VICTREX CODE OF CONDUCT DOING THE RIGHT THING

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CODE OF VICTREX CODE OF plc

INTRODUCTION FROM OUR CEO CODE OF FRAMEWORK Passion, Innovation and Performance are integral to our behaviours and we must support and uphold them in an ethical manner. Our ethical principles are set in our Code of Conduct and underpin the way we do business and treat one another. Our Code sets the foundations of how we act personally, with others and in our communities. CODE OF Our continued success as a business rests on maintaining these principles and ensuring we strive to always: DO THE RIGHT THING. Jakob Sigurdsson CEO, plc Our Code of Conduct gives us the ethical foundation for everything we do. It s supported by the expectations set in our Code of Conduct suite of supporting policies, on Conduct, People and Sustainability. Our Behaviours and Values span these, demonstrating how we use these to deliver our Strategy and Objectives.

in our We are open and honest We comply with all applicable laws and regulations We do not engage in anticompetitive activity, bribery or corruption We protect our company information and confidential information shared with us CODE OF We follow good standards of corporate governance and do not abuse market regulations Our Conduct policies include Fraud Policy Conflict of Interests Policy Modern Slavery & Human Trafficking Policy Conflict Minerals Policy Export & Sanctions Policy Anti-Bribery & Corruption and Financial Crime Policy Competition and Anti-Trust Policy Data Protection Policy Information Security Policy Share Dealing Codes Ivy Wong Customer Services, Hong Kong CEO Award winner 2016 for Demonstrating our Values

for our We treat people with fairness and respect, and hold ourselves and each other to account We do not discriminate We provide a safe and healthy workplace and ensure our activities do not harm our employees, the public or the environment CODE OF Our People policies include Global Whistleblowing Policy Disciplinary & Grievance Policies Diversity & Equal Opportunities Policy SHE Policy Matt Owen Operations, Hillhouse CEO Award winner 2016 for Demonstrating our Values

for We deliver sustainable polymer solutions We work to minimise the environmental impact of our business operations We contribute to the wellbeing of our local communities We seek to inspire the next generation CODE OF Our Sustainability policies include Sustainability Policy Irene Sinz Sales, Europe CEO Award winner 2016 for Giving Something Back

Find out more Speak up All of our employees, officers and Board members must be aware of and follow our Code of Conduct and its supporting policies. Any breaches of the Code may result in disciplinary action. There is annual recertification through mandatory awareness training. If you have concerns that this Code of Conduct or its supporting policies are not being followed, DO THE RIGHT THING and let us know. The Global Whistleblowing Policy gives you more help on how to do this. Our employees can read the full Code of Conduct policies on the Code of Conduct section on the V-NET Policies page, and are encouraged to discuss with their line managers if they are unsure how these relate to their role. External parties can see more information on www.victrexplc.com

There is no right way to do the wrong thing Code of Conduct 2017