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Our ValuesCourage. We value and encourage innovationand thoughtful risk-taking on all levels. Wechampion change and work to overcome thebarriers to success, while remaining flexibleand adaptable. Although our dynamicenvironment often calls for quick response andbold action, we don't fear taking initiative ormaking mistakes, because we know that trialand error are an integral part of learning.exchange of ideas both internally andexternally.Human Rights. We believe that respect forhuman rights is a fundamental element for amodern sustainable society, and strive touphold support for human rights. The Groupdoes not condone or facilitate violations ofhuman rights, and respects the human rightsof its employees.Customer Focus. Our aim is simple – toprovide every customer, both internal andexternal, with products and services ofuncompromising quality, error free, on time,every time. We gear our activities to enhanceand maximize value to our customers. We dothat by anticipating their needs, exceedingrequirements, and continually striving toimprove.Supply Chain Conformance. The GroupCompanies expect that their raw materialssuppliers (including distributors) comply withthe DIC Group Supply Chain CSRDeployment Guidebook and with applicablelaws, including those intended to eradicateslavery and human trafficking as well as thoseintended to eliminate bribery and corruptionin contracting.Communication. We support and encourageopen communication and meaningfulcooperation among colleagues from varyingbackgrounds and disciplines. We keep ourselves fully informed and involved in thebusiness. We share information freely,trusting in the cooperative spirit of ourassociates. We believe in the free and honestSustainability. DIC Group aims to conductdevelopment that “meets the needs of thepresent without compromising the ability offuture generations to meet their own needs”and be a group that contributes to sustainableenhancement of society and the globalenvironment.These Standards & Guidelines are a statement of policies for individual andbusiness conduct and do not, in any way, create any contractual or otheremployment rights or any assurance of continued employment.And, for Sun Chemical Employees, your employment, unless otherwisespecifically covered by written contract, is at will, and terminable by either youor Sun Chemical at any time, with or without cause, and with or without notice.3

What Are The Business Conduct Basics?any customer, supplier, governmentofficial, or third party.As an employee of a DIC Group Company,you are obliged to know and operate within acode of conduct that is in keeping with theGroup’s values. No one is expecting you to bea legal expert. Thus, the focus is on “doingthe right thing.” These Standards &Guidelines are important in developing acommon set of values to run our business.As used in this Code of Business Conduct,“Group,” “Group Company,” and “GroupCompanies” means DIC Corporation and itssubsidiaries, including Sun Chemical GroupCoöperatief U.A., DIC Asia Pacific Pte. Ltd.,and DIC (China) Co. Ltd., and their controlledsubsidiaries and joint venture partners overwhich a DIC Group Company exercisesmanagement control, wherever located.Here is a summary of the standards that allemployees of the Group Companies areexpected to live up to: Obey all applicable laws governing ourbusiness. Strive to be honest, fair, and trustworthyin all your dealings. Avoid all conflicts of interest betweenyour work and personal life. Value diversity by observing fairemployment practices with all co-workers. Strive to create a safe workplace and toprotect the environment. Respect the rights, dignity, and privacy offellow employees and other individualswith whom you deal on behalf of yourGroup Company. Ensure that our work environments arebased on freedom from harassment anddiscrimination in all forms. Protect the Group’s proprietary andconfidential information from improperdisclosure. Don’t accept or offer any improperpayments, gifts, or gratuities from or to Don’t accept any confidential informationfrom another person or company or sign aconfidentiality agreement in favor of athird party without proper authorizationand legal review. Don’t enter into any contractual obligationwithout proper authorization and legalreview. Make sure that financial records of GroupCompanies are accurate, complete, fullyreflect the described transaction, andcomply with applicable laws andaccounting standards. Make sure that your business relationshipswith the Group’s customers, suppliers,competitors, and governments complywith all applicable laws, includingcompetition, antitrust, anti-bribery,financial transaction, tax, and antiterrorism laws. Take a firm stance against and do notyield to any demands from anti-socialorganizations such as organized crimesyndicates, groups that advocate hatecrimes, or terrorists.Is That All?The brief summary on this page does not limit orrestrict the Code of Business Conduct Standards& Guidelines. It is meant only to introducesome of the important concepts that support theGroup’s values. Common sense and a basicunderstanding of legal and ethical principlesshould be what you need to do your part tomaintain a high standard of conduct andpreserve the reputation of the Group. Please readthoroughly the Standards & Guidelines in thisbooklet. These explanations will assist you inidentifying legal and ethical issues as they ariseand help you to resolve them.4

What Are The Business Conduct Basics?in meeting its legal and ethical obligationsdepends on each of us seeking advice beforeproblems occur and reporting incidents that mayviolate this Code of Business Conduct. It makesno difference whether an employee engages inillegal or unethical conduct to benefit himself orherself or others, or whether he or she does so ina misguided attempt to benefit the GroupCompanies. In plain words, unethical or illegalconduct is unacceptable.What About National Differences?The Group Companies are global companies,and therefore we have a set of global Standards& Guidelines. The Group realizes that laws varyfrom country-to-country and from region-toregion, and employees are required to complywith the laws applicable to their locations andthe transactions they conduct. However, this isonly a minimum standard. To the extent theCode of Business Conduct Standards &Guidelines are more strenuous than local laws,the Group requires adherence to the higherglobal business standards expressed here. In thisway we can assure fair and consistent treatmentfor our employees, customers, and suppliersaround the world.What Do I Do If I Find A Non-ComplianceIssue Or A Possible Non-Compliance Issue?You are obligated to make every effort to assurethat the Group Company for which you workremains in compliance with this Code ofBusiness Conduct. Accordingly, all employeesare required to report known or suspected noncompliance with safety, the law, or Grouppolicies to one of the individuals listed inAppendix A. In making a report, it is essentialthat the person reporting the problem NOTconduct his or her own inquiry for it mayinvolve complex legal issues. Even if you arenot certain whether an action constitutes noncompliance, you are requested to promptly makea report.Who Must Follow These Standards &Guidelines?These Standards and Guidelines are applicableto all employees (including directors, officers,part-time employees, temporary employees,dispatched employees, seconded employees, andadvisors acting on behalf of a DIC GroupCompany) of Group Companies worldwide.What Constitutes Compliance?These Standards & Guidelines reflect andrequire the joint responsibility of the GroupCompanies and their employees to comply withthe laws that govern the activities of the GroupCompanies around the world, to adhere to thehighest ethical standards, and to act asresponsible members of the communities wherewe operate. These Standards & Guidelines havebeen structured to provide Group employeesthroughout the world with the basic guidancenecessary to meet the goals and objectives of theGroup Companies in their pursuit of globalbusiness relationships. All employees areaccountable for compliance with these Standards& Guidelines, as well as governmental laws andregulations applicable to the Group’s activities,and such other policies and procedures as maybe instituted by their Group Company.All reports concerning possible non-compliancewith the law or Group policies will be treatedconfidentially to the extent possible under thecircumstances, and will be fairly and promptlyevaluated by an appropriate corporate officer.And he or she will take necessary correctivemeasures. With swift and timely reporting, DICGroup can resolve compliance problemsquickly.It is Group policy to support and protect anyperson who makes a good faith effort to reportsuspected non-compliance issues. As a result ofthe investigation, even if the reported activity isdetermined to be clear of any non-complianceissues, as long as the report is made in good faithand not done maliciously (for example, todeliberately slander another), the person whomade the report will not be held liable for doingso.Each employee is responsible for ensuring thathe/she understands and abides by theseStandards & Guidelines, with the assistance ofhis/her Group Company. The Group’s successRetaliation against any individual who reports anon-compliance issue or who participates in aninvestigation of such report is prohibited and is a5

What Are The Business Conduct Basics?serious violation of this Code of BusinessConduct. Anyone engaging in such retaliationwill be subject to disciplinary action.proper to seek guidance on the right course ofconduct.If you have questions concerning theseStandards & Guidelines, the related policies orprocedures of the Group Company for whichyou work, the laws governing your activities onbehalf of the Group Company for which youwork, or if you feel the need to seek guidancewith respect to a legal or ethical question, youmay contact any of the following resources toseek guidance or report any concerns:What About Cooperating In AnyInvestigation?All employees are required to cooperate in theinvestigation of any alleged violation. If it isdetermined that corrective action is required, theapplicable Group Company and its seniormanagement will decide what steps should betaken to rectify the situation and prevent itsrecurrence.Who Can Answer My Questions?These Standards & Guidelines cannot providedefinitive answers to all questions encounteredwhile working for the Group. For that, we mustrely on our own common sense and goodjudgment about what is required to adhere to theGroup’s high standards, including when it is Your Manager or Supervisor A higher level manager in yourmanagement line of reporting Contact Persons listed in Appendix ATo report violations of this Code ofBusiness Conduct, please make sure tocontact any of the Contact Persons listed inAppendix A.6

1 Your Rights As An Employee: Respect, Dignity, Privacy Equal Opportunity Verbal harassment: Includes slurs,derogatory comments, threats, or intimidatinglanguage of an ethnic, racial, religious, orsexual nature.The Group recognizes that its greatest strengthlies in the talent and the ability of its people.We are expected to hold ourselvesaccountable to the highest professionalstandards with mutual respect being the basisof all professional relationships. Animportant part of this is freedom fromdiscrimination, fear, harassment, and othernegative social issues. Thus, the Group isdedicated to ensuring that our people have aspositive and freedom-based workenvironment as possible. Although specificHuman Resources programs and policies maydiffer in detail by company, division,operating unit, subsidiary, or affiliatedcompany, overall goals have been establishedto guide the Group’s activities in employeerelations. It is the Group’s policy to: Visual harassment: Includes derogatory,offensive, threatening, or demeaning written,printed, or electronic materials, gestures,pictures, or physical objects that are displayed,sent to another person, or made available toothers to view that are of an offensive, ethnic,racial, religious, or sexual nature. Physical harassment: Includes unwelcometouching, hazing, or physical interference of aperson or a person’s property. Sexual harassment: Includes unwelcomesexual advances, whether or not there is animplied or expressed condition ofemployment, advancement, or other benefit, ora threat of negative employment action if suchdemands are rebuffed. Provide equal opportunity for allindividuals in recruiting, hiring,developing, promoting, compensating, andall other terms and conditions ofemployment without regard to race,religion, sex, color, age, marital status,gender, sexual orientation, physical ormental disability, veteran status, nationalorigin, or any other characteristic protectedby applicable law, and in accordance withapplicable laws and jurisdictions. Discrimination: Includes discrimination inemployment, such as in hiring, promotions,compensation, work assignments, workinghours, and dismissal, based on gender, age,nationality, race, skin color, ethnicity, religion,creed, social status, origin, marital status,sexual orientation, or physical or mentaldisability, or any other attribute protected byapplicable laws and regulations. Maintain a professional, safe, drug-free,and discrimination-free work environment. Physical punishment: Includes verbalmistreatment and psychological or physicalrestraint. Recognize and compensate employeesbased on their performance and provide acompetitive array of benefits.No RetaliationRetaliation includes adverse action taken againstan employee who has made an internal orexternal claim or given evidence in support of aclaim of discrimination or harassment.Retaliation is strictly prohibited and anyonefound to be in violation of this policy will bedisciplined accordingly.Anti-Harassment And Non-DiscriminationThe Group’s policies and the laws of manycountries prohibit all types of discrimination,harassment, hazing, intimidation, and retaliationin the workplace or at any company or businessrelated function, event or meeting. Prohibitedpractices include, but are not limited to:7

1 Your Rights As An Employee: Respect, Dignity, PrivacyReporting A Claim Of Harassment,Discrimination, Or Retaliationand European Union directives applicable tonon-public, personally identifiable informationrelated to its employees. Because these laws arecomplex, these Standards & Guidelines cannotstate in detail all the specific actions required ofthe Group and the Group Company for whichyou work.Complaints about harassment, discrimination,or retaliation should be directed to a contactperson listed in Appendix A.Privacy In The WorkplaceIt is the Group’s policy to comply withapplicable legal requirements concerningprivacy in the workplace. However, employeesand contractors should be aware that they mayhave limited rights of privacy as to anyinformation or file maintained by, transmitted,or stored through the computer systems, voicemail, email, or other technical or electronicresources of the Group and/or the GroupCompany for which you work, with theexception of information or files maintained byHuman Resources or as specifically regulated bylaw.In general, Group policy requires: Adherence to appropriate proceduresconcerning intern

DIC Group and Sun Chemical Group understand and play by the rules when conducting business activities. I want DIC Group to live its corporate values; be trusted by customers, business partners, shareholders and other stakeholders; and garner and maintain a reputation as a company to do business with.