1. Sustainable Palm based feedstock sourcing statement

The Lubrizol Corporation (Lubrizol) is committed to sourcing raw materials from suppliers that conduct business ethically and responsibly, aligning with our core values, including environmental protection and social responsibility. Lubrizol is working on its supply chain and is committed to “No Deforestation, No Peat and No Exploitation (NDPE)” principles and complying with the EU Deforestation regulatory requirements. While EUDR-compliant sources are not yet readily available for all materials in scope, Lubrizol is implementing conversion to these sources as they become accessible.

Following the Accountability Framework Initiative’s Operational Guidance, Lubrizol has established a cutoff date of December 31, 2020, for no-deforestation and no-conversion supply chains. The cutoff date serves as a benchmark to ensure our sourcing practices are environmentally and socially responsible, supporting compliance, promoting sustainable practices, and contributing to sector-wide efforts to prevent deforestation and conversion.

A small percentage of the raw materials purchased by Lubrizol contain palm-based derivatives. Lubrizol recognizes that the harvesting and processing of palm-based feedstocks may pose serious environmental ramifications, including deforestation, greenhouse gas emissions, air pollution and loss of peatlands. Lubrizol purchases palm-based raw materials directly and indirectly, like many specialty chemical manufacturers.

Lubrizol’s goal is to ensure that all palm-based raw materials Lubrizol sources are harvested and processed in environmentally responsible ways. Lubrizol has been a member of the Roundtable on Sustainable Palm Oil (RSPO) since 2018. Lubrizol obtained Mass Balance certification from RSPO for 9 key facilities sourcing and using palm-based derivatives for beauty and home care ingredients. RSPO certified locations can be found here.

In addition, Lubrizol recognizes that the harvesting of palm fruit may have social and economic ramifications. Lubrizol requires that its suppliers adhere to Lubrizol's Supplier Code of Conduct, and Code of Ethics which details Lubrizol's expectation – for itself and its business partners – to conduct business honestly and with integrity. The Codes set forth Lubrizol's commitment to important ethical, legal and social issues, such as complying with employment, trade and environmental laws and regulations, continuously improving the safety of workers, fostering an inclusive and respectful workplace and maintaining fair and ethical business practices in the countries where they operate. Lubrizol's Code applies to all suppliers, including suppliers of palm-based raw materials.

Lubrizol has established time bound implementation plan for conversion of palm-based feedstocks to deforestation free and certified sources. Utilizing the Accountability Framework Initiative guidance, a phased approach will be used for implementation as described below:

Phase 1: Convert 30% of high priority palm sourced products by December 31, 2026.
Phase 2: Attain conversion for 60% of priority palm sourced products by December 31, 2028.
Phase 3: Effectively reach 100% conversion of palm sourced products by December 31, 2030.

2. Grievance Procedure

Lubrizol is committed to sourcing raw materials ethically and responsibly. This grievance procedure outlines a process for addressing concerns related to our palm-based supply chain, ensuring prompt, fair, and transparent resolution.

Scope - Applicable to all employees, suppliers, and stakeholders involved in palm-derived supply chain.

Reporting - Stakeholders may report grievances through the Navex Global Hotline, or by contacting the Sustainability Team or the Corporate Ethics Office. Navex Global is an independent firm that provides reporting services to Lubrizol.

Corporate Ethics Office: Email: Ethics@Lubrizol.com | Phone: 1-440-347-5000
Ethics hotline (NAVEX web reporting) https://www.brk-hotline.com
International toll-free phone numbers: Refer to page 44 of the Lubrizol Code of Ethics. Lubrizol Code of Ethics - Lubrizol
Sustainability Team: InspiringSustainability@Lubrizol.com

Investigation - All grievances will be promptly investigated by an independent team. Lubrizol commits to transparent and fair resolution of all grievances, with regular updates provided to the complainant.

Resolution – Feedback will be utilized to identify areas for improvement and enhance company policies and practices.

3. Compliance with NDPE

Lubrizol recognizes the critical importance of adhering to NDPE principles to protect the environment and uphold the rights of local communities and workers. We are committed to integrating these principles into our sourcing practices. While we strive to achieve full compliance, we recognize this is a journey that requires continuous improvement and collaboration with our suppliers and stakeholders.

Non-Compliance - Lubrizol reserves the right to monitor its suppliers' sustainability performance and compliance. Suppliers not meeting Lubrizol’s standards will be encouraged to comply.

Statement on Palm Oil