Stahl Statement on Modern Slavery‘No one shall be held in slavery or servitude; slavery and theslave trade shall be prohibited in all their forms’, United Nations

It is essential for Stahl to conduct business with the highest level of integrity in all ourinteractions. In an evolving and ever challenging commercial and regulatory and complianceenvironment, we want to be prepared to adapt the way we work to ensure that we always conductbusiness in the most appropriate, ethical and transparent way. This statement sets out the steps
taken by Stahl to mitigate and eradicate the risk of Modern Slavery and human trafficking in its
supply chain. This statement is prepared as per section 54 of the UK Modern Slavery Act 2015.

What is Modern Slavery?
Modern Slavery means any form of forced labor, prison labor, indentured labor, bonded labor, debt
servitude, state imposed forced labor and human trafficking, where coercion, threats or deception
are used to intimidate, penalize or deceive workers, thereby creating situations of involuntary
work and exploitation. Modern Slavery is also associated with (the worst) forms of child labor.
Stahl’s Business and Supply Chain overview
Stahl is the world leader in high-performance coatings and leather chemicals. Stahl specializes inproviding products and services to manufacturers of leather, synthetics, textiles and othermaterials used in the automotive, garment, footwear and home furnishing consumer industries. As
a manufacturer of chemical products, Stahl considers the health and safety of its employees to be
its primary responsibility. Stahl is a role model for workplace safety, with a low accident
frequency rate. Through its continuous improvement culture, Stahl also ensures that the impact ofits activities on the surrounding ecosystems is limited.
Stahl operates 11 manufacturing sites, 38 technical service laboratory centers and 6 sales
support offices around the world, employing around 1,830 people, and around 32% of whom areengaged in technical application activities. The operations are located in 27 countries, with its
registered Head office in The Netherlands. The top ten countries*(i.e.: with the highest net sales),in alphabetical order, are Brazil, China, Germany, India, Italy, Mexico, South Korea, Spain,
Thailand and the USA.
Stahl’s standpoint and policies on Modern Slavery

Standpoint

Modern slavery, or any form of forced or compulsory labour, is a violation of human rights. Stahltakes a strong stance against any form of modern slavery. Stahl condemns modern slavery andchild labour, and shall not participate in the trafficking, recruitment, or receipt of any persons, bymeans of threat or abuse of power. Stahl allows employees to resign from their position at any
time if they are forced in such a situation. By behaving ethically and honestly with all its partners,
Stahl is committed to ensuring that modern slavery does not occur elsewhere and it strives only to
do business with organizations that uphold similar principles.

Stahl’s policies

Stahl is committed to the guiding principles of UN Global Compact, the world’s largest corporate
sustainability initiative, and reports on these principles annually. With this commitment, Stahl has
confirmed the alignment of its strategy and operations to the universal principles of human rights,
labor, environment and anti-corruption. Stahl’s activities are also aligned with the 17 SustainableDevelopment Goals (SDG’s) announced at the UN General Assembly in 2015, where desirable andrelevant.
UN Global Compact’s Ten Principles
Stahl is committed to the UN Global Compact’s Ten Principles and strives to conduct its businesswith the highest standards of integrity and ethical behavior. This means operating in ways that, ata minimum, meet fundamental responsibilities in the areas of human rights, labor, environment
and anti-corruption.
The Ten Principles are:
▪ Principle 1: Businesses should support and respect the protection of internationallyproclaimed human rights▪ Principle 2: Make sure that they are not complicit in human rights abuses▪ Principle 3: Businesses should uphold the freedom of association and the effective
recognition of the right to collective bargaining▪ Principle 4: The elimination of all forms of forced and compulsory labor▪ Principle 5: The effective abolition of child labor▪ Principle 6: The elimination of discrimination in respect of employment and occupation▪ Principle 7: Businesses should support a precautionary approach to environmental challenges▪ Principle 8: Undertake initiatives to promote greater environmental responsibility▪ Principle 9: Encourage the development and diffusion of environmentally friendly technologies▪ Principle 10: Businesses should work against corruption in all its forms, including extortionand bribery
Based on these Ten Principles, we implemented our Corporate Responsibility & Sustainability
policies, among which the Code of Conducts for employees and business partners.
a)Stahl Employee Code of Conduct
Stahl’s Employee Code of Conduct and whistleblower rules reflect these high standards ofintegrity and ethical behavior. The Code of Conduct and the whistleblower rules apply to all itsemployees. Every new employee needs to sign this Code of Conduct and whistleblower rules. Stahl
specifically mentions Modern Slavery in its Employee Code of Conduct.
To ensure a high level of understanding of the risks of modern slavery and human trafficking andto give guidance on behavior, Stahl trains all relevant employees via e-learning courses on modernslavery, anti-bribery and corruption. To date [100%] of targeted employees have been trained.
b)
Stahl Business Partner Code of Conduct
It is mandatory for business partners to sign the Stahl Business Partner Code of Conduct or, if thebusiness partner has its own Code of Conduct, to provide a copy which we check. In theunfortunate event that the business partner does not comply with the Code of Conduct, immediate
action is taken, including, if necessary, immediate discontinuation of the business relationshipwith such business partner. Stahl included specific wording on Modern Slavery in its Business
Partner Code of Conduct.
Due Diligence Processes
In order to ensure the Modern Slavery is not taking place in its business, Stahl implemented thefollowing due diligence procedure.
Business Partner Due Diligence procedure
Stahl implemented a Business Partner Due Diligence procedure for business partners. With thisBusiness Partner Due Diligence Procedure the compliance-relevant behavior and the integrity ofthe (potential) business partner of Stahl is monitored and this procedure will assist our employees
in establishing and maintaining a commercial relationship with reliable and ethical businesspartners.

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Stahl Compliance Report (Codes of Conduct)
The Stahl Code of Conduct is structurally discussed during meetings with the respective businesspartners. Such discussions are confirmed in reports and/or e-mails. The Code of Conduct is also
discussed during the Quarterly Executive Control Group meetings. Every year, the group directors,
managing directors for the regions and local managers need to complete a Code of Conduct
compliance questionnaire about the Code of Conduct with respect to employees and business
partners. We refer to the Stahl Compliance Report as published on the Stahl website.
Supplier audit protocol
In 2019 Stahl began due diligence on the Code of Conduct by auditing selected suppliers on its
implementation. The scope of this due diligence auditing of suppliers will be amplified
significantly in 2020 with the help of the Ecovadis ratings system, which is already usedthroughout much of the chemical industry supply chain. The Ecovadis assessment is a thorough
CSR assessment that covers the elements of Environment, Labour & Human Rights, Ethics andSustainable Procurement, and will amplify the understanding of the wider sustainability
performance of our supply base in addition to the Business Partner Code of Conduct and Business
Partner Due Diligence procedures.
Stahl continuously improves, develop and strengthens its efforts to promote the UN Global
Compact’s Ten Principles, including the elimination of all forms of forced and compulsory labor.
This statement constitutes the Stahl Statement on Modern Slavery for the financial year ending 31
December 2019. This statement has been approved by the Board of Directors of Stahl Parent B.V.

Huub van Beijeren
Chief Executive Officer3