Conflicts of interest

Strict separation of private and business interests is very important to Evonik.

Employees’ personal relationships or interests must not influence their work for Evonik. Therefore, both actual conflicts of interest and the mere appearance of a conflict of interest must be avoided. All employees are required to report actual or possible conflicts of interest to avoid potential consequences for themselves under employment law or criminal law, and to avoid harming Evonik.

CONFLICTS OF INTEREST MAY ARISE AS A RESULT OF:

	Secondary employment
	Financial interests in competitors, business partners or other companies connected to Evonik
	Business transactions and decisions involving relatives and other related parties.

Secondary employment

Secondary employment can impair Evonik's interests. Firstly, because employees have an obligation to dedicate their entire working capacity to the benefit of Evonik within their employment relationship. And secondly, because secondary employment could affect employees’ business decisions at Evonik or decisions made by third parties with regard to Evonik. As a general rule, all employees are therefore required to report any entrepreneurial activity, commercial work for a third party, or corresponding functions assumed at a third party.

This obligation also applies to employees who take on a public or political function, or undertake social, charitable or other work, unless the nature and extent of the function or work is such that it is not likely to impair Evonik's interests.

The general duty to report secondary employment and the activities outlined above apply regardless whether the employee receives remuneration or undertakes the work on a voluntary basis.

Financial interests in competitors, business partners or other companies connected to Evonik

Employees must notify Evonik of any direct or indirect financial interest exceeding 5 percent in a competitor or business partner of Evonik – especially customers, suppliers, distributors, agents, consultants, service-providers and other companies with a connection to Evonik. This obligation also applies if the financial interest is not held by the employee but by a relative or other related party (see below), provided the employee is aware of the interest held.

Business transactions and decisions involving relatives and other related parties

Employees must report all business and personnel decisions in connection with Evonik involving the following relatives and other related parties:

• Spouse
• Life partner/registered civil partner
• Parents, parents-in-law, step-parents
• Children, children-in-law, step-children
• Siblings, half-siblings, step-siblings
• Other persons living in the same household
• Other persons with whom they have a close personal and/or economic or financial relationship

WHAT ACTION IS REQUIRED IN THE ABOVE CASES?

In all three cases outlined above, employees are required to notify their supervisor and the Human Resources department in writing as soon as possible. Notification is not necessary if applicable local law conflicts with this obligation.

Employees must wait for a decision by the Human Resources department. In particular, they may not take up notifiable secondary employment, transact business, or make any related decision before they have received the consent of the Human Resources department. In the case of secondary employment, consent will be given if there is no conflict with Evonik’s legitimate interests.

Where employment contracts specify additional or other arrangements, these must be observed. This also applies to local regulations based on mandatory local law.