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Page 24 Code of Conduct The Right Way Every Day Letter from the CEO Bhavesh V. Bob Patel Chief Executive Officer and Chairman of the Management Board Dear Colleagues At LyondellBasell we aspire to become the most valued chemical company in the world. To meet this aspiration we must all conduct ourselves with integrity and adhere to a common set of values and behaviors which are outlined in our Code of Conduct. The Code of Conduct explains how we conduct business around the world. Each of us must commit to understanding this Code of Conduct and abiding by its principles. To familiarize you with the Code of Conduct and how we do business annual training is provided to all employees. I am proud of the character and ethical conduct exemplified by LyondellBasell employees. However just as we must intervene to ensure a safe work environment we must also report instances of behavior which may violate our Code of Conduct. If you suspect or know of any possible violations or if you have any concerns you should feel safe to speak up and to take the appropriate actions as described in the Code. I want a work environment where you are valued inspired to do great things and feel safe to speak up. Speaking up in good faith will not result in any retaliation. Thank you for your continued dedication and hard work. Your commitment to performing at your best and with integrity will help us to achieve our goal of becoming the most valued chemical company in the world. Best regards i ii Table of Contents A Letter from Our CEO i Table of Contents ii Section 1 Everyday Excellence How We use Our Code of Conduct 1 Welcome to Our Code 1 Who Must Follow Our Code 2 Knowing and Following the Law 2 Where to Seek Guidance and Report Concerns 3 Consequences for Violating Our Code 3 Responding to Audits Investigations and Inquiries 3 Code Waivers 3 Section 2 Everyday Excellence for Our People and Our Company 4 We Respect Our Fellow Employees 4 We Expect to Achieve Goal Zero in Operational Excellence 6 We Protect Our Companys Assets 7 We Use Company Technologies Responsibly 8 We Respect Each Others Personal Information 8 We Avoid Conflicts of Interest 9 We Comply with Anti-Corruption Laws 10 We Work to Prevent Money Laundering 11 We Comply with Antitrust and Competition Laws 11 Section 3 Everyday Excellence for Our Shareholders 12 We Work to Prevent Insider Trading and Tipping 12 We Maintain Accurate Financial Books and Records 13 Section 4 Everyday Excellence for Our Customers and Vendors 14 We Strive to Meet Product Quality and Safety Standards 14 We Deal Fairly with Our Customers and Vendors 15 We Safeguard Third Party Information 15 We Comply with International Trade Controls 15 Section 5 Everyday Excellence for Our Communities 16 We Operate as a Good Corporate Citizen 16 We Work to Protect Our Environment 17 We Make Charitable and Political Contributions Ethically 17 Section 6 Acknowledgment Form 18 Index of Contact Information inside back cover 1 Every Day Excellence How We Use Our Code of Conduct Welcome to our Code of Conduct Code The Code embodies our dedication to conducting business ethically and responsibly. It explains the behaviors expected of each of us and sets the standards of how we work together to achieve our goals. The Right Way I Every Day www.lyondellbasell.ethicspoint.com2 Who Must Follow Our Code Our Code applies to all employees officers directors or anyone doing business on behalf of our Company. In addition we expect those we do business with to follow similar principles when working with LyondellBasell. While everyone has a personal responsibility to abide by the Code when conducting business on behalf of our Company supervisors and managers have additional obligations. If you are a supervisor or manager you have a duty to act as an ethical role model for those who report to you. You should never take any adverse action against someone for raising a good faith concern. Instead you should reinforce the Code through your actions. If you become aware of a compliance lapse it is your responsibility to take the appropriate action and escalate as required. Knowing and Following the Law The Code is the cornerstone of our commitment to comply with the law but the Code does not describe every law that may apply to you. As a global organization our work is subject to the laws and regulations of many different countries. Each of us is responsible for knowing and following these laws in addition to our Code policies and procedures. If you believe there is a conflict between the law of your country and another in which we do business a conflict between the law and our Code or a conflict between the law and anything you are asked to do seek guidance by following the steps outlined in this Code. Please read the Code carefully as you are expected to know and follow it at all times. From time to time you may be asked to indicate that you have read understood and acknowledged our Code. Failure to read or acknowledge the standards contained in the Code does not relieve your responsibility to comply with it or any of our other policies or procedures. All references to our Company or LyondellBasell in our Code refer to LyondellBasell Industries N.V. its subsidiaries and affiliates in which we have operational control through a services agreement or other contractual arrangement. Company policies referred to in our Code can be found on Elements the Company intranet. The Right Way I Every Day www.lyondellbasell.ethicspoint.com3 for raising a concern you should bring this matter to the HR department Legal department Compliance department or report it through the Ethics Helpline. Consequences for Violating Our Code Our Company takes Code violations very seriously. Individuals who violate the Code are subject to disciplinary action up to and including termination from employment. Responding to Audits Investigations and Inquiries We must respond to and comply with all external and internal audits and investigations including government investigations. You may never impede or delay any such audit or investigation. You must be truthful cooperate fully never misrepresent facts or circumstances and provide auditors and investigators with the information they request. If you have any questions about any audit investigation or inquiry and how you should respond consult with the Legal department or Compliance department. Code Waivers Waivers of the Code must be consistent with the New York Stock Exchange Rules. Question Anton observed a situation that he believes is a violation of our Code of Conduct. Should he report this situation even if he is not completely certain there is a violation Answer Yes. All employees are responsible for reporting possible violations to their supervisors or another Company resource as described in the Where to Seek Guidance and Report Concerns section. Antons report will be taken seriously and investigated as appropriate. It is better to report a good faith belief that turns out not to be an issue than to ignore a possible violation of the law or Company policy. Where to Seek Guidance and Report Concerns Raising awareness of possible violations or concerns and taking the appropriate action as described in our Code is part of our culture as is our commitment that doing so will not result in any retaliation. Therefore you are expected to come forward with any questions or concerns you may have. If you need guidance or if you would like to make a report the following resources are available to you Your supervisor or manager The Human Resources HR department The Legal department The Compliance department The Ethics Helpline by phone or via www.lyondellbasell. In some locations failing to report Code violations or misconduct may also result in civil and criminal penalties and fines. Note that failure to report any suspected Code violation or misconduct immediately may also be considered a violation of the Code. Reports to the Ethics Helpline Our Ethics Helpline is maintained by EthicsPoint an independent third party provider. A report can be made via the telephone directly to an EthicsPoint representative or via the internet. The Ethics Helpline is available 24 hours a day seven days a week with translators. Where allowed by law you may choose to make an anonymous report. LyondellBasell will not attempt to identify you if you choose to remain anonymous. If you choose to make an anonymous report through EthicsPoint the EthicsPoint system allows you and the investigator to have a confidential anonymous dialog. When you make a report to the Ethics Helpline EthicsPoint will forward your report to LyondellBasells Compliance department for review. We Do Not Tolerate Retaliation As part of our culture we have a responsibility to our Company and each other and we are expected to report our concerns when we believe something improper or inappropriate has or may have taken place. However it can be difficult to uphold this responsibility when we fear retaliation. LyondellBasell does not tolerate retaliatory acts against anyone for making a report in good faith. When you make a report in good faith it means you provide all of the information you have and you believe to be true. When made in good faith even if an investigation prompted by your report does not confirm that misconduct has taken place no action will be taken against you. You should feel comfortable making a report to any of the resources listed in the Where to Seek Guidance and Report Concerns section. If you believe that you or someone else has been retaliated against Every Day Excellence for Our People and Our Company We Respect Our Fellow Employees At LyondellBasell we are dedicated to the highest standards of fairness and respect for every employee. To thrive in a global marketplace we must respect value and welcome the diverse perspectives and backgrounds of each of our employees and stakeholders. Therefore we encourage the open sharing of ideas and communication of problems. Each of us must support and promote a diverse workforce by respecting the various talents and opinions of our coworkers. 4 The Right Way I Every Day Unlawful Discrimination LyondellBasell does not unlawfully discriminate against any person on any basis in any part of its global operations. We comply with applicable laws governing unlawful discrimination in employment in every location in which we operate. This means in part that we never make unlawful employment-related decisions based on a legally-protected status or traits such as race gender color age sexual orientation religion disability genetic information or other characteristics as and where protected by applicable law. We make decisions to hire promote terminate or transfer employees based on merit. Anti-Harassment LyondellBasell is committed to providing a workplace free of harassment. To promote respect within our organization we must all treat one another with dignity. Our Company does not tolerate any form of harassment or abusive work environment whether it comes from within or outside of our workplace. Harassment can be any form of unwelcome or abusive workplace conductsexual or non-sexual in naturethat has the effect of creating an intimidating hostile or offensive workplace. A few examples include Physical contact including touching hugging or kissing Verbal comments such as racial slurs or sexist jokes or comments Non-verbal visual displays including electronic displays or acts that contain offensive photographs videos or hand gestures Threats or acts of fear intimidation bullying mobbing or other legally- prohibited abusive workplace behavior Workplace Violence We insist on a non-violent workplace. We must never engage in tolerate or ignore any form of violence. This includes threats or acts intimidation or instilling fear of bodily harm in others. If you know of an actual or potential threat or act of violence you should report your concerns immediately. Question Yesterday Simon had an argument with a co-worker that almost escalated into a physical confrontation when he challenged him to meet him in the parking lot outside. Simon now fears that his co-worker may try to harm him at some point. What should Simon do Answer Simon should report this incident immediately to any of the resources listed in the Where to Seek Guidance and Report Concerns section. In certain circumstances you also may report the incident to Global Security or applicable law enforcement. 5 The Right Way I Every Day We Expect to Achieve Goal Zero in Operational Excellence Working safely is a core value of our Company. It begins with Goal Zero by which we make the commitment to never allow the safe responsible operation of our facilities to be compromised for any reason. It also means we must be dedicated to safety excellence. Nothing should matter to us more than working safelyand we therefore must strive to create a workplace in which no one gets hurt anywhere at any time. Our Code Company standards and Company policies must be followed by every employee and person working on behalf of the Company at all times. You are expected to report any actual or suspected violations of Company rules and policies consistent with the steps outlined in Where to Seek Guidance and Report Concerns. Alcohol and Substance Abuse At LyondellBasell we never perform our work under the influence of alcohol illegal drugs or improperly used prescription medications. In addition we must never possess use sell offer or distribute illegal drugs or other controlled substances on Company premises or while conducting Company business. We may possess and consume alcohol at Company sponsored or authorized functions or in certain legitimate business settings such as client entertainment. At all such times however we are expected to act responsibly and to drink moderately not to the point that we are under the influence. The Company may withdraw these privileges if they are abused. Question Lilly knows she is supposed to report injuries job-related illnesses and accidents but her performance award depends on the incident rate going down. What does LyondellBasell really want Answer LyondellBasell wants every employee to report injuries job- related illnesses and accidents. It is only through such reporting that the Company can respond to dangerous situations measure our safety performance and uphold our commitment to health safety and the protection of the environment. Awards for all employees are tied to overall performance in which safety is one of several components. To protect all those working in LyondellBasell facilities and those living in the communities in which LyondellBasell operates accurate and timely reporting is a necessity. 6 The Right Way I Every Day Question Angela recently purchased office supplies using her corporate credit card. Since her department did not need the office supplies she returned the supplies to the vendor and received the refund on her personal credit card and did not refund the funds to the Company. Is this a violation of Company policy Answer Yes. This would be considered stealing from the Company as she received money for supplies that were purchased with Company funds. We Protect Our Companys Assets We all have a duty to exercise care when using our Companys assets. This includes Company funds products computer systems and software vehicles facilities equipment documents networks confidential information intellectual property and even our reputation. Company assets cannot be used for personal use unless specifically permitted by Company policy. Theft of Company assets or stealing from the Company is a violation of the Code. In addition if you know or suspect any theft abuse misuse or waste of Company assets you should report it immediately. Confidential Information and Intellectual Property You may have access to LyondellBasells confidential non-public information. Confidential non-public information can take many forms including financial information customer lists business strategies and plans or operational and asset-related information. As an employee you are expected to use confidential information solely for the benefit of the Company and not impermissibly disclose it to others outside the Company. Just as we expect all employees to respect the Companys confidential information we expect employees to respect the confidential information of others including competitors suppliers and customers. If you inadvertently learn of such information please notify your supervisor or manager. One type of confidential information is called Intellectual Property IP. Our IP is a valuable asset and we must take great care to protect and enforce our IP rights at all times. IP includes intangible property such as copyrights patents trademarks design rights logos and brands. The law protects our rights to this property as it does other forms of physical property. To the maximum extent permitted by law the rights to all IP created with Company materials on Company time at our Companys expense or within the scope of our duties belong to LyondellBasell. Trade secretsa special class of confidential data that gives our Company a competitive advantageare also valuable Company assets we must protect. Some examples of trade secrets include Customer lists or data Terms and conditions rates or fees offered to customers Marketing and strategic plans Technological developments Never disclose trade secrets or any other confidential or proprietary information without a business need and prior authorization to do so. Take special care not to disclose this information by properly securing your computer documents or other sensitive materials. In addition avoid discussing such information in places where you can be overheard including restaurants restrooms taxis airplanes or elevators. Remember these obligations continue even after your employment with LyondellBasell ends. Our Reputation We keep our reputation strong through appropriate and accurate dialogue with our stakeholders. Our reputation for integrity is influenced heavily by the information we provide to the public. This means in part that all such communications must present a fair and accurate picture of our business dealings. Only authorized individuals may speak about LyondellBasell to the media the investment community and other public forums. If you receive a request for information from the media you should forward it to Corporate Communications. If you receive a request from an analyst or member of the investment community you should forward it to Investor Relations. If you receive a request from an outside legal representative or government agency you should forward it to the Legal department. Do not take the following actions Speak on behalf of LyondellBasell unless you are a designated spokesperson and have authorization to do so Disclose any confidential information Refer to LyondellBasell customers suppliers or partners without their approval For more information please see the applicable Company policies on Elements. 7 The Right Way I Every Day We Use Company Technologies Responsibly Our computer and network systems are valuable assets of our Company. When using them do so appropriately and remember that you represent LyondellBasell in all you do. Always use Company computer and network systems including guest and corporate wireless in a safe ethical lawful efficient and productive manner. This means you should never use these systems to access view send or communicate illegal inappropriate sexually explicit offensive or unsolicited materials. While limited personal use is allowed you should never let such use interfere with your job responsibilities. You should treat email texts blogs and instant messages with the same care you would in writing a letter on LyondellBasells letterhead. We should remember that Subject to applicable laws all computer systems and the data created transferred and stored is Company property. For security and system maintenance purposes individuals authorized by LyondellBasell may monitor equipment systems and network traffic at any time. Monitoring will only be carried out to the extent permitted or required by law and as necessary and justifiable for business purposes. Employees must not share accounts and must keep their passwords secure and are responsible for the work performed with their account this includes but is not limited to email and use of Company information. 8 Employees must not circumvent desktop or security controls. This activity can result in the introduction of malicious programs e.g. viruses into Company computer systems. Violating copyright or similar laws or regulations including but not limited to the installation or distribution of pirated or other software products that are not appropriately licensed for use by LyondellBasell is also strictly prohibited. Information not released for public consumption or company Confidential information cannot be transferred to or stored on flash drives external optical drives or third party hosted systems such as personal email or internet hosted services. We Respect Each Others Personal Data and Follow Data Privacy Regulations Our Company respects the confidentiality and protection required by law of current and former employee personal data as well as personal data of our contractors and customers. This typically includes information such as home addresses government-issued identification numbers payroll and other personal information. With respect to such personal data we must Act in accordance with applicable law act in accordance with Company policy collect use and process such information only for legitimate business purposes and take care to prevent unauthorized disclosure. Social Media and Networking At LyondellBasell we recognize the vast opportunities provided to personally participate in various social media outlets. Social media includes a variety of social networking sites blogs and wikis. However when making use of such personal opportunities we strongly encourage you to do so with caution. You may never use social media to defame harass bully mob threaten or intimidate Company employees customers competitors or vendors. In addition never share any confidential or proprietary Company information through your participation in social media. According to the National Labor Relations Act in the United States confidential information for purposes of this section of our Code does not include personal wage disciplinary or other information about terms and conditions of your employment. The use of social media outlets should never interfere with work. The Right Way I Every Day Question Martins brother owns a company that has supplied materials to our Company for many years. Martin was recently promoted and in his new position will have authority to contract with his brothers company. What must Martin do Answer Martin should disclose the conflict via the Conflict of Interest disclosure form to his supervisor with a copy to the Compliance department so that it can be resolved. Even though his brothers company is a longtime supplier of our Company an appearance of a conflict has now been created because Martin has the authority to contract with his brothers company. In this case Martin should be recused from making any decisions about using his brothers company and an independent decision maker such as Martins supervisor should be designated to make such decisions instead of Martin. The important thing for Martin is to recognize a potential or actual conflict of interest and make the required disclosure. 9 We Avoid Conflicts of Interest LyondellBasell is committed to maintaining our stakeholders trust through ethical and reliable performance. This begins with our commitment to integrity. We should be alert to anything that could create a conflict of interest or even an appearance of a conflict of interest. A conflict of interest arises when our personal interests are not aligned with those of our Company. We should always be free from any interests influence or relationship that might conflict with the best interests of LyondellBasell. We should also avoid conduct which may appear to raise a conflict of interest. Below are some common examples of situations in which conflicts of interest may occur. Financial Interests Some of us may have financial investments and interests in companies other than LyondellBasell. If we have a significant financial interest in a business or entity that transacts or seeks to transact any business or compete with LyondellBasell then the details of the significant financial interest should be disclosed to the Compliance department. A Significant Financial Interest is defined as a direct or indirect aggregate interest of more than 10 percent i of any class of the outstanding securities of a firm or a corporation ii interest in a partnership or association or iii of the total assets or gross income of such employee. Outside Employment Part of what makes LyondellBasell so successful is our commitment to the work we perform. In order to uphold this commitment we are strongly discouraged from accepting outside employment or outside business opportunities in entities doing business with or competing with LyondellBasell. Such opportunities are considered conflicts of interest and must be disclosed. Doing Business with Family and Friends A conflict of interest may exist if a family member works for a customer competitor or vendor of our Company and you are in a position to affect Company business with that customer competitor or vendor. Doing business on behalf of the Company with family members in such circumstances will likely lead to a conflict of interest situation and must be disclosed. Family member means an employees immediate family members such as his or her spouse children mother father sisters brothers and steps or in-laws of these types as well as domestic partners. In addition at no time may you directly supervise a family member. If you think you may already have a reporting relationship with a member of your family you should disclose it. The Right Way I Every Day Question A vendor offers his contact at LyondellBasell Diana two high priced front row seats to a sporting event. The vendor tells Diana that he does not want anything in return as he cannot attend the event. What should Diana do Answer Diana should consult her supervisor or another Company resource as described in the Where to Seek Guidance and Report Concerns section. Our Gifts Entertainment and Travel Policy addresses such matters and in this case if the value of the tickets exceeds 100 she must obtain approval from her Senior Officer before accepting this gift. If the vendor accompanied Diana to the event then the ticket would be entertainment rather than a gift and she would not be required to obtain prior approval from her Senior Officer. 10 Business Gifts and Entertainment When conducting LyondellBasell business you may exchange business gifts and participate in entertainment to foster good relations between our Company and its customers or vendors. However we must use good judgment when offering or accepting such courtesies. Otherwise we may find ourselves in a conflict of interest situation. This means we may never offer or accept a business gift or entertainment if doing so would create a bias in our decisions. Before accepting or offering a business courtesy ask yourself if you would feel comfortable if others knew of it. As a rule you may only offer or accept a business gift or entertainment if it is unsolicited and complies with applicable Company policies. In addition we may not offer or accept improper gifts and entertainment directly or indirectly through third parties or allow our family members to do so. When interacting with government officials and employees we must follow stricter rules. Refer to the Bribes and Improper Payments section of our Code and applicable Company policies on Elements for additional information. Disclosing Conflicts of Interest If you are aware of actions or interests of your own or others that might create a conflict you must make a disclosure by completing a disclosure form. In addition we should work actively with our customers vendors and anyone doing business on behalf of LyondellBasell to identify and address conflicts of interest. For more information or guidance please see the applicable Company policies on Elements. We Comply with Anti-Corruption Laws As a global organization LyondellBasell is committed to acting ethically and legally across the globe. We uphold this commitment regardless of where we do business. This means in part that we abide by all international anti-corruption laws treaties and regulations that forbid bribery improper payments or kickbacks. Bribes and Improper Payments Doing business the right way means we never offer or accept any form of bribe payment or kickback. A bribe is an offer or promise to give anything of value in order to improperly influence a decision or to gain an improper business advantage. A kickback occurs when money is returned or is paid as a reward for awarding or fostering business. In addition LyondellBasell prohibits facilitating payments. A facilitating payment is a small paymentusually in cashmade to expedite routine government services. Although such payments may be common in certain parts of the world our Company prohibits them. You must take caution to avoid improper payments. You should always determine the ownership structure of our third party representatives by performing due diligence as required by applicable Company policies. You must also ensure that you do not allow third parties to make or receive any improper payment on our behalf. You may never seek or accept any improper payment or kickbacks. Violations of this policy may result in disciplinary action up to and including termination as well as possible civil and criminal penalties for those parties and our Company. If you have any questions or concerns about this please refer to the section Where to Seek Guidance and Report Concerns. You are expected to report your concerns about bribes and improper payments. LyondellBasell will not tolerate retaliation against anyone who makes a good faith report of misconduct. The Right Way I Every Day www.lyondellbasell.ethicspoint.com11 We Work to Prevent Money Laundering LyondellBasell is committed to detecting and preventing money laundering. Money laundering means engaging in financial transactions that conceal the identity source or destination of money gained through illegal means. As part of our commitment to identifying and stopping money laundering activity we must comply with all applicable anti-money laundering laws throughout the world. In addition we must ensure that we only do business and engage in financial transactions with persons conducting legitimate and lawful activities. We should always confirm the identities of persons or firms with whom we conduct business and be comfortable that any funds we receive are derived solely from lawful and legitimate sources. Money laundering issues can be complex. If you have any questions or concerns about this please see the applicable Company policies on Elements. You should report any suspicious activity to our Chief Compliance Officer. We Comply with Antitrust and Competition Laws Delivering excellence to our customers means we do our part to ensure they have access to quality products at fair prices. Therefore LyondellBasell is committed to competing vigorously yet ethically and lawfully. To make sure all companies play by the same rules various competition laws have been enacted in the countries in which we do business. These laws generally prohibit price fixing dividing territories colluding with our competitors and other actions that negatively affect our customers or restrict competition. We must always follow the letter and spirit of these competition laws wherever we conduct our business. These laws may apply even when you are doing business outside of a countrys borders. It is your responsibility to know and follow all competition laws that apply to your work. The following examples illustrate prohibited practices Entering into price fixing agreements Allocating market shareeither formally or informallyamong competitors Bid rigging Restricting or limiting production in order to reduce competition If you need guidance please refer to the section Where to Seek Guidance and Report Concerns and see the applicable Company policies on Elements. Question One of Carlos distributors recently offered to pay for Carlos and his family to take an all-expense paid beach vacation in exchange for Carlos increasing the volume of product provided to the distributor. Carlos was planning on increasing the volume of product anyway and does not see any issue with accepting the vacation. Did Carlos do anything wrong Answer Yes. By Carlos accepting the vacation it creates the appearance of a kickback. Carlos should decline the offer of the vacation and consider terminating the relationship with the distributor. Every Day Excellence for Our Shareholders We Work to Prevent Insider Trading and Tipping We must refuse to engage in illegal and unethical securities trading. While working at LyondellBasell we may come across confidential information about our Company subsidiaries or affiliates joint ventures clients or vendors. 12 The Right Way I Every Day www.lyondellbasell.ethicspoint.com13 Throughout the world countries have enacted laws that prohibit us from trading securities based on material nonpublic information. Material non-public information refers to information that is not available to the public and that a reasonable investor would likely consider important in deciding whether to purchase or sell a security. If you trade on the basis of such information it is considered insider trading and is illegal. Therefore you may not buy or sell our or another companys securities if you possess such information. Additionally if you share information with another person and that other person trades on the basis of the information that is considered tipping and both of you may be guilty of insider trading. Inside information may include Financial information including earnings forecasts or dividend changes Winning or losing a client or contract Changes in our most senior management Litigation or government investigations Mergers acquisitions or divestitures Sale or purchase of major assets or subsidiaries If you feel you or another employee may have engaged in insider trading or tipping you should contact the Legal department immediately. We Maintain Accurate Financial Books and Records Our shareholders depend on our honesty and integrity particularly when measuring the financial strength of our Company. It is crucial then that we maintain accurate and honest accounting practices and recordkeeping at all times. We must all comply with recognized accounting principles. Those who have financial and accounting responsibilities must also ensure that our accounting methods are accurate presenting an honest transparent and forthright picture of our Company. We must comply with all legal and regulatory requirements and follow our internal accounting policies and controls at all times. Incomplete or inaccurate financial disclosures not only damage our Company and its reputation but they also harm our stakeholders who rely on their accuracy. We must Keep and present all Company records and reports in accordance with the law. These records include accounting records as well as any other electronic or written records such as expense reports and time sheets Establish and maintain a system of strong and effective internal controls Ensure that all Company records accurately and fairly reflect the underlying transaction Question Sam accidently saw a copy of a confidential memo describing a large contract that our Company will soon sign with another company. If Sam buys some of the other companys stock on the basis of this information and before the news of the contract is made public is Sam engaging in insider trading Answer Yes assuming that the news of this contract is material nonpublic information or inside information. If Sam purchases securities of the other company on the basis of this information before it becomes public Sam is engaging in insider trading. Never falsify any document Record all financial transactions in the proper account department and accounting period Ensure that all actions and commitments are in accordance with Company policy Records Management We must retain our business records as long as the law requires and as long as necessary for our business purposes. This means we should Classify documents according to Company policy Retain and discard Company records consistent with Company policy and schedules Follow all special record-keeping requirements issued with respect to internal investigations litigation and government inquiries However if you receive notice that some or all of your records are required for an internal or government investigation or legal proceeding you shall not discard or destroy them. If you receive a subpoena or request for any document or record please notify the Legal department immediately. Similarly if you receive a request from a business counterpart a government agency or a third party to provide a record or document you should contact the Legal department. Every Day Excellence for Our Customers and Vendors We Strive to Meet Product Quality and Safety Standards Our products play a vital role in improving the quality of peoples lives. Our customers depend on us to provide products that meet or exceed all applicable quality and safety standards. Therefore we must ensure that we comply with quality controls and all related laws and regulations. In addition we must hold our vendors accountable for the quality and safety of the products and services they provide to us. If you know or suspect that a vendor is not upholding our standards you should report the situation by following the steps outlined in the Where to Seek Guidance and Report Concerns section. 14 The Right Way I Every Day www.lyondellbasell.ethicspoint.com15 We Deal Fairly with Our Customers and Vendors Doing business the right way means we always provide accurate and fair information about our Companyand our competitionto all of our customers vendors and stakeholders. This means that we must always engage in fair and ethical marketing sales and communications. We may never misrepresent our products or those of our competitors. In addition we may never take unfair advantage of anyone through manipulation or abuse of privileged or proprietary information misrepresentations or any other unethical or illegal practice. Use of Competitive Information Sometimes we have access to information about our competitors that may give our Company a business advantage. This information may come from others or employees who worked previously for or have information about a competitor. It is important that we act legally and ethically at all times with respect to this information. Even if it may be legal to use competitive information it may not be ethical. If confidential information about a competitor is deliberately or inadvertently disclosed to you you should discuss its disclosure with the Legal department and refuse to use it without express permission from the Legal department to do so. Question Patrick is training a new employee Marisol who previously worked for a competing chemical company. While discussing product markets Marisol discloses financial information about her previous employer which could affect future business decisions our Company makes. Marisol doesnt see anything wrong with sharing this information and Patrick thinks it is too useful to ignore. What should be done in this situation Answer First Patrick should explain to Marisol that her disclosure violates our Code. Helping her understand this will prevent future disclosures from occurring. Next Patrick should discuss the incident with the Legal department to determine the best course of action. Of course Patrick must not attempt to use this information for LyondellBasells gain as doing so is a violation of our Code. We Safeguard Third Party Information Through our work we may be privy to confidential information about our vendors and other stakeholders. We must safeguard this information and honor all contractual commitments we enter into with these parties relating to said information at all times. This means in part protecting all third-party intellectual property such as inventions and software from disclosure or misuse. We Comply with International Trade Controls LyondellBasell is a global company. As such it is our responsibility to know and follow all applicable laws and regulations that govern international trade. Consequences for violating trade control laws and regulations are severe for both our Company and the individuals involved. ImportExport Controls One of the responsibilities we all share is knowing and following laws relating to imports and exports. An import occurs when a product software service technology or technical information is shipped into a customs territory and an export occurs when the same is shipped out of a customs territory. Imports are subject to various laws and regulations that may require the payment of duties and taxes and the submission of certain filings. Various laws and regulations may require licenses and permits before exporting any products services technology or technical information. For additional information please see the applicable Company policies and procedures on Elements. Sanctioned Countries and Boycotts Some laws prohibit us from doing business with certain people or entities or conducting business in certain countries. We must follow those laws. We are mindful of economic sanctions imposed by the United Nations European Union United States and other jurisdictions that may restrict or prohibit trade transactions. Activities that may be restricted or prohibited include investments transfers of assets monetary payments imports exports sales or supplies of goods services software or technology trade- related transactions travel to the affected countries and any facilitation of others who are conducting these activities. We must be aware of and follow applicable restrictions wherever we are doing business to the extent not otherwise in conflict with applicable laws of primary jurisdiction. We must also comply with anti-boycott laws and regulations where applicable. Every Day Excellence for Our Communities We Operate as a Good Corporate Citizen Our commitment to excellence means we take great care to uphold human rights in all of our operations and facilities regardless of local custom. We recognize that our Company has a responsibility to respect and protect human rights by doing the following We do not use child or forced indentured or involuntary labor We uphold all fair wage and hours laws wherever we work We always promote the health and safety of our workers in every location in which we conduct business We do not knowingly do business with subcontractors or suppliers who use child or forced labor engage in human trafficking practices or the exploitation of children 16 The Right Way I Every Day www.lyondellbasell.ethicspoint.com17 LyondellBasell is committed to doing business with others who share our commitment to human rights. You should report any violations of this policy or any human rights labor wage or hours laws by referring to the section Where to Seek Guidance and Report Concerns. We Work to Protect Our Environment At LyondellBasell we are proud of our long history of managing our performance to minimize its impact on the environment. We achieve Goal Zero performance by operating our sites safely and reliably. We believe that compliance is a minimum standard. As a result we meet and strive to exceed environmental standards in all of our operations. We develop products that enable our customers to use energy and water more efficiently. In addition we work with our stakeholders to ensure that our products are consistent with environmental regulations and laws. We Make Charitable and Political Contributions Ethically Our Company has a strong sense of social responsibility and takes pride in our many volunteers. Our people give generously of their time and effort to make a difference in our local communities. In addition to Company-sponsored opportunities such as Global Care Day we are each encouraged to pursue other charitable activities of our choice. However in pursuing charitable activities that are not sponsored by the Company we may only do so on our own time and using our own resources. Question Johnny has concerns that one of his suppliers in Thailand may be using child labor and engaging in human trafficking practices. Should Johnny report his concerns Answer Yes. Johnnys supplier could be violating child labor or other laws so Johnny should report his concerns to his supervisor or another Company resource as described in the Where to Seek Guidance and Report Concerns section. Our Company does not do business with suppliers who use child or forced labor engage in human trafficking practices or the exploitation of children. This applies to your individual political involvement not sponsored by the Company as well. While we are encouraged to engage in such activity we may never do so on Company premises during Company time or with Company resources. We must also refrain from posting personal political messages on blogs or other public forums using Company networks or computers even during non-work hours. Each country where LyondellBasell operates has restrictions on political contributions by companies. Employees must consult the Government Relations department to ensure strict compliance with applicable laws. For additional information or guidance please see the applicable Company policies on Elements. 18 By signing below I acknowledge that I have reviewed and understand LyondellBasells Code of Conduct Code. I further acknowledge and agree that The Code provides a general overview of our Companys policies and it does not necessarily represent all such policies and practices in force at any particular time. I will comply with the Code written policies practices rules regulations or directives issued by LyondellBasell. I should contact my immediate supervisor or manager HR department Legal department Compliance department or Ethics Helpline as appropriate if I have any questions concerning our Code or any behavior or situation concerning the Company. I should promptly report any violations of the Code as appropriate either to my immediate supervisor or manager HR department Legal department Compliance department or Ethics Helpline. Failure to follow the Code may result in disciplinary action up to and including termination from employment. Date Employee Name Please Print Employee Signature Acknowledgment Form Compliance Department Michael D. Hopkins Chief Compliance Officer Margaret C. Mousoudakis Assistant Compliance Officer Compliance department email EthicsPoint Index of Contact Information and Resources London 4th Floor One Vine Street London W1J OAH United Kingdom Tel 44 207 220 2600 Rotterdam Delftseplein 27E 3013 AA Rotterdam Netherlands Tel 31 10 275 5500 Houston LyondellBasell Tower Suite 300 1221 McKinney Street Houston TX 77010 P.O. Box 3646 77253-3646 Tel 1 713 309 7200