At allnex, our mission revolves entirely around you, our customers: to listen to our customers and exceed your expectations; to lead in innovation, quality and reliability; and to create value in all that we do. Not only is compliance part of our core values, we have many more that dictate the way we do business on a daily basis and help our customers achieve success.

Safety 
Our first priority is safety, which involves preventing and reducing risks, minimizing the frequency and scale of incidents, and protecting our employees from injury and illness.

Compliance 
We strive to comply with all relevant regulations in each of the countries where we operate, including rules relating to safety, health and the environment (SHE). 

Diversity 
As a global company we value the diversity that exists in our workforce, which also helps to make us more flexible and innovative. 

Integrity 
Having integrity means being honest, transparent and respectful. We embrace good business practices, which include sustainability, and we expect all our employees to adhere to a code of conduct which enables them to navigate challenging situations. 

Value Creation 
Providing value to our stakeholders is our business imperative. Value includes providing quality products to our customers and returns for our investors, as well as contributing to the communities in which we operate. 

Teaming/Collaboration 
Teaming and collaboration are important for delivering continuous improvement. We use collaborative techniques within our organization, and also for engaging with upstream and downstream partners to create mutually beneficial solutions.

The fundamental principles described in the Code of Conduct apply to all allnex managers and employees, regardless of the country they work in or the job they do. This is important, because markets and ways of doing business vary and we therefore need a reliable standardized code of behaviors. Our common objective is to ensure that, every day, all activities in the company are shaped by these principles.
 

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In allnex, we are committed to the protection of our employees, customers, contractors, the environment and the communities in which we operate. We see this as an essential element of being recognized as the leading Coating Resins company. 

We believe that sustainable businesses give first priority to safety, health and environmental and security considerations. Our internal standards, objectives, performance tracking, procedures and audits are the foundation for our continuous improvement and operational excellence and are applied globally.

We are committed to safety at all levels and aim to work together to achieve the goal of “zero harm”. A positive attitude from all of us contributes to achieving the high level SHE culture to which we are committed.

We familiarize ourselves with environmental, health and safety laws, and our standards, which are applicable to our work environment. We do our job in a safe and environmentally responsible manner in compliance with all applicable environmental, safety and health laws and related corporate standards and policies.

• SHE Policy Chinese
• SHE Policy Dutch
• SHE Policy English
• SHE Policy French
• SHE Policy German
• SHE Policy Indonesian
• SHE Policy Italian
• SHE Policy Japanese
• SHE Policy Malaysian
• SHE Policy Norwegian
• SHE Policy Potuguese
• SHE Policy Russian
• SHE Policy Vietnamese

All our values are people-oriented and we aim to treat each other professionally based on fairness, respect and dignity. We encourage fair employment practices worldwide and offer equal opportunities to all our employees. 

This policy applies not only to fair and objective hiring practices, but to all aspects of the employment relationship.

We are convinced that the diversity of our workforce is an asset. Diversity means having a workforce that is reflective of different cultures, nationalities, genders, generations, ethnic groups, abilities, social backgrounds, religious beliefs, sexual orientations and all the other differences that make each of us a unique individual.

We aim to be inclusive, which means creating a work environment where everyone has the opportunity to fully participate in making our company successful. This is why we reject any form of discrimination or harassment.

We comply with all labor and employment laws and standards in the countries where we operate, including all laws pertaining to child labor, human trafficking and freedom of association.

We are committed to ensure compliance with the existing conflict minerals regulations and also ethical and responsible sourcing of minerals globally. For more information see also our Responsible Sourcing of Minerals Policy

As a company we are committed to full, accurate, timely and comprehensive reporting and disclosure of financial information. We describe all transactions accurately and ensure that the books and records are properly maintained in accordance with law and allnex policies. “Books and records” include electronic or paper format and covers all data, certifications and other written material provided for financial reporting and disclosure purposes, as well as documents collected for other recording purposes, including expense reports. 

We ensure that all books and records are fully available for audit by internal auditors and independent external auditors. Records include, but are not limited to, manufacturing and production records, marketing and business plans, sales and technical reports, contracts, supply chain documentation, IT records, accounting and tax records and travel, accommodation and other expenses records.

A conflict of interest exists when our employees’ self-interest competes with the company’s business interests – whether in reality or when an observer could reasonably perceive this to be the case. We therefore ensure that we always act in the best interest of allnex and avoid situations where our own financial, social, political or other personal interest conflicts or could conflict with the business interests of allnex.

Corruption is contrary to our values and is prohibited. Accordingly, we never offer, promise, grant or authorize, either directly or indirectly through any third party, the giving of money or anything of value to customers, suppliers or other third parties to influence decisions or obtain any outcome or improper advantage. This applies also in the reverse direction, so that no individual acting for or on behalf of allnex may accept or agree to accept anything of value with the intention of obtaining any improper advantage. 

Facilitation or “grease” payments - small payments to expedite or to secure routine government action to which one is entitled - are considered bribes and are therefore prohibited. 

Maintaining detailed and accurate books and records is crucial to our business as they guide our decision-making and are essential in terms of fulfilling our obligation to provide full and transparent disclosure to our stakeholders. Therefore, our books and records must correctly reflect all business transactions and expenditures, be complete, accurate and prepared in accordance with applicable laws as well as allnex’s own accounting and reporting policies and procedures. 

We regularly interact – directly or indirectly - with public officials all around the world. The term “public official” is broadly defined and includes, for example, employees of federal, state or municipal regulators and administrators, employees of companies owned or partially owned by public bodies, employees of international organizations, politicians, as well as political parties and their representatives. Many jurisdictions apply stricter rules where interactions with public officials are concerned such as prohibiting the giving of anything of value. Therefore, we take particular care when interacting with public officials and make sure we always comply with applicable laws and our own internal standards. 

All donation and sponsoring activities must be in line with allnex values and are made in compliance with our anti-corruption requirements. allnex never makes donations to political organizations, political parties or individual politicians. 

Offering or accepting occasional gifts, entertainment or hospitality may occur in the normal course of business. However, we never use these as a way to influence business decisions or to obtain an improper advantage from a public official or a private person. We also never allow the impression to be created that our objectivity and impartiality may be affected by our offer or acceptance of such gifts. All gifts, entertainment and hospitality must be modest, appropriate in the given context and infrequent. In case of doubt, they are to be disclosed to one’s manager or to the allnex Legal Department.

Money Laundering is a method by which money obtained or generated by unlawful activity (e.g. drug trafficking, smuggling, corruption) is camouflaged through the legal channel of finance and business in order to conceal the money’s origin. When entering into a relationship with a customer, we need to watch out for warning signals that may indicate possible money laundering violations. 

We will comply with all applicable anti-money laundering laws and act diligently to prevent allnex from being involved or used in money laundering or any other criminal activity.

We believe in the benefits and principles of competition. Free markets enable economic prosperity and contribute to social welfare, but they only work properly when the principles of fair competition are respected and observed. We compete fairly for business through the quality and price of our innovative products. We do not engage in any activities that could reasonably be construed as being anti-competitive, abusive or unfair, for example: 

• Exchange of commercial data with competitors (e.g. prices, territories, customers, production capacities, profits) 
• Allocation of markets, customers, production programs with competitors 
• Horizontal price fixing 
• Bid rigging (e.g. submitting fictional offers for bidding) 

To ensure that market participants respect these principles of fair competition, many jurisdictions have introduced laws prohibiting anti-competitive practices. We strictly obey antitrust and competition laws at all times and in all jurisdictions.

Allnex Holding GmbH and the allnex group, as one of the indirect overseas investments of PTT Public Company Limited and PTT Global Chemical (“PTTGC”),  commit to adopt and pursue a tax strategy that is aligned with that of PTTGC. 

Allnex holds strong commitment to tax compliance. As stated in our tax control framework, we take our obligations to comply with the tax laws and regulations of all the countries where we operate very seriously. We aim for this to be embodied in the mindset of all our employees including the local board of directors / local management team to underpin the way we do business with each other and with our external stakeholders. Our stakeholders include our customers, suppliers, employees, shareholders, the various governments of the countries where we operate, and the public as a whole.

The tax policies, strategy and tax control framework of Allnex are specifically formulated to reflect this mindset. Our tax policy, simply stated, is to ensure that we apply clear and transparent compliance and reporting processes directed at collecting, paying and reporting all taxes relevant to our operations in all countries where we operate in an accurate and timely manner.

For more information download this document.

Countries may impose various economic sanctions and restrictions targeting business with specific jurisdictions, entities, individuals, economic sectors or end-use commerce control. The international nature of our business means that we must comply fully with trade laws and regulations and company best practices governing the trade of goods, services and technologies in all countries where we do business directly or indirectly. This also includes compliance with regulatory requirements covering controlled substances, antidumping laws, boycott laws and regulations. 

Trade Compliance 
Many countries maintain laws and regulations that restrict trade of certain products, services and technologies to certain countries, buyers or distributors. Such restrictions must not be avoided by export or other sale to a permitted third-party that then redirects the product to a restricted party. A license may be required before trading certain of our products, services or technical data. A so-called export of technology can occur through a plant visit by an individual (foreign national or not), including another employee of allnex, through a telephone conversation or email exchange. The laws and regulations regarding commerce control are complex and change frequently. Our trade compliance professionals are readily available to provide additional guidance and assistance with all related issues. 

Antidumping Laws 
Many countries prohibit a manufacturer from another country from selling goods in that country at a price lower than the manufacturer sells the goods in its home country plus the cost of shipping, if local manufacturers are harmed by this form of unfair competition.

We entrust our employees with access to allnex’s assets so that they can effectively do their work. These assets consist of tangible items of economic value such as equipment, tools, materials, supplies, office and communications equipment as well as intangible assets such as proprietary information, customer goodwill and even the working time of our employees. We all have an obligation to protect company assets against any improper use and to safeguard them from theft, abuse and waste. 

At allnex, we gain and produce information that is vital to our business success. Intellectual assets consist of intellectual property rights, know-how and proprietary information. We protect and safeguard our confidential business information (in whatever form: paper, electronic, product sample, etc.) and we do not disclose it without a legitimate business reason. We are cautious when discussing sensitive information and only share allnex information with others if they have a genuine business need to know and, then, only under the protection of an appropriate non-disclosure agreements.

We are also committed to respecting the intellectual property rights of other parties. 

allnex is committed to respecting the privacy of its employees and its business partners. We adhere to the law and the allnex data protection policy when processing our employees’ personal information and our business partners’ data and we take appropriate measures to ensure that such data is protected and maintained securely.

If you see something that you think isn’t right, please speak up. We encourage you to report in good faith any known or suspected violation of our Code of Conduct. Any concern can be submitted confidentially and/or anonymously. The hotline operates 24 hours, 365 days a year and supports multiple languages.

The hotline can be reached

via www.lighthouse-services.com/allnex, 

by email to reports@lighthouse-services.com,

by phone

- English speaking USA and Canada: 844-260-0005 (Toll-Free)
- Spanish speaking USA and Canada: 800-216-1288  (Toll-Free)
- French speaking Canada: 855-725-0002  (Toll-Free)
- Spanish speaking Mexico: 01-800-681-5340  (Toll-Free)
- All other countries: +1 800-603-2869  (Toll-Free)

or by fax: +1 (215) 689-3885

The Botany site in New South Wales (NSW), Australia operates under a NSW Environment Protection Licence. Under the terms of the licence, the site is required to publish the following information:

 

Environmental Monitoring Data

The report provides the community access to environmental monitoring data as required by the Environment Protection Licence. The report is updated regularly and posted here:  NSW Environmental Monitoring Report

 

Pollution Incident Response Management Plan

In the event of a pollution incident, allnex will take all necessary actions to minimize the size and any adverse effects of the unintended release. If the incident presents an immediate threat to human health or property, the relevant authorities and local community will be informed of the incident in accordance with NSW legislative requirements.  The procedure for communicating a pollution incident can be accessed through the following link: Pollution Incident Response Plan - Communication Procedure
 

Botany Site Groundwater Remediation Program

The site groundwater remediation program will be carried out progressively from 2021 to 2027 as illustrated in this plan: Botany Site Groundwater Remediation Program

Groundwater Remediation Newsletters

Allnex’s Code of Conduct contains references to the reporting of wrongdoing.  In Australia, legislation was introduced in 2019 requiring large corporations in Australia to have a separate whistleblower policy that complies with the requirements of the Australian legislation.

 

Allnex has introduced a Whistleblower Policy which applies specifically to the Group’s operations in Australia.  A copy of the policy can be found here

When doing business with allnex, suppliers of goods and services are expected to respect and adhere to required principles of decent business as described in the allnex Supplier Code of Conduct. allnex expects its suppliers to adhere to and live by the aforementioned principles by incorporating them in its own business practices.

A copy of allnex Supplier Code of Conduct can be found here:

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This statement sets out the steps Allnex Australia has taken during the previous year to manage the potential risk that slavery and human trafficking is taking place in any of its operations and supply chains.

allnex Australia Modern Slavery Statement 2021
allnex Australia Modern Slavery Statement 2022
allnex Australia Modern Slavery Statement 2023

Allnex Norway AS is covered by the Norwegian Act on enterprises’ transparency and work
with fundamental human rights and decent working conditions (Transparency Act)

Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act