Unifrax Business Conduct and Code of Business Ethics.

Unifrax purpose.

Unifrax is a global leader in high-performance speciality products used in many industries in diverse applications. Our purpose is to help customers save energy, reduce pollution and improve fire safety.

Unifrax values.

• Workplace and product safety – our number one priority
• Ethics – we always do things the right way. No compromises.
• People – we value and respect every employee and strive to help them achieve their professional goals.
• Meet our commitments – we deliver on our promises to employees, customers and our investors. We set challenging goals and overcome obstacles to achieve results.
• Customer focus – we value long-term relationships and put the customer’s perspective at the centre of our discussions and decisions.
• Innovation – we develop new and improved products that create value for our customers
• Continuous improvement – we continually focus on reducing cost and complexity.
• Teamwork – we collaborate globally to maximise results.
• Speed and agility – we quickly respond to opportunities and challenges.

Unifrax business conduct and ethics.

Unifrax is committed to upholding the highest standards of ethical behaviour in all aspects of our business. We have made operating with integrity a cornerstone of our vision and values. For Unifrax employees, ethical behaviour cannot be an “optional extra”; it must always be an integral part of the way we do business. In essence it is a matter of spirit and intent. It is characterised by the qualities of truthfulness and freedom from deception and fraud. Employees and representatives of Unifrax must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Unifrax Whistleblower Policy/Integrity Hotline.

Unifrax has an Integrity Hotline where employees are encouraged to report anonymously any unethical or illegal conduct observed on the job. All employees are made aware of our anonymous Integrity Hotline, our ethics policies and code of business conduct. These policies are reviewed annually at all Unifrax facilities.

Examples of issues which may be reported through the Whistle-blower Process include:

• Illegal activities on company premises
• Violation of environmental laws and regulations
• Use of illegal drugs in the workplace
• Alteration of company records and intentional misstatement of financial reports
• Acts of fraud
• Theft of company property
• Safety violations or unsafe working conditions
• Sexual harassment or other acts of violence in the workplace
• Bribes, kickbacks or unauthorised payments
• Other questionable accounting or financial matters

Unifrax Non-retaliation Policy.

Unifrax prohibits retaliation against anyone who raises a business conduct concern or cooperates in a company investigation. No director, officer or employee who in good faith reports a concern shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment. This Whistle-blower Policy is intended to encourage and enable employees and others to raise serious concerns within the Company without fear of reprisal.

Unifrax Anti-bribery Principle.

Unifrax prohibits bribery. Unifrax employees and any third party, to whom this principle applies, must not provide, offer or accept bribes, kickbacks, corrupt payments, facilitation payments or inappropriate gifts, to or from government officials or any commercial person or entity, regardless of local practices or customs. All Unifrax employees and any third party acting on Unifrax’s behalf must comply with all applicable anti-bribery laws and regulations, including, but not limited to, the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA).

Unifrax Anti-trust and Competition Principle.

Unifrax is committed to engaging in fair and vigorous competition, in compliance with all anti-trust and competition laws and regulations globally. Antitrust issues may be encountered in the areas of pricing, boycotts and trade association activity. Certain business activities, such as agreements between competitors that fix prices, violate these laws and this principle and are not acceptable. Many other business activities, such as certain restrictive supply or distribution agreements or unfair use of a strong market position to harm competition, may violate these laws and this principle. Anti-trust and competition laws vary from country to country and are complex. Unifrax employees must consult legal counsel whenever their business activities might be regulated by these laws.

Unifrax Conflict of Interest Policy.

Employees and third parties to whom this principle applies must be free from conflicts of interest that could adversely influence their judgment, objectivity, in conducting Unifrax business activities. Employees must avoid situations where their personal interests could inappropriately influence or appear to influence, their business judgment. This is called “conflict of interest.” Even the perception that personal interests influence business judgement can hurt Unifrax’s reputation. Employees may take part in legitimate financial, business, charitable and other activities outside their Unifrax jobs with written company approval. Any real, potential or perceived conflict of interest raised by those activities must be promptly disclosed to management and updated on a periodic basis.

Unifrax Export and Import Trade Compliance Principle.

Unifrax and related entities are committed to conducting business in compliance with laws and regulations that apply to our locations throughout the world. This includes laws and regulations pertaining to trade embargoes and economic sanctions, export control, anti-boycott, cargo security, import classification and valuation, product/country of origin marking and trade agreements. As a responsible corporate citizen, it is incumbent upon Unifrax and related entities to consistently follow established guidelines to maintain integrity and lawfulness in our international transactions. When participating in international transactions, Unifrax and related entity employees must be aware of and follow local country laws and regulations. Should Unifrax practices conflict with local law, employees must always obey the law.

Unifrax Human Rights Policy.

Unifrax is committed to developing an organisational culture which implements a policy of support for the internationally recognised human rights contained within the Universal Declaration of Human Rights and seeks to avoid complicity in human rights abuses. Reference: http://www.un.org/en/documents/udhr/.

Unifrax Equal Employment Opportunity Policy.

Unifrax practises equal employment opportunity for all persons regardless of race, colour, religion or belief, sex (including pregnancy, gender identity and sexual orientation), sexuality, gender reassignment, national or ethnic origin, age, genetic information, marital status, veteran status or disability. This is a fundamental policy of Unifrax.

Unifrax Pay and Benefits Policy.

We provide our employees with fair and competitive pay and benefits. Our wages meet or exceed local market conditions and ensure an adequate standard of living for our employees and their families. Our pay systems are linked to company and individual performance.

We comply with all applicable laws and agreements on work time and paid leave. We respect the right to rest and leisure, including vacation and the right to family life, including parental leave and comparable provisions. All forms of forced and compulsory labour and child labour are strictly prohibited. Our human resource policies prevent illegal discrimination and promote fundamental rights to privacy and prevention of inhuman or degrading treatment. Our safety and health policies require safe working conditions and fair work schedules. We encourage our partners, suppliers, distributors, contractors and vendors to support these policies and we place value on working with others who share our commitment to human rights.

Unifrax encourages its employees to fully utilise their potential by offering ample training and education opportunities. We support internal training programmes and internal promotions to provide career opportunities. Access to qualification and training measures is based on the principle of equal opportunities for all employees. To the extent applicable we comply with Title VII, Civil Rights Act of 1964, all amendments, Executive Order 11246 and other applicable state and federal laws and regulations regarding equal opportunity, the UK Modern Slavery Act of 2015 and California Transparency in Supply Chains Act.

Unifrax Data Protection Policy.

Unifrax will hold and process, electronically and manually, the data it collects in relation to its subjects in compliance with applicable processes, laws and regulations.

Unifrax Sustainable Environment – Corporate Social Responsibility Policy.

Unifrax products reduce pollutants in the environment and saves energy. Our insulation products reduce fuel use, which results in a smaller carbon footprint.

We acknowledge our responsibility to the community and to protect the environment. We develop and implement practices that reduce energy consumption and waste generation. We work to minimise waste disposal through recovery, recycle and reuse practices.

The Unifrax goal is to protect the health and safety of everyone who comes into contact with our products. To ensure proper use of our products, we monitor them over their entire lifecycle. We observe all applicable laws regarding manufacture, testing, handling and application of our products.

As good environmental stewards, we conserve energy, conserve water and recycle.