Corporate Governance

Solenis is committed to profitably growing our business based solely on the merits of our portfolio of offerings and the capabilities of our team. We comply with anti-bribery and anti-corruption laws applicable where we operate, including, but not limited to, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. Solenis employees and third-party representatives are strictly prohibited from the payment of bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector. Yearly certification is conducted to ensure employee compliance and we keep books, records and accounts that accurately and fairly reflect in reasonable detail our foreign and domestic transactions.

Solenis does not tolerate unwelcome conduct, whether verbal, nonverbal or physical, that is based on a person’s age, disability, gender, genetic characteristic, national origin, race, color, religion, sexual orientation, veteran status or other protected group status. This includes unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal or physical conduct of a sexual nature. We do not tolerate harassment of our employees by co-workers, supervisors or anyone they encounter while conducting business.

We are committed to full compliance with U.S. and European Union antitrust and competition laws, and similar laws of the other countries where we do business. Employees must learn the legal requirements of the jurisdiction where they work by seeking the advice of our Legal department and/or from other policies and training materials. Our representatives may not engage in price-fixing, bid-rigging, market or customer allocation or any other activity that violates applicable laws.

The Solenis digital security program assures that we have the correct information structure to protect our operations and the reliability and confidentiality of business and individual data. This includes employing the latest technologies, understanding and identifying potential vulnerabilities and educating our employees and third-party partners as to their roles and responsibilities.

Our process allows us to consider data privacy risks from the outset of a project, build in privacy controls and apply the principles of privacy by design and default. Data processing projects are designed with privacy compliance in mind and the most private options are selected by default. The process continues throughout the development and implementation of a project.

Each Solenis employee has the responsibility to report or share in good faith any concerns about actual or suspected violations of our Global Standards of Business Conduct, policies and procedures or any laws or regulations governing our operations. We encourage employees to use our hotline, Share Your Concern, a global internet and telephone information and reporting service, to make a confidential report. All are investigated and no adverse actions can be taken against any employee who acts in good faith. Share Your Concern is available 24 hours a day, seven days a week and a translation service is available for callers who do not speak English.

Solenis has zero tolerance for any threatened or actual workplace violence, whether onsite at our facilities or anywhere that an employee is conducting our business. This includes conduct that is threatening, intimidating, abusive, harassing, or otherwise violent whether verbal, non-verbal, physical or written. Employees who know or suspect a transaction or relationship may be in violation of this policy must report such concern immediately.