Code of Business Conduct and Ethics

The Board has adopted and disseminated throughout the Group an Elementis Code of Business Conduct and Ethics (the “Code”) and an Anti-corruption Policy (the “Anti-corruption Policy”). The aim is 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.

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, receiving or solicitation of anything of value to any person (private or 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 report any violations of the Code or the Anti-corruption Policy promptly to a responsible supervisor, the Group General Counsel or other appropriate internal authority. 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. In addition, the Code is supported by a policy that prohibits retaliation against employees who communicate good faith concerns relating to lawful or ethical business conduct, and audit or accounting procedures or other related matters.

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


    Principal features of the Code of Business Conduct and Ethics (“Code”)
  • Global application of, and training given on, the Code to all employees;
  • Same high standards expected of contractors, consultants, agents and sales representatives;
  • Knowledge of and compliance with the Code expected and all employees have a duty to report violations, supported by a non-retaliation policy;
  • Rules on complying with all applicable laws, rules and regulations including anti-trust, bribery and insider dealing; and
  • Rules and guidance on: conflicts of interest; political donations and outside activities/interests; gifts, gratuities and loans; confidential information and privacy; fair dealing with customers, suppliers and other third parties; and anti-harassment.
  • Elementis plc Code of Business Conduct and Ethics



2018 Tax Strategy