ABOUT THE ETHICS HOTLINE

What is the Chemours Ethics Hotline and why use a third-party?

The Chemours Ethics Line is a service provided by the company that allows anyone — employees, customers, suppliers, or members of the general public — to ask questions, raise concerns or report potential ethical violations, or follow up on questions or concerns about ethical issues which they have already raised.

The Chemours Ethics Hotline is operated by NAVEX Global, an independent company. We use an independent company to operate the Chemours Ethic’s Hotline to give employees an added level of comfort and security that their reports will remain confidential.

Why do we need the Chemours Ethics Hotline?

  • We believe that our employees are our most important asset. By creating open channels of communication, we can promote a positive work environment and maximize productivity.
  • An effective reporting system is critical to and supports our other efforts to foster a culture of integrity and ethical decision-making.
  • In addition, as a publicly traded company, we are required by law to have an anonymous reporting vehicle to address accounting and auditing fraud directly to the Audit Committee.

ABOUT REPORTING

May I report using either the Internet or the telephone?

Yes. With NAVEX Global, you have the ability to file a report by telephone or the Internet.

You can file an NAVEX Global report from any computer that can access the Internet. You can file from home. Many public locations, including most public libraries, have Internet computers. If you don’t have access or are uncomfortable using a computer, you can call the NAVEX Global toll-free hotline which is available 24 hours a day, 365 days a year. Dialing instructions vary by country; verify the proper dialing instructions with a local team member.

What type of situations should I report?

The NAVEX Global system is designed for employees to report any violation of the Chemours Code of Conduct, our values, suspicious activity or other concerns you may have. Please provide as much detail as possible and check back through the portal frequently.

I am not sure if what I have observed or heard is a violation of company policy or involves unethical conduct, but it just does not look right to me. What should I do?

File a report. If you want assistance in preparing and filing your report so it can be properly understood NAVEX Global can help you. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go unchecked.

What if you have questions for me concerning my report?

The NAVEX Global system allows company representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue will help ensure situations can be resolved, even if they’re complex.

If I see a violation, shouldn't I just report it to my manager, human resources and let them deal with it?

When you observe some behavior, you believe violates our Code of Conduct, we expect you to report it. You certainly can bring any concerns forward to management, Human Resources, your Ethics Champion or Ethics & Compliance. We recognize, however, that there may be circumstances when you are not comfortable reporting an issue in person. That is why we have partnered with NAVEX Global. We would rather you report anonymously (where permitted by local laws) than keep the information to yourself.

Does management really want me to report?

Absolutely. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Unshakable Integrity is a critical, cornerstone value of our company. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. Just look at news reports about recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and to your coworkers to report it.

We all want to work in a positive environment. We all also have the responsibility to act in an ethical manner. That includes speaking up and letting the right people know if someone is not acting appropriately. By working together, we can maintain a healthy, productive and positive environment. Unreported misconduct can threaten the livelihood of an entire company.

SECURITY & CONFIDENTIALITY

Can I file a report from anywhere, by telephone or Internet, and still remain anonymous?

A report from home, work, a neighbor’s computer, or any Internet portal will remain secure and anonymous, where permitted by local laws. This internet portal never identifies a visitor by screen name and the NAVEX Global system strips away identifying information, such as an IP address, so that anonymity is maintained. NAVEX Global is prohibited from pursuing a reporter’s identity. Hotline-based reports have the same security and confidentiality protection as telephone toll-free hotline reports.

I am concerned the information I provide will ultimately reveal my identity. How can you assure me that will not happen?

The NAVEX Global system is designed to protect your anonymity. NAVEX is prohibited from trying to determine a reporter’s identity. To further ensure your anonymity, you should be careful not reveal any identifying details as part of your report. For example, “from my cube next to Jan Smith … ” or “in my 33 years of working at this plant… ”

Where do these reports go? Who can access them?

Reports are entered directly to a NAVEX Global secure server to prevent any possible security breach. NAVEX Global makes these reports available only to specific individuals within Chemours who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has been trained in protecting the confidentiality of these reports.

I am concerned about negative consequences to me if I make a report. If I feel that I have been the victim of retaliation as the result of my report, what should I do?

Chemours has a strict non-retaliation policy. We expect the highest standards of conduct from the Chemours community and we expect every employee to speak up and inform the appropriate parties if they have observed or experienced harassing, unethical, illegal or suspicious activity. Chemours prohibits retaliation against anyone who reports or seeks guidance on possible ethical, harassment or compliance issues in good faith. Please report any suspected retaliation immediately through any of the channels listed above, including the Hotline.

TIPS & BEST PRACTICES

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The NAVEX Global system and report distribution protocols are designed so implicated employees, including manager are not notified about or granted access to reports in which they have been named. The only exception is in countries where implicated parties are required to be notified by law.

What if I remember something important about the incident after I file the report?

When you file a report, either using the Internet or through the toll-free telephone hotline, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX Global system again, either by internet or telephone, and access the original report. At that point, you can add more details.

Are these follow-ups on reports as secure as the first one?

Yes. All NAVEX Global correspondences are held in the same strict confidence as the initial report, and have the same anonymity, if you choose (and where permitted by local laws).

What should I do if the telephone number is not working?

If the telephone number listed above is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.

What should I do if the country I am in is not listed in the drop down boxes?

If there is no telephone hotline number listed for your location, please make your report online through this web site. Please indicate in the report that telephone instructions for your country location were not available.