DuPont’s Anti-Bribery/Anti-Corruption Position Statement

DuPont is committed to conducting its business activities in accordance with all applicable laws and regulations that prohibit bribery or corruption.  This prohibition against bribery and corruption is a cornerstone of DuPont’s commitment to conducting business in an ethical manner, which is one of the Core Values reflected in DuPont’s Code of Conduct.  In support of its commitment to integrity, DuPont expects all of its employees and business partners to abide by the anti-bribery and anti-corruption standards that DuPont has established as part of its ethics and compliance program.

Laws and Regulations

DuPont is committed to complying with all applicable anti-bribery and anti-corruption laws that apply to its business activities around the world, including but not limited to, the U.S. Foreign Corrupt Practices Act (“FCPA”), and U.K. Bribery Act and other anti-bribery and anti-corruption laws which may apply in relevant jurisdictions.

Code of Conduct

DuPont’s Code of Conduct, which defines the ethical principles which guide our business activities, contains a specific prohibition on bribes, kickbacks and other transfers of value that are illegal or improper.  The Code of Conduct also contains a prohibition on using gifts or entertainment to improperly influence any business decision, and sets forth specific guidelines on the types of business courtesies which are consistent with DuPont’s compliance expectations.

Anti-Bribery/Anti-Corruption Program Guide

DuPont’s Anti-Bribery/Anti-Corruption Program Guide describes various components of the compliance program that DuPont has implemented in furtherance of its commitment to prohibiting bribery and corruption in its business activities.  This compliance program includes (without limitation) the anti-bribery/anti-corruption training and compliance resources that DuPont makes available to its employees, the due diligence procedures that are implemented with business partners or in connection with mergers and acquisitions, the approval requirements for business travel involving government officials, and the financial and accounting controls that have been established to maintain the adequacy of DuPont’s books and records.

Business Partner Expectations

DuPont expects its business partners to abide by the same ethical standards with respect to bribery and corruption that apply to its employees.  In order to make its business partners aware of these standards, DuPont has developed anti-bribery and anti-corruption compliance language for its written contracts with business partners and also requires certain business partners to sign compliance certifications.  DuPont’s business partners must commit to conducting business in an ethical and responsible manner.

Compliance Reporting and Monitoring

DuPont makes various mechanisms available for its employees and business partners to report any concerns they may have about ethical business practices (including practices which may be suspected of violating anti-bribery and anti-corruption laws).  These mechanisms include a confidential hotline for reporting concerns, which are reviewed by DuPont’s legal and compliance team.  DuPont has a non-retaliation policy against anyone who makes a good faith report about an ethical concern.  To the extent that DuPont determines that any employee has violated its anti-bribery and anti-corruption policies and procedures, that employee is subject to disciplinary action (including termination of employment).  DuPont also conducts periodic audit and monitoring procedures to ensure that its business activities are being conducted in accordance with the anti-bribery and anti-corruption policies and procedures that it has established as part of its compliance program.

September 2018