CODE OF CONDUCT2TABLE OF CONTENTSFOREWORD 4

HOW TO MAKE THE RIGHT DECISIONS? 5

1. RESPONSIBILITIES OF K ANSAI HELIOS 6

1.1. One Code for all
1.2. A culture of open and honest communication
1.3. Protection of personal data
1.4. Performance and development
1.5. Human rights and labour practices
1.6. Forced and child labour
2. RESPONSIBILITIES OF EMPLOYEES 

82.1. Inside (non-public) information
2.2. IT code of conduct
2.3. Protection of company property and the property of business partners
2.4. Acting in accordance with the labour law and employment contract
2.5. Complying with the antitrust law
3. PROTECTION OF THE ENVIRONMENT, HEALTH AND SAFET Y 11

3.1. Protection of the environment
3.2. Health and safety
4. THRUSTWORTHY BUSINESS PARTNER 12

4.1. Stance against corruption
4.2. Gifts, hospitality, and other benefits to a reasonable extent
4.3. Contributing to the society
4.4. Avoiding conflicts of interest
4.5. Prohibition of money laundering
5. RAISING CONCERNS 14

5.1. Timely notification of concerns
5.2. Non-retaliation

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Dietmar Jost

Mitsuru Masunaga

Bastian Krauss

Yoshihiro Tanaka

FOREWORDBY K ANSAI HELIOS GROUP MANAGEMENT BOARD

At KANSAI HELIOS, we are mindful of ourresponsibility to design excellence and to makean impact as a trusted business partner – for ourEmployees, our customers, and societies where
we operate. Serving a global customer base withmanufacturing, distribution, and sales activities
worldwide, compliance and integrity represent
inseparable parts of our sustainable development.
We are committed to comply with the laws andregulations, implement honest and fair corporate
governance practices and to strengthen integrity
across all business processes.

our constants are. Knowing, understanding,and living by the Code is an essential part of
who we are, and what we stand for at KANSAIHELIOS. The Code defines basic requirements
and fundamental standards for our business
relationships towards our stakeholders and theenvironment.

In today’s challenging business environment,
we need to be faster, more flexible and more
open-minded than ever before. In spite ofchanges becoming a part of our daily business,
we must still equally understand and know whatThe Code also embodies our shared values andlays the foundation for the success of KANSAIHELIOS. We encourage all KANSAI HELIOSGroup Employees to read the Code carefully
and to refer to it whenever necessary. The Codeoffers a relevant guidance as the reputation ofthe company and its excellence lies in the handsof every single person when it comes to making
the right decisions. Each of us should follow thisCode, both in letter and in spirit.

Dietmar Jost,President, Executive Director

Mitsuru Masunaga,
Executive Vice President, Executive Director

Bastian Krauss,
Executive Vice President, Executive Director

Yoshihiro Tanaka,
Executive Director

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HOW TO MAKE THE
RIGHT DECISIONS?
The Code puts into words the actions andattitudes that guide us. Embracing variety oflaws, political systems and cultures where
KANSAI HELIOS Group companies operatein, we may come across situations where thecourses of actions are not obvious.

Please ask yourselves these questions if
you are ever unsure about what action totake.

YOUR INTEGRITY IS IN THE RIGHT CIRCLES,IF YOU CAN ANSWER „YES“ TO THE FOLLOWING.
Complies with laws andregulations?
Complies with KANSAIHELIOS standards, policies
and rules?

Does it reflect KANSAIHELIOS Values?
Would it be perceived honest
and fair from the perspectiveof others?

Is it consistent with the
KANSAI HELIOS Code ofConduct?
Would it be all right if itappeared in a news headline?
Does it meet expectations of
KANSAI HELIOS stakeholders?
Will it reflect well on me and
KANSAI HELIOS stakeholders(Employees, customers,partners, regulators, public)?

BE AWARE
Please make sure that you understand thestandards of the Code of Conduct as well as therespective laws and corporate guidelines. If you arefacing a situation that gives you any doubt as tohow to act consistent with this Code of Conduct,
please contact your manager or write an email toKANSAI HELIOS Group Compliance department,compliance@kansai-helios.eu.

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1.
RESPONSIBILITIESOF KANSAI HELIOS
1.1.
ONE CODE FOR ALL

1.3.
PROTECTION OF PERSONAL DATAThis Code of Conduct is binding for all
Employees of KANSAI HELIOS worldwide.
Each manager and employee (collectivelyreferred to as Employees in this Code) have apersonal responsibility to be aware of the Codeof Conduct and to comply with it.

All personal data collected and held by KANSAIHELIOS will be processed fairly, transparently,
carefully and in compliance with the locallyapplicable data protection laws and agreements.
Access to personnel records is restricted toKANSAI HELIOS Group Employees who haveappropriate authorization and a business needfor that information.

Our Code of Conduct is based on the Ten
Principles of the United Nations Global
Compact (www.unglobalcompact.org/what-isgc/mission/principles) and it is setting the stage
for long-term success.
1.2.
A CULTURE OF OPEN AND HONESTCOMMUNICATIONAt KANSAI HELIOS, everyone should feel
comfortable to speak their own mind, particularly
with respect to ethical concerns. Openness,
integrity and reliability foster open two-way
communication between Employees andbetween the Employee and the superior on all
aspects of the working environment.
All Employees are encouraged to discuss
through the employee’s line management chain.

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1.4.
PERFORMANCE AND DEVELOPMENT

At KANSAI HELIOS we encourage an ongoing
dialogue on performance and developmentwith Employees. It is the responsibility of all
Employees to develop in their professional
career.
1.5.
HUMAN RIGHTS AND L ABOUR PRACTICESKANSAI HELIOS is committed to an attractive
working environment. Our Employees must
be recruited, selected and promoted basedon objective and non-discriminatory criteria.
We respect individuality in terms of nationality,gender, race, skin colour, political or religious
beliefs, social or ethnic background, age, healthstatus or disability, and sexual orientation.
We advance corporate culture based on thediversity and inclusion and perceive it asa source of sustainable development andinnovation.

KANSAI HELIOS supports and respects theprotection of internationally proclaimed humanrights and ensures that Employees are notcomplicit in human rights abuse. Businesses
should uphold the freedom of associationand the effective recognition of the right tocollective bargaining. We believe in the fairtreatment of Employees free from sexual
harassment, corporal punishment or torture,
mental abuse, forced and compulsory labour.
At KANSAI HELIOS we do not tolerateharassment of any kind, including verbal or
physical abuse. All KANSAI HELIOS GroupEmployees are expected to treat each otherwith courtesy, dignity and respect. Employees
are encouraged to acknowledge others’
differences and leverage diversity in order toachieve a sustainable competitive advantage.
We respect the personal rights of everyone.
1.6.
FORCED AND CHILD L ABOURKANSAI HELIOS will only employ individuals
who are working of their own free will andhave reached the minimum age according tothe International Labour Organization (ILO)
Convention, the conventions of the United
Nations and national laws.

72.
RESPONSIBILITIESOF EMPLOYEES
2.1.
INSIDE (NON-PUBLIC) INFORMATIONKANSAI HELIOS Group Employees may becomeaware of information about KANSAI HELIOS andother companies that has not been made public.
The use of such non-public or inside information,other than in the normal performance of one’s
work, profession or position, is unethical andmay be a violation of the law and relevant
confidentiality obligations. A violation may resultin civil and criminal penalties, prosecution andother sanctions. At KANSAI HELIOS we do nottolerate the improper use of inside information,
regardless of whether it is unlawful or not.
2.2.
IT CODE OF CONDUCT

Disclosure or dissemination of confidential
or proprietary information regarding KANSAIHELIOS, its products, or its customers outside
the official communication structures isstrictly prohibited. All IT-related resources andfacilities are provided only for internal use andfor business related matters. They cannot beused for personal use. It should not be usedin any way that is unethical or illegal, or thatit could embarrass, defame, mispresent, orconvey an unjust or unfavourable impressionof KANSAI HELIOS or its business affairs,Employees, suppliers, customers, competitors orstakeholders.
Any device with access to the information systemshould be secured by personal passwords
and/or additional authentication. Users must

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apply them in a responsible way, keeping them
private and securing them against misuse. It isnecessary to operate in accordance with theapplicable Information Security Policy and IT
organizational rules of KANSAI HELIOS.
2.3.
PROTECTION OF COMPANY PROPERT Y
AND THE PROPERT Y OF BUSINESSPARTNERS

We are all required to handle company property
with care and in a responsible manner and toprotect KANSAI HELIOS assets and those of ourbusiness partners against loss, damage, theft,
abuse and unauthorized use. Company property
also includes intellectual property, internal
knowledge, patents, trademarks, copyrighted
material and trade secrets.
2.4.
ACTING IN ACCORDANCE WITH THE
L ABOUR L AW AND EMPLOYMENTCONTRACTKANSAI HELIOS policy is to comply with theapplicable labour and social security laws andall other applicable laws and regulations that arevalid in the countries in which we are present.
Additionally, every individual employmentrelationship is regulated by the respective
employment contract, which defines the specificrights, obligations, responsibilities, wages andbenefits of each Employee. Such an employment
contract must be in full compliance with theapplicable regulations.

2.5.
COMPLYING WITH THE ANTITRUST L AWKANSAI HELIOS is fully committed to comply withthe antitrust law regime in the countries where weoperate in. In following this principle, we are driven
by the need to be both efficient and innovative.
None of our Employees should engage in any
form of communication (written, electronic orverbal) with a competitor that attempts to:• agree, fix, stabilise or control prices, credit
terms, discounts or rebates (or other pricecomponents);• share sensitive business information;• allocate contracts, customers or territories;• boycott certain customers, competitors orsuppliers; or• limit output or sale of any product or service.

Equally, we do not unduly restrict our suppliers or
customers, including distributors and agents,
in their business dealings.
Finally, Employees must ensure that they do notuse commercial strategies that may abusea dominant market position of or exploit abusiness partner’s dependence on KANSAIHELIOS.

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3.
PROTECTION OF
THE ENVIRONMENT,HEALTH AND SAFETY
3.1.
PROTECTION OF THE ENVIRONMENT

3.2.
HEALTH AND SAFET Y

As a chemical company, we have a higheconomical, ecological and social responsibility
and we encourage the development and diffusionof environmentally friendly technologies.
We are all required to deal in a precautionary
and responsible manner with natural resources
and to protect the environment in our work area.
We act responsibly to protect and preserve ourEmployees’, neighbours’, and business partners’
health. We are all able to eliminate or minimize therisk of accidents or occupational diseases.

KANSAI HELIOS provides safe and healthy
working conditions to prevent harm. We organize
special health and safety programs and trainings,
and each Employee is responsible for complying
with health and safety regulations.
KANSAI HELIOS is a drug-free work environment.
Employees must not use, possess, or be under
the influence of alcohol or illegal drugs. This
also includes reporting to work while under theinfluence of alcohol or other illegal drugs.

The goal is to initiate the appropriate emergency
response and damage repair measures aspromptly and as precisely as possible.
Not only but also for this reason, KANSAIHELIOS supports activities in the communities
where our Employees live and work.

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4.
THRUSTWORTHY
BUSINESS PARTNER
4.1.
STANCE AGAINST CORRUPTIONKANSAI HELIOS must comply with all laws, rules
and regulations intended to prevent corruption
and extortion in all countries where we dobusiness by prohibiting corruption and by keeping
proper financial records. It is prohibited to pay,offer or accept bribes to gain any commercial
advantage or personal benefit. All details areclearly defined in KANSAI HELIOS
Anti-Corruption and Gifts Policy.
4.2.
GIFTS, HOSPITALIT Y, AND OTHER
BENEFITS TO A REASONABLE EXTENT

Exchange of gifts and entertainment can build
goodwill in business, but sometimes can create
improper influence and some may be seen asbribes that break the law and damage KANSAIHELIOS reputation for fair dealing. The followingtypes of gifts and entertainment are prohibited:
Any gift or entertainment that would be illegal(anything offered to a government official inbreach of local and international anti-corruption
laws, any facilitation payment whether by cash,
cash equivalents or by any other means);• Any gift of cash or cash equivalent (such as gift
certificates, loans, stock, stock options);•12

Any entertainment that is indecent, sexuallyorientated, does not comply with KANSAIHELIOS commitment to mutual respect orthat otherwise might adversely affect KANSAIHELIOS reputation;• Any gift or entertainment that any person
acting on behalf of the Group pays for
personally to avoid having to report or seekapproval.
•For further guidance on the rules for refusing,receiving and disclosing offers of gifts andentertainment please refer to KANSAI HELIOS
Anti-Corruption and Gifts Policy.
4.3.
CONTRIBUTING TO THE SOCIET Y

In pursuit of corporate goals, KANSAI HELIOS
may offer donations and sponsorships, that aresupporting the advancement and promotionof companies’ key societal commitments andother legitimate objectives. Employees must beaware that sponsorships and donations mustnever be made to procure improper advantage
or to contribute (directly or indirectly) to politicalparties, organisations or individual politicians.
All details are clearly explained in KANSAIHELIOS Anti-Corruption and Gifts Policy.

4.4.
AVOIDING CONFLICTS OF INTEREST

4.5.
PROHIBITION OF MONEY L AUNDERINGKANSAI HELIOS Employees must act in the bestinterest of the company and avoid any conflicts ofinterest. Such conflict arises when an Employee’s
interests and the interests of KANSAI HELIOS are
not the same, even if the decision or outcomeappears to be mutually beneficial. KANSAIHELIOS will take steps that even the appearanceof a conflict of interest is avoided, as already suchappearance might create negative reputation.
All details are set out in the KANSAI HELIOS
Anti-Corruption and Gifts Policy.

Money laundering can be defined as transforming
the proceeds of crime into the legitimate
economy. KANSAI HELIOS objects to all formsof money laundering. We will therefore take allnecessary steps to prevent transactions frombeing used by others to launder money. Before
entering into an agreement with a business
partner we will do our utmost to safeguard thatthe customer is genuine and conducts businessin a law-abiding manner. All details are clearly
defined in KANSAI HELIOS Anti-money
laundering policy.

135.
RAISING CONCERNS
5.1.
TIMELY NOTIFICATION OF CONCERNSKANSAI HELIOS encourages any Employee toraise their concerns as promptly as possible ifthey become aware of a situation or matter which
they reasonably believe might show any of themalpractices in one of the following areas:• misconduct in connection with corruption(including conflicts of interest), money
laundering, antitrust law, and export controls,• danger to the health and safety of any
individual,• data protection and information security
including general IT user policy.
Timely notification is required to ensure thatnecessary measures are taken to avoid
or minimise the potential of any negative
consequences to KANSAI HELIOS, including

its reputation, and to remedy the situation in
the best interest of KANSAI HELIOS and its
Employees. Speaking up will also help KANSAIHELIOS to improve its compliance efforts. Where
appropriate, complaints may be made on aconfidential basis or through our reporting line.
5.2.
NON-RETALIATIONKANSAI HELIOS will protect each Employeethat decides to speak up in good faith. This
includes a clear non-retaliation policy. In turn,anyone who misuses KANSAI HELIOS’s channels
to maliciously denigrate a colleague will facedisciplinary consequences.
All details are clearly defined in KANSAI HELIOS
Speak up Policy.

About the KANSAI HELIOS Code of Conduct:
Version 2.2, September 2023
KANSAI HELIOS Code of Conduct is in effect as of February 15, 2022.
Version of the Code, initially published on April 1, 2019, is no longer valid.
You can always find the most current Code of Conduct on the companies‘ intranet
and on the KANSAI HELIOS’s corporate website.
Responsible: KANSAI HELIOS Group Compliance Department (compliance@kansai-helios.eu)
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www.kansai-helios.eu

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