A commitment from our

SUPPLIER Code of Conduct

global team...

www.thor.com

OUR WORLDWIDE CODE OF CONDUCT NETWORKUKFranceSpainUSA

GermanyItaly
Japan
China

MexicoMalaysiaBrazilSouth Africa
Australia

TABLE OF CONTENTS
Introduction

04

Environmental & Safety05

Social06

Governance

07

Whistleblower System

08

www.thor.com

Introduction...
Thor is a multinational manufacturer and distributor of biocides, disinfectant products, flame retardants, personal careingredients and other speciality chemicals.
As an organisation, we are committed to the highest standards ofcorporate social responsibility, ethical principles and sustainability ineverything we do.
Our objective is to contribute to the advancement of a sustainable
society. In pursuit of this objective, we place great emphasis on forging
resilient partnerships and fostering long lasting collaboration with oursuppliers and contractors.
We expect everyone that we work with to have a shared commitment
to upholding consistent standards of corporate responsibility, thereby
ensuring compliance across our supply chain.
Our Supplier Code of Conduct is our expectation of how our supply
chain joins us in our pursuit of a global sustainable society. It is ourexpectation of the requirements to partner with us to supply goods orservices to Thor anywhere in the world.

“I’m proud to say that I’mpart of the Thor family andI understand and uphold
our Codes.”
GIUSEPPE DE LUCIA
Main Board Director

04

Our values...
TRUST
We work as a team
We earn trust from our employee family, customers and business
partners with our competency, integrity and ability to succeed.
HONESTY
We deliver on our promises
We always operate honestly and ethically in everything we doand with everyone with whom we connect.
OPTIMISM
We believe in our future
We see opportunity where others see problems and we use
these opportunities in our quest for success.
RESPECTWe treat everyone with dignity and respect
We believe that everyone should enjoy an environment freefrom discrimination and harassment.

Environmental & Safety...
All suppliers are expected to:• Comply with all applicable laws and regulations relating to the environment andhealth and safety, ensuring that all necessary operating permits and permissions
are in place and maintained.
• Ensure processes are in place to maintain the correct management of waste,emissions and discharges.
• Utilise resources efficiently, adopting energy-efficient and environmentally friendly
technologies and reducing waste and emissions to air, water and soil.
• Implement management systems to ensure that products meet applicable quality
and safety requirements.

• Safeguard the health and safety of employees, neighbours and the general public
by addressing hazards associated with processes and products.
• Ensure the correct storage, use and transportation of all hazardous chemicals
related to the organisation.
• Implement procedures that address and handle potential emergency scenarios,
aiming to minimise their repercussions on individuals, assets, communities,
customers and the environment.

ENVIRONMENTAL

AWARENESS AT ALL TIMES

05

Social...
All suppliers are expected to:• Guarantee the safeguarding of globally recognised humanrights within their activities and for their workforce.
Refrain from engaging in any form of coerced labour,
encompassing modern slavery and human trafficking,either directly or indirectly, and abstain from employing
child labour or utilising materials originating from suchlabour.
• Conform to all relevant regulations concerning
wages and working hours, ensuring no discriminationin employee compensation.
• Treat all employees with dignity and respect,including zero-tolerance of any form of abuse or
harassment, whether it is verbal or physical innature.
• Promote diversity and inclusion within theirorganisation ensuring there is zero-tolerance ofdiscrimination including (but not limited to)discrimination related to age, disability, gender
reassignment and gender identity, national origin,sex or sexual orientation, marital or civil partnershipstatus, family status including pregnancy, maternity,
paternity or other carer status, race including ethnic origin,genetic information, religious, political or other beliefs,
full-time or part-time status or any other trait safeguarded
by relevant legislation.
• Ensure employee freedom to associate and the right tobargain collectively, to the extent permitted under applicable
local law.
• Prevent illegal eviction and unauthorised acquisition of land, forests
and water bodies.

06

SAFEGUARDING
AWARENESS AT ALL TIMESGovernance...
All suppliers are expected to:• Comply with all applicable national and international laws and standards.
• Maintain zero-tolerance relating to any form of bribery, corruption, or moneylaundering. Ensure that any payments, presents, or other engagements extended
to clients, government officials, subcontractors, or other parties acting on yourbehalf adhere to the stipulations set forth in relevant anti-bribery regulations.
Thor upholds the principle that Thor employees neither offer nor accept gifts
or favours that might compromise or cast suspicion upon the impartiality of
their decisions.
• Maintain compliance with all national and international regulations relating toapplicable competition laws, regardless of jurisdiction, ensuring that there is noengagement in price fixing, bid rigging, market collusion or other anti-competitivepractices.
• Ensure adherence to relevant non-proliferation, export control, sanctions, andembargo regulations.
• Ensure that there are no conflicts of interest in business relationships withThor.
• In accordance with all national and international regulations and contractualagreements with Thor, ensure that confidentiality concerning all confidential
and commercially sensitive information shared with/by Thor is maintained.
At all times ensure the safeguarding of personal information received fromThor, as well as Thor’s intellectual property rights, through appropriate andsufficient measures.
• Implement suitable policies, management systems, and allocate resources toensure the responsible management of all their operations, in accordancewith relevant legal obligations and the standards detailed in this Supplier Codeof Conduct.

• Implement suitable health, safety, and environmental (HSE) risk management
procedures that identify hazards at site/locations and effectively manage all related
health, safety, and environmental risks to an acceptable level.
• Institute training initiatives to enable their managers and employees to attain asuitable level of knowledge and comprehension regarding the provisions outlinedin this Supplier Code of Conduct, in addition to applicable laws, regulations
and acknowledged standards.

COMPLIANCE

AWARENESS AT ALL TIMES

07

Whistleblower System...
All suppliers are expected to facilitate a mechanism fortheir employees and other stakeholders to raise
concerns or report potential unlawful activities within
their workplace.

Thor’s whistleblowing system, SpeakUP, allows for confidential reportingof issues related to illegal or improper conduct.

If you see or suspect any conduct or business practices that are contrary to our Supplier Code of Conduct, you should report your concern using thefollowing web address: https://secure.ethicspoint.eu/domain/media/en/gui/106916/index.html
08

10/2023

OUR VALUES
TRUST

We work as a team

HONESTY

We deliver on our promises

OPTIMISM

We believe in our futureRESPECT

We treat everyone with dignity and respect

www.thor.com