COMPETING VIGOROUSLY
& FAIRLY

At Celanese, we differentiate ourselves from our competitors through
our commitment to generating customer value. While we compete
vigorously in the marketplace, we always compete fairly. This means
that we comply with competition laws everywhere we do business.

INTRODUCTION: ETHICAL ADVANTAGE

MESSAGE FROM OUR CHIEF OPERATING OFFICER, SCOTT SUTTON

Transcript

Hi everybody, I'm Scott Sutton. I'm really glad to be here today to talk to you about competition laws because at Celanese we deliver strategies that create value for our shareholders and we create innovation with our customers that delivers tremendous value to them as well. But it's not a matter of how much of that we do, it's really about how we do that. At Celanese we really do run unique business models and we run a unique supply chain as well, but how we go out and get that business and how we compete vigorously is very important.

Competition laws promote open competition in the marketplace and protect consumers from unfair practices. As a global company, we're subject to the competition laws in every country where we do business. This means that we have to establish our prices and other commercial terms independently, without agreements or coordination with our competitors. As we do business, we gather competitive intelligence, but always through proper channels – we never get that directly from a competitor.

Open communication is key, so if you have any questions or concerns about competition law, please talk with a Celanese lawyer or any member of our executive management team. It's up to all of us to ensure that we conduct business ethically and lawfully.

We're all responsible for working with integrity and protecting each other and the company. Because how we do business really does matter.

OUR COMMITMENT TO COMPLIANCE

Celanese is committed to operating with integrity and in compliance with all applicable laws and internal policies. This commitment applies to competition laws (also known as antitrust laws), which are designed to promote fair and honest competition and to protect customers and competitors from anti-competitive conduct.

The purpose of this Competition Law Guide is to establish policies and guidance for complying with competition laws. This will help you to understand basic competition law issues and recognize situations that may present competition law concerns. Seek guidance from the Law Department if you have questions about competition law or the requirements of this Guide.

MESSAGE FROM OUR CHIEF COMPLIANCE OFFICER, REBECCA STARK

Transcript

At Celanese we're committed to working with integrity, following our company policies, and complying with the law. We win business because of the quality of our products and the solutions we bring to our customers….never by competing unfairly or violating the law.

Competition laws, also known as antitrust laws, are intended to protect consumers from unfair practices. Every Celanese director, officer, and employee is responsible for complying with these laws wherever we do business.

As you conduct business each day, use the Celanese Competition Law Guide as a resource. It will help you understand your role in ensuring that our commercial activities are in compliance with applicable competition laws. This interactive Guide is organized by topic, so you can easily find information relevant to your situation. This Guide may not address every specific situation, but it does explain our philosophy in a way that will help you identify potential antitrust concerns and determine the best way to proceed.

If you ever have questions about this guidance, please contact the Law Department or any member of our senior management team. If you believe that conduct is taking place that is inconsistent with this guidance, please contact me directly.

We also have a helpline that you can use to raise concerns, and if you feel more comfortable remaining anonymous, you may certainly do so. We take all of your concerns seriously and we look into every concern that is raised. We do not tolerate any retaliation for raising issues in good faith.

We should all be proud to work for a company that wins business through vigorous, fair, and honest competition. Because how we do business really does matter.

Thank you for your time and commitment to compliance.

CONSEQUENCES OF MISCONDUCT

Competition laws, also known as antitrust laws, are complex and carry harsh penalties. Celanese and its employees, officers, and directors are subject to the policies in this Guide and must comply with all applicable laws governing competition in every jurisdiction where Celanese does business.

Compliance with our competition law policy is a condition of employment. We will take appropriate disciplinary action, which could include termination of employment, for breaches of our competition law policy. In some circumstances, if an employee has violated a law, Celanese may notify relevant authorities. This could result in fines or even imprisonment as the result of criminal prosecution.

GO BACK

ETHICS HELPLINE

If you need to discuss an issue, the best place to start is often with your Supervisor.

They know your situation; they can direct you to resources, help you with procedures, and lend immediate support. But you can always reach out to our Celanese Leaders, HR Partner, or Chief Compliance Officer.

The Ethics Helpline is always available to you to raise your compliance concerns confidentially or anonymously. It's necessary to report certain compliance issues (bribes, price fixing, and failures of financial integrity) to the Chief Compliance Officer or the Ethics Helpline because they can result in serious consequences.

Read the Celanese Non-Retaliation Policy

Celanese will not permit retaliation for providing information regarding any conduct which you reasonably believe constitutes a violation of our Business Conduct Policy, any applicable law, or for participating in an investigation.


The Ethics Helpline

All Ethics Helpline calls are confidential and, if you like, you can raise concerns anonymously.

1.866.384.4223
(866-ethic ce)

INTERNATIONAL NUMBERS* (toll free)


Country AT&T Direct ®
Belgium 0-800-100-10 Brazil 0800 890 0288 China, PRC 108-11 France 0805-701-288 Germany 0-800-2255-288 Hungary 06 800-01111 India 000-117 Italy 800-172-444 Japan 00 539-111 Mexico 01-800-288-2872 Netherlands 0800-022-9111 Russia 363-2400 Singapore 800-0111-111 Spain 900-99-00-11 Sweden 020 799 111 U.K. 0800-89-0011

*1. AT&T Direct® for your country
2. Wait for tone
3. Then 866-384-4223

More AT&T Direct® numbers can be found here.