Albemarle Code of Conduct - Page 35



CONTACT WITH
COMPETITORS
We believe in the principle of free trade. We are committed to vigorous but fair competition and act independently
of our competitors. We expect our customers and vendors to also compete fairly and will take action against those
who do not.
We do not agree with competitors to fix, raise, lower or
stabilize prices of goods that we sell.
We do not agree with a third-party to boycott a
particular supplier or customer even on apparently
legitimate grounds (credit performance, safety).

We do not fix other competitive terms such as pricing
formula, surcharges, discounts, margins, rebates,
commissions or credit terms with competitors.
We do not enter into a no-poach agreement with
competing hirers of talent or discuss compensation
levels for potential or existing employees.

We do not agree with competitors to limit the quality
or features of our products, research or innovation.

We avoid casual contact or communication with
competitors that could give the impression of collusion
or the inappropriate exchange of information between
Albemarle and competitors.

We do not use third parties (including consultants,
third-party sales representatives or industry
associations) to assist in or facilitate improper
contacts or activities with competitors.
We compete on price, quality, volume, service, talent,
research and innovation.



We do not disclose, request or otherwise exchange
competitively sensitive information with competitors in
an inappropriate manner.

We do not agree with competitors to limit production
or production capacity.

We do not rig bids or otherwise illegally coordinate
bidding or tendering activities with competitors.

We do not allocate markets, customers, suppliers or
geographic territories with competitors.
D OI NG BU SINESS A S A GLOBA L C OMPAN Y


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