SUPPLIER EXPECTATIONS

Stonhard as an affiliate/subsidiary company to RPM International Inc. (NYSE: RPM) expects the same level of commitment to ethical business conduct from our suppliers that we expect from our employees.

All of our business dealings and the business dealings of those with whom we do business are expected to be consistent with our Core Principles of Integrity, Commitment, Responsible Entrepreneurship and Moral Courage.

As a supplier to an RPM Company, we expect you to ensure compliance with our contractual agreements and terms and our Code of Conduct, The Values and Expectations of 168. Further, we expect you to adhere to these Supplier Expectations.

View our Code of Conduct, The Values and Expectations of 168 www.rpminc.com/about-rpm/worldwide-code-guidelines

We expect our suppliers to fully comply with applicable laws and to all relevant internationally recognized environmental, social responsibility, governance and business value standards and to employ business practices that respect individual privacy, the social, environmental and economic impacts of their work and to act as responsible corporate citizens in all endeavors. Where there are no relevant local or international requirements or standards we expect our Suppliers to comply with industry best practices.

Specifically, we expect our Suppliers to:

Product Stewardship

• Provide renewable/recycled material opportunities, address those chemicals within existing formulations that are under regulatory/toxicological review by authorities and develop and provide "safer" alternative formulations of materials that will be discontinued/phased-out due to regulatory restriction or other reasons. Optimize use of packaging materials and pursue recyclable/renewable options.
• Seek environmentally conscious development, manufacture and disposal methods.
• Protect the environment and the health of their employees, customers and neighbors.
• Provide us with all information necessary for us to comply with our disclosure, reporting and registration requirements related to products we purchase.
• Use resources efficiently and reduce waste and emissions.
• Optimize methods of transportation in their supply chain, seeking sustainable transportation modes wherever possible.
• Act responsibly by minimizing their impact on the environment.
• Support a collaborative approach to developing new, competitive and sustainable offerings.
• Develop an environmental stewardship program with the following areas of focus: energy conservation (improving energy efficiency reduces emissions as well as energy costs leading to more efficient production of products) and conservation and reuse programs (including waste minimization and recycling).
• Seek continuous improvement in the areas of product innovation, product quality, environmental stewardship, human rights, responsiveness, and responsible chemistry.
• Ensure their products to be free of Conflict Minerals¹ mined from the Democratic Republic of the Congo or its adjoining countries by undertaking reasonable due diligence with their supply chains to ensure that Conflict Minerals are being source only from mines and smelters which are conflict free and provide written certification thereof.

Employees

• Provide a safe workplace and working environment to their employees.
• Have a safety program that is actively supported by management and that, at a minimum, complies with applicable laws, rules and regulations.
• Share our commitment to human rights and worker rights and act consistent with internationally proclaimed standards, specifically in relation to fair and appropriate compensation, the right to work, prevention of harassment, safety, freedom of association, work hours, overtime, wages, benefits, slavery, human trafficking and child and forced labor.
• Create and maintain an environment free from any threats of violence, sexual exploitation or abuse.

Business Conduct

• Maintain policy requiring reporting of regulatory issues to senior management.
• Comply with all applicable antitrust, competition and trade laws, rules and regulations.
• Be free of corruption, conduct business in an ethical manner and avoid conflicts of interest.
• Refrain from making inappropriate offers, gifts, assurances or other things of value for the purposes of seeking advantage.
• Conduct business consistent with our Code of Conduct.
• Protect data and personal information in a manner consistent with international expectations.
• Protect confidential information.
• Promptly respond to all requests for data or information.
• Upon reasonable notice, permit our representatives to visit all Supplier facilities and audit all such facilities and all records relevant to products we purchase.
• Ensure that no goods sent to us are associated with, either through manufacture, ownership, and shipment or otherwise, countries on the U.S sanctioned parties list: Iran, Syria, Sudan, Cuba, and North Korea. We expect disclosure to us prior to shipment if there is any such association.
• Ensure that no goods sent to us are associated with, either through manufacture, ownership or otherwise, entities or individuals subject to sanctions programs of the United States and/or any country through which the goods originate, transition or are used administered by the United States Office of Foreign Asset Control, or any other U.S. government agency including, but not limited to, U.S. Department of Commerce and U.S. State Department.
• Provide our representatives with accurate and complete information about policies, procedures, workforce, use of subcontractors or other relevant information about operations or supply chains, pertinent and necessary for our representatives to be able to evaluate performance against these Supplies Expectations.
• Disclose to us if you have been or become debarred by any government purchase agency such at the U.S. General Services Administration.

You agree that we have the right to verify your compliance with these Supplier Expectations, our contractual relationships and our Code of Conduct and to take corrective action, including, but not limited to, termination of our relationship with you, if we have reason to believe you are not in compliance therewith.

 ¹ “Conflict Minerals” refers to gold, tin, tantalum, tungsten, the derivatives of cassiterite, columbite-tantalite, and wolframite, regardless of where sourced, processed or sold.