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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.