Ethics and Business Conduct

​

ETHICS

Grace has established corporate governance principles, business ethics, anti-corruption and conflicts of interest policies to help employees in their daily business interactions, as well as policies on any political activities. Grace also requires all of its employees to undergo annual ethics training. The policies and related training reaffirm Grace's commitment to comply with all applicable laws and be governed by the highest level of business ethics.

• Business Ethics Policy 
  
• Conflicts of Interest Policy
  
• Political Contribution Policy
  
• Corrupt Business Practices Policy
  

ETHICS AND INTEGRITY ACTION HOTLINE

As part of the company's Business Ethics Policies, the Board of Directors has established a confidential hotline that employees, customers, vendors or other interested persons can use to anonymously report violations of, or express concerns regarding compliance with, any of the company's ethics policies (including, but not limited to, any matters involving accounting, internal accounting controls, audit matters or fraud).

The hotline is available toll-free from more than 30 countries and is staffed 24x7 by multilingual case managers.

In addition to the hotline, you may express your concerns or inquire about Grace's Corporate Governance by contacting:

1. Your normal contact at the company; or
2. The General Counsel and Chief Ethics Officer (listed below); or
3. The Chair of the Audit Committee (listed below); or
4. The Lead Independent Director (listed below).

COUNTRY, ACCESS CODES