Fairness as a matter of principle

LUBCON GmbH is a wholly owned subsidiary of FUCHS SE. As a global lubricant group with activities in many different fields of business FUCHS is continuously competing. The international competition we face is without any restriction. In our opinion, fair competition is the basis for integrity and progress and it additionally enables opportunities and development in the market.

The guideline for the actions of each employee is to comply with the applicable laws. Management and employees are called upon without exception to comply with the applicable laws, regulations and social standards within the scope of their duties, regardless of whether this relates to state or local regulations. Unlawful behavior poses the risk of image loss, weakens our market position and is likely to cause economic damage to our company.

FUCHS has introduced a Code of Conduct in 2004, in which, inter alia, the principles of fair competition, transparency and integrity are established. Areas such as corporate governance and compliance are assigned directly to the management. The FUCHS Compliance Management System is composed of the Chief Compliance Officer and a compliance organization that supports and giving advice to people worldwide. For each country there is a unit compliance officer.

The Code of Conduct which was reissued in 2012 as well as existing for significant compliance guidelines fields—including anti-corruption and competition—constitutes a binding framework in order to ensure respect for the law and social ethics. This is completed by giving information and training and moreover, the consistent accounting and disciplinary compliance violations, a compliance hotline, regular compliance reporting as well as a special compliance audit.

FUCHS Compliance Communication

Since September 15th 2014, FUCHS has enabled access to the FUCHS Compliance Communication System through the company's website, a digital whistleblower portal. The portal is based on a standardized system solution of the Business Keeper AG and meets the highest IT security requirements. It enables users to share observations in detail and to contact the Compliance Officer. Throughout the process the user may remain completely anonymous.

FUCHS assures that at no time personal data is collected. In order to exclude that the call of the whistleblower system can be traced you will not find a direct link to the portal, but an Internet address. Please copy this fully into the address line of your browse:

www.bkms-system.net/FUCHS-Compliance-Communication

FUCHS has given itself Rules of Procedure which summarize the principles and the process of the whistleblower mechanism. The Rules of Procedure can be found here: Rules of Procedure

Alternatively, you have the option to report your concerns to the appropriate external authorities. However, FUCHS encourages you to first contact us internally before reverting to the external authorities, as our experience shows that reports are typically resolved more quickly and effectively this way.

In Germany, there are several external reporting authorities available: The Federal Office of Justice (BfJ), the Federal Cartel Office (BKartA), and the Federal Financial Supervisory Authority (BaFin). The primary point of contact is usually the Federal Office of Justice. Please follow the provided link to learn more about the external reporting mechanism and the jurisdictions of these external authorities (only available in German).

BfJ - Hinweisgeberstelle (bundesjustizamt.de)