Human Rights Policy

We believe everyone deserves to be treated with fairness, respect and dignity. At Whitehall Specialties, Inc. (the Company), we strive to go about our business in a responsible way, respecting the human rights of our workers, customers, partners and communities. Our human rights policy and code of conduct help assist us in doing the right things in our relationships with our employees, individuals performing services for us, contractors, and suppliers that are in accordance with the United Nations Guiding Principles on Business and Human Rights.

The Company also expects the organizations we do business with to uphold these principles and urges them to adopt similar policies within their own businesses.

The Human Rights Policy is overseen by The Whitehall Specialties Chief Executive Officer and the Company Leadership Team.

Community and Stakeholder Engagement

We are a proud part of the communities in which we operate. We engage with people in those communities. Our aim is to ensure through dialogue that we are listening to, learning from and considering their views as we conduct our business. We believe that local issues are most appropriately addressed at the local level.

Where appropriate, we engage with stakeholders on human rights issues related to our business. This includes any concern whether in our Company, across our value chain or with our various engagements, through which we seek to promote respect for human rights.

Key Issues

We are committed to respecting U.S. and internationally recognized human rights. Our policies and ongoing procedures cover the breadth of these rights, principles, and related issues. Our approach to human rights is largely based upon understanding how our products, business activities and operations may impact our stakeholders, including employees, others performing services for us, customers, contractors, and communities.

Diversity and Inclusion

We value diversity and are committed to equal opportunity. We are intolerant of discrimination and harassment and work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national origin, ethnicity, religion, age, disability, sexual orientation or any other status protected by applicable law. The basis for recruitment, hiring, placement, development, training, compensation, and advancement at the Company includes non-discriminatory factors such as the qualifications, performance, skills and experience of those involved.

We do not tolerate disrespectful or inappropriate behavior, unfair treatment, or retaliation of any kind. Harassment is not tolerated in the workplace or in any work-related circumstance outside the workplace.

Freedom of Association

We respect our employees’ right to join or not join a labor union without fear of reprisal, intimidation, or harassment.

Safe and Healthy Workplace

The safety and health of our employees is essential. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. When a safety or health risk is identified, it is addressed and remediated.

Workplace Respect

We are committed to maintaining a workplace that is free from violence, harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats.

Forced Labor and Human Trafficking

We prohibit the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery and any form of human trafficking. We prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required.

Work Hours, Wages and Benefits

We strive to compensate employees competitively relative to the industry and local labor market. We work to ensure full compliance with applicable wage, work hours, overtime, and benefits laws.

Land Rights and Water Resources

We recognize the significant implications regarding respect for human rights that land use and water use across our supply chain may have. While we do not typically purchase ingredients directly from farms, we are compelled, based on our values as a buyer of agricultural commodities, to influence the protection of land rights of local farmers and communities whenever reasonably possible.

Guidance and Reporting

We strive to create workplaces in which open and honest communications with all employees are valued and respected. The Company is committed to comply with applicable labor and employment laws wherever we operate and ensures employees are aware of the Human Rights Policy through training and an annual certification process. Any employee who believes a conflict arises between the language of the policy and the laws, customs and practices of the place where he or she works, or who has questions about this policy or would like to confidentially report a potential violation of this policy, should raise those questions and concerns with local management or Human Resources.

Employees can also report suspected policy violations. No reprisal or retaliatory action will be taken against any employee for raising concerns under this policy. The Company will investigate, address and respond to the concerns of employees and will take appropriate corrective action in response to any violation.

The Human Rights Policy is aligned with the Company’s Code of Conduct.

This policy, including translations and related information, can be found via the Company’s internet site: www.whitehall-specialties.com

The Company reserves the right to amend this policy at any time. Nothing in this policy should be construed as or implying that a contract exists between the Company and its employees or construed as a guarantee of continued employment with Whitehall Specialties, Inc.