Revised August 10, 2023

HUMAN RIGHTS POLICY

At RPM, our ethical philosophy is embodied in our Code of Conduct, the Values and Expectations of 168. These values come to life through motivated associates who enjoy their work and create conditions that enable each of them to grow and our stakeholders to prosper. Without those who participate in making or providing our products and services, we would not be able to accomplish our goal of Building a Better World.

For these and other reasons, we remain committed to conducting business ethically and responsibly, respecting and promoting human rights and safe working conditions, and opposing human trafficking and exploitation. RPM embodies these values by:

• Implementing policies and guidelines requiring equal opportunities and prohibiting discrimination, harassment, and child and forced labor;
• Complying with applicable health and safety and wage and hour laws;
• Taking steps to ensure healthy and safe working environments, internally and with respect to our suppliers;
• Evaluating and selecting our service providers and suppliers and expecting them to operate in accordance with our core values set forth in the Values and Expectations of 168 and  adhere to our Supplier Code of Conduct;
• Undertaking due diligence efforts as part of our evaluation of potential suppliers, including with regard to labor and health and safety practices;
• Providing online and in-person education to our supply-chain managers on the topics of child and forced labor, human trafficking, and the identification and mitigation of associated risk;
• Respecting our employees’ right to freedom of association and collective bargaining in accordance with local laws; and
• Offering a reporting Hotline where individuals can report any ethical or employment concerns without fear of retaliation.

We also support:

• The U.N. Guiding Principles for Business and Human Rights which respects and honors the principles of internationally recognized human rights;
• Those rights expressed in the International Bill of Human Rights (e., Universal Declaration of Human Rights and the International Covenants on Economic, Social and Cultural Rights and Civil & Political Rights);
• The principles concerning fundamental rights as set out in the International Labor Organization (ILO) Declaration on Fundamental Principles and Rights at Work; and
• Access to safe drinking water and sanitation, derived from the right to an adequate standard of living under Article 11(1) of the International Covenant on Economic, Social and Cultural Rights.

A suspected violation of human rights may be reported to a supervisor or to the applicable Human Resources, Legal or Compliance departments. A suspected violation may also be reported through the Company’s Hotline. Questions related to our human rights efforts can be addressed to sustainability@rpminc.com.