Administering the Trinseo Ethics and Compliance Program

We take great care to ensure proper administration of the Trinseo Ethics and Compliance Program. Key elements in this process include executive oversight, protection of those reporting potential violations, employee training resources, and an ethics and compliance hotline.

Administration
Trinseo’s Associate General Counsel and Chief Compliance Officer chairs the Trinseo Ethics and Compliance Committee, which reports to the Audit Committee of Trinseo’s Board of Directors and is comprised of 11 senior Trinseo executives who represent diverse functions and geographies.

This committee:

• Is responsible for the oversight and management of the Trinseo Ethics and Compliance Program
• Reviews and, when necessary, modifies or updates the Trinseo Code of Business Conduct and its supporting policies on an ongoing basis
• Oversees the responses to any ethics or compliance reports or questions
• Conducts or monitors any investigatory activity
• Assists in communicating the Trinseo Ethics and Compliance Program to employees and the public

Reporting Approach
Most Trinseo employees embrace the company’s high ethical standards. Occasionally, however, individuals may act in a way that reflects poorly on Trinseo and its people.

Trinseo encourages employees who know or suspect that a legal or ethical violation has occurred or is taking place to speak up and report the situation.

Trinseo has zero tolerance for any reprisal or retaliation against a person who reports a known or suspected violation in good faith. Trinseo will take disciplinary action, up to and including termination of employment, against any employee involved in threatened, attempted, or actual retaliation.

Employee Training and Communication
We provide periodic updates on Trinseo compliance efforts using various internal communications tools, such as:

• News stories and Intranet content
• Trinseo Ethics and Compliance Program presentation available for leaders to use in their work groups
• Web-based ethics and compliance training module for employees

Trinseo Ethics and Compliance Hotline
Trinseo has contracted with NAVEX Global ‒ a worldwide leader in ethics and compliance programs ‒ to provide a hotline, which allows anonymous reporting of ethics and compliance concerns or allegations where legally possible. Any individual inside or outside the company who has a concern about ethics and/or compliance at Trinseo is encouraged to report the issue.