Business conduct and ethics

Compliance with all applicable laws and regulations including health, safety and environmental ('HSE') laws and regulations, and effective management of HSE and other ethical issues, are viewed by the Board as critical to the successful long term performance of Elementis.

It is the policy of Elementis to promote honest, ethical and lawful conduct by all employees, officers and directors of the Group, and the Board has adopted and disseminated throughout the Group the Elementis Code of Business Conduct and Ethics (the 'Code') and an Anti-corruption Policy (the 'Anti-corruption Policy'), to help employees understand the Group's standards of ethical business practices and to stimulate awareness of ethical and legal issues that may be encountered in carrying out their responsibilities. In addition, Group businesses are expected to require independent contractors, consultants, agents and sales representatives who represent the Group to agree to the same high standards as the Group's employees while working on Group business.

The Code requires all employees to comply with applicable laws, governmental rules and regulations, including making full, accurate and timely disclosures in the periodic reports required to be filed by the Group with regulators and in other public communications made by the Group. The Anti-corruption Policy prohibits the giving of anything of value to any person in government or state-owned companies, a political party or persons holding public office, including candidates, or performing public duties in order to obtain or retain business or secure an improper advantage with respect to any aspect of the Group's business.

Employees are required to adhere strictly to the Code and to promptly report (to a responsible supervisor, the Group General Counsel or other appropriate internal authority) any violations of the Code or the Anti-corruption Policy. In order to help employees comply with the Code and Anti-corruption Policy, clear guidance is given on matters such as competition law, bribery, political donations, the giving and receiving of gifts, conflicts of interests and Group whistleblowing procedures.

As well as policies and guidance, the Group recognises the importance of providing training. Web-based, modular training courses, designed in conjunction with the Integrity Interactive Corporation, are offered to employees across the Group. Some of these courses are mandatory for all employees, such as training on the Code, and others are only mandatory depending on the job role or position. These courses include topics such as "Mutual respect in the workplace", "Human rights", "Environmental stewardship", "Anti-trust", "Privacy and data protection" and "Financial integrity". About 770 employees were enrolled onto courses during 2008. On-site training, for example on health and safety, is also provided.

The Group General Counsel is responsible for the Code, Anti-corruption Policy and all matters related to business conduct and ethics, and legal and regulatory compliance.