Employee guidelines

A Group-wide standard provides clear guidance regarding incentives.

Our employees are prohibited, either directly or in connection with their professional duties, from offering personal advantages to the employees of other companies – in particular when

• initiating,
• awarding or
• handling an order or assignment.

Our employees are likewise prohibited from accepting such advantages or requesting them for themselves. If an employee is offered such gifts, they must immediately notify their supervisor or the compliance organization.

Exceptions: may be made for occasional, low-value gifts (e.g. promotional gifts).

Transparency with the public

LANXESS must not grant advantages of any kind to public servants or other officials in Germany or abroad. When commissioning service providers who have contact with officials on behalf of LANXESS, employees must likewise ensure compliance with the prohibition on corruption.

It is one of LANXESS’s basic principles not to support any political parties or groups. LANXESS is involved in large industrial associations, which we regard as fundamental to representing our interests. We disclose contributions and spending on political activities transparently. Donations require approval from the Corporate Communications central function – depending on the value – or from the Chairman of the Board of Management of LANXESS AG, in both cases after prior consultation with the compliance organization.

Prevention and training

To enhance our employees’ awareness of these rules of conduct, the issue of corruption is regularly covered by compliance training. In addition, we hold specific anti-corruption training aimed at exposed professional groups and countries. If there are indications of compliance violations, our employees and external third parties can contact the compliance organization – anonymously if they wish.

Monitoring and audits

The Corporate Audit function examines the implementation of and adherence to our compliance principles in the LANXESS Group. This also includes reviewing the measures to prevent corruption. The annual audit planning, which covers all business units, follows a risk-based approach, which also considers the exposure to corruption. Verified cases of fraudulent behavior on the part of LANXESS employees lead to appropriate disciplinary actions up to and including dismissal as well as consideration of further legal steps.

Expectation for business partners

We also communicate our clear expectations for the prevention of corruption to our suppliers and service providers in our Business Partner Code of Conduct. It makes the clear demand that our suppliers must not engage in

• bribery,
• fraud or
• extortion.

It is essential for us that they acknowledge the principles contained in the Business Partner Code of Conduct or have established their own comparable standards. If suppliers or service providers do not comply with these principles, this may lead to the termination of the contractual relationship.

To avoid conflicts of interest, all employees must separate their personal interests from those of the company. Our Code of Conduct clearly requires employees to disclose potential conflicts of interest, for example as a result of secondary employment or personal business relationships that could conflict with the interests of LANXESS. There were no verified conflicts of interest in the reporting year. We will not tolerate verified misconduct and it will result in appropriate disciplinary measures up to and including dismissal.

Financial regulations

LANXESS complies with all applicable anti-money laundering and terrorist financing laws and regulations. We do not do business with partners that are subject to relevant sanctions, that engage in illegal business activities or whose funds are derived from illegitimate sources. To ensure this, LANXESS describes the requirements placed on our business partners in the Business Partner Code of Conduct and has established a Group-wide trade compliance management system.