflict of interests between company and privacy, employees may
not use the services offered by their business partners. Exceptions are to be arranged inadvance with the superior or the responsible Human Resources Manager.

4.6 Conflicts of interest

Both within and outside of the company, situations are to be avoided in which ourpersonal interests or the personal interests of third parties conflict or appear to conflictwith the interests of the company. Any identified or suspected conflict of interest must
be disclosed and immediately reported to superiors. If necessary, we will obtain written
approval on how further action should be taken in such a case (e.g. to stand down).
If we wish to hire a person close to us, i.e. a person with whom we have a close personal
relationship (e.g. family members, other residents of the same household or close friends),
our superior is to be informed, who will then, together with Human Resources, decide how
to proceed.

18

19

5

Reports of misconductand questions

5.1 Basic principle

As employees, we are expected to express our concerns in the event of actual or assumed
unlawful activities and not to remain silent or simply overlook them. In such cases, or if
there are questions or ambiguities, we are to raise them directly to the person involved
or discuss the situation, or the person responsible for the Code of Conduct.
If this is not possible for some reason, such concerns or questions may also be reported
on an anonymous basis. In the speak-up process the corresponding procedure is recorded.
The relevant information can be found on the Intranet.

5.2 Protection of thereporting person

Employees who report actual or suspected violations of external or internal regulations
in good faith are protected and no repercussions against them will be tolerated.
However, we do not tolerate employees making such reports contrary to their betterknowledge, thus abusing their right to submit reports. Such employees must reckon withappropriate sanctions.

We are committed to ourvalues and principles andreport any behavior thatdeviates from them.

20

21

6

Final provisions

6.1 Implementationand training

As employees, we are committed to complying with the Code of Conduct. The company
reserves the right to amend the Code of Conduct if necessary in line with its right to issue
directives. The current version applies in each case. Any changes will be notified in goodtime.
We are made aware of the correct behavior by means of training courses and further
documentation. Our superiors and the person responsible for the Code of Conduct support
and advise all employees for questions and doubts regarding the Code of Conduct.

6.2 Violations and sanctions

The employees are obligated to actively collaborate in the implementation of theCode of Conduct. Intentional misconduct and violations of legal provisions or company
standards such as this Code of Conduct or other policies or directives will not be tolerated
and can, regardless of the hierarchical position in the company and depending on the levelof severity and type of the violation, result in disciplinary (e.g. warning, reprimand) or
legal consequences (e.g. termination, damages, fines, jail). All violations of the regulations
will be investigated.

6.3 Publication

Every employee can find the current and valid version of the Code of Conduct
on the Intranet.

6.4 Entry into force

This Code of Conduct was approved by the members of the Executive Teamin December 2018.

We integrate the Code of
Conduct into our decisions.
And we motivate all employees
to act accordingly.

22

23

60.16_en (0624) © Blaser Swisslube AG, Switzerland

Blaser Swisslube

contact@blaser.com

blaser.com