ARCADIUM LITHIUM PLC
CORPORATE DISCLOSURE POLICY
Adopted March 7, 2024
Arcadium Lithium plc (“we,” the “Company”, or correlative terms) is committed to fair and clear
disclosure of information about the Company without advantage to any particular analyst orinvestor, in compliance with all applicable securities laws and regulations, including the rules
and regulations of the Securities and Exchange Commission (“SEC”) and the stock exchanges
on which the Company’s securities are listed.
The Company and its management believe it is in the Company’s best interest to maintain anopen dialogue with our shareholders and the investment community regarding the Company’s
historical and current performance and future prospects. The Company can best createshareholder value by publicly articulating its strategies, business strengths, and growth
opportunities through an active and open dialogue, without selective disclosure to any individualor group of analysts or investors. At the same time we will continue to recognize and protect theCompany’s confidentiality in the areas of key business and operating strategies.
This policy (the “Policy”) applies to all directors, officers and other employees of the Companyand its subsidiaries.
Compliance
The Company complies with all applicable securities laws and periodic reporting rules andregulations, including those of the SEC, NYSE and ASX. It is our practice to disclose material
information about the Company publicly, not selectively, and to ensure that financial measures
can be interpreted clearly in relation to Generally Accepted Accounting Principles (“GAAP”).
Compliance Guidelines
The Company has established the following guidelines to ensure compliance with applicablelaws and regulations, including SEC regulations (such as Regulation FD) which generally
prohibits the selective disclosure of material non-public information and rules concerning thedisclosure of non-GAAP financial measures, including Regulation G.

I.

Disclosure Policy

No person subject to this policy is authorized to communicate information about the Company
that is material non-public information, except through Company-sanctioned public disclosure.
The Company recognizes that online social media (e.g., Facebook, X (formerly known asTwitter), Instagram, LinkedIn, etc.) is a significant means of communication. In addition topersonal uses, social media is also used from time to time in connection with Companybusiness activities. However, directors, officers and other employees are prohibited fromengaging in social media activities for Company-related business, except with the express
approval of an Authorized Representative (as defined below) or the General Counsel and#97137972v17

Secretary. Any approval will be subject to various conditions and parameters.
It is the Company’s policy that material non-public information will not be conveyed to the publicthrough social media but rather through the Company’s authorized means of publicdissemination.

II.

Authorized Representatives of the Companya. Persons authorized to communicate on behalf of the Company to analysts, securities
market professionals, investors, and shareholders of the Company are limited to theChief Executive Officer; the Chief Financial Officer; and employees in the Company’s
Investor Relations department (each, an “Authorized Representative”).
b. Other persons subject to this policy may communicate with analysts and investors aspart of the Company’s Investor Relations program, if an Authorized Representative will
also be present.
c. At no time will any person subject to this policy, with the exception of the designated
Investor Relations manager(s), meet with any investor, analyst, or other member of theinvestment community without another Authorized Representative being present (the“two- person” rule).
d. Except as specified under (a) and (b) above, persons subject to this policy are prohibitedfrom communicating about any matter relating to the Company’s businesses orindustries with analysts, investors, shareholders, investment professionals, orintermediaries such as “expert network services” which provide information to investors.
All questions on these matters are to be referred to the Investor Relations manager(s),or in his or her absence, another Authorized Representative.
e. Certain designated personnel (such as the functional leads of commercial, marketingand procurement and designated members of their staff) may, in the ordinary course of
their day-to-day activities for the Company, communicate about the business and related
developments with customers, suppliers and industry publications (but not with businessor investing professionals or publications). The subject matter disclosed to customers,
suppliers and industry publications must be limited to factual information concerning thebusiness of a nature that would be of interest to persons, such as customers andsuppliers, other than in their capacities as investors or potential investors. Whenengaging in any such communications you must not disclose any material non-publicinformation.
f.

III.

Appropriate training will be provided to Authorized Representatives on compliance withthis Policy, review of public statements regarding material information and proceduresfor disclosing non-public information.
Quarterly Earnings Release Conference Calls and Updatea. We will hold quarterly investor conference calls open to the public and media (in listen2#97137972v17

only mode), and provide advance public notice about the call through a media release,by electronic distribution, and posting on First Call or other similar publication service
and the Company website, www.arcadiumlithium.com. For quarterly conference calls,
information on how to access the call or webcast, the date and the time for the call,
together with the subject matter of the call, will be provided as described above, andposted on our website at least two weeks before the conference call.
b. A playback of the conference call (or webcast) along with a transcript of the call will beprovided on the Events & Presentations page of the website. These items will be clearly
identified as historical documents a short time after they are first posted and removed
from the website after 12 months.
c. The Company generally seeks to provide updates on its annual guidance relative to theCompany’s financial targets on a quarterly basis and summarize this guidance in an
Outlook Statement, which will be included in the aforementioned media release andposted on our website prior to the time of our quarterly conference call. All guidance, andchanges to or affirmations of guidance, will be provided through public disclosure, suchas media releases or conference calls or webcasts open to the public.
d. We will not undertake any duty to update or reaffirm our guidance and Outlook
Statement (except according to the aforementioned quarterly earnings release cadence),unless required by applicable law, and will disclaim any legal obligation to the contrary.

IV.

Presentations
a. We will use the safe harbor guidelines for forward-looking information as part ofindividual, group, and conference investor communications formats.
b. The Company will participate in investor conferences sponsored by financial services
firms and others. It is our practice to issue media releases in conjunction with the majorpresentations scheduled during the year, and to post those presentations on ourwebsite, arcadiumlithium.com, under the Presentations tab. These presentations will beclearly identified as historic documents 60 days after they are first posted and removed
from the website after 12 months.
c. Authorized Representatives may meet with individual investors, groups of investors, andin Company-sponsored facility tours. Similarly, we will participate in other public forums
at which analysts or investors could be present, including industry seminars, tradeshows, employee, retiree and annual shareholder meetings, and meetings withcommercial partners that are shareholders. The Company will not disclose any material
non-public information during these meetings. Similarly, if a presentation at a conferenceor other meeting with members of the investment community is not publicly accessible orpublicized, no material non-public information will be disclosed at the conference ormeeting. If any inadvertent disclosure of material non-public information concerning theCompany is made during any such conferences or meetings, it will be promptly
disclosed via media release.
d. If approved by the Company’s General Counsel and Secretary or his or her designee,
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Authorized Representatives may selectively disclose material non-public information toCompany fiduciaries, to persons who have signed confidentiality agreements, or toprospective investors in a registered public offering, in compliance with Regulation FD.

V.

Financial Measure Reconciliations

In accordance with the SEC’s Regulation G and other applicable SEC rules, we will define all
non-GAAP financial measures that we use in our quarterly earnings and guidance releases,
conference calls and presentations clearly in such releases and presentations or, in the case ofconference calls or other verbal communications of non-GAAP financial measures, on ourwebsite, arcadiumlithium.com, on the Investor Relations home page. In addition, all suchearnings releases, presentations and web postings will include reconciliations of any such nonGAAP financial measures to their most directly comparable GAAP measure. Any suchreconciliations will be posted to our website prior to or at the time of the disclosure.

VI.

Ongoing Interaction with Investors

At times Authorized Representatives may answer questions during telephone calls and inperson meetings with shareholders and the financial community. When we do answer suchqueries, there is no obligation to forward the information to others who have not specificallyasked for it. When answering such queries, Authorized Representatives must not disclose any
material non-public information. If any inadvertent disclosure of material non-public information
concerning the Company is made during any such calls or meetings, it will be promptlydisclosed via media release.

VII.

Analyst Models and Reports

Authorized Representatives will provide feedback on draft analyst reports or models only as toaccuracy with regards to publicly disclosed facts.

VIII.

Leaks or Rumors

The Company does not comment on leaks or rumors.

IX.

Quiet Period

The Company will observe a formal “quiet period,” during which it will be the Company’s generalpolicy that the Company does not comment on the financial outlook for the Company. The“quiet period” begins at the close of business on the last day of the quarter and is observed until
the public earnings release for that quarter. During this time the Company will not participate inany meetings with investors, although Investor Relations can be made available to answer orclarify fact-based questions with historical information that has been previously disclosed by theCompany and access to the Company’s senior executives will generally be prohibited.
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X.

Dissemination of Information under Regulation FD

Our policy is to ensure that all of our media releases and conference calls meet therequirements of Regulation FD for broad, non-exclusive dissemination of material non-public
information. The aforementioned media releases (including our quarterly earnings releases) willbe (1) filed with or furnished to the SEC on a Current Report on Form 8-K (or anotherappropriate public filing, such as an annual report on Form 10-K or a quarterly report on Form10-Q) and/or (2) sent through an electronically distributed media release and posting on First
Call or other similar publication service.
Any media releases that are intended to notify the public of upcoming presentations orconference calls must include details about how to access the presentation or call (i.e., throughwebcast or a toll-free telephone number) and should generally be distributed at least one weekprior to the relevant presentation or call.
Further information
All inquiries regarding the provisions or procedures of this Policy should be addressed to:Daniel Rosen
Designated Investor Relations Associate Director
Sara Ponessa
General Counsel and Secretary5#97137972v17