Disclosure 412-1 Operations that have been subject to human rights reviews or impact assessments

Clariant monitors and manages human rights impacts, both in its own operations and in supply chains, and works to make sure that there is no contribution, knowingly or unknowingly, to any adverse human rights impacts. Therefore, we have assessed all of our operations globally in our human-rights due-diligence review.

For details on Clariant’s commitments, the process and findings, please see: the Human Rights Management Approach and our Human Rights webpage.

Furthermore, we have established our »Clariant Integrity Line« to enable people to bring to our attention any concerns they may have. The Integrity Line is a channel through which all violations against the Code of Conduct can be reported, including discrimination or violations of human rights.

Disclosure 412-2 Employee training on human rights policies or procedures

Sustainable success can only be achieved if all employees behave in a lawful and ethical manner. Since 2007, the Clariant Code of Conduct has defined a set of rules and principles that are binding for all employees to protect the company’s reputation and keep risks to shareholders to an absolute minimum. The code demands adherence to all applicable laws and other regulations. The code forbids involvement of employees that could lead to conflicts of interest; it regulates how to deal with gifts and invitations as well as donations and sponsorships; it forbids bribery and corruption, money laundering, so-called insider trading, violations against anti-trust laws, violations against embargo and trade control regulations, disclosure of confidential information, embezzlement, the misappropriation of corporate assets, as well as violations of data privacy. Employees may not endanger the environment or discriminate against or harass colleagues through their behavior.

All employees receive the Code of Conduct when they are hired and must agree to it when signing their contract of employment. So-called e-learnings are mandatory for all employees. Participation in these trainings, which cover different topics or themes of the Code of Conduct, is registered, and defaulters will be sanctioned. The code is available in all relevant national languages.

Disclosure 412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening

All investments with a total volume of more than CHF 1 million must be approved by the Investment Subcommittee of the Executive Committee (EC). The subcommittee makes its decision based on financial, strategic, and sustainability criteria, the latter of which also includes human rights aspects.