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Matt Lepore, SVP, General Counsel & CCO, BASF Corporation

Strong Communication and Collaboration required for Effective Compliance

Companies face a variety of emerging compliance challenges ranging from the need to have strong anticorruption measures to ensuring compliance with variousdata protection laws as technology evolves. One of the most basic challenges for large companies today is ensuring that a company’s compliance program keeps pace with our ever increasingly interconnected world. An effective global compliance program requires strong lines of communication and collaboration among the compliance team, corporate functions and businessunits in all the regions where your company operates.

"It is important for business partners to understand each other’s core values,competencies and goals"

Our Compliance Program in North America is a part of the BASF Group’s Global Compliance Program. We closely partner with our colleagues around the world to ensure that we operate to the highest legal and ethical standards. To ensure this consistency, the BASF Group replaced its twenty-four regional Codes of Conduct with one Global Code of Conduct, while also allowing each region flexibly to address legal requirements that are unique to their particular region.

The BASF Group’s Global Compliance Team meets on a regular basis to discuss trends, emerging areas, initiatives and experiences in their respective regions. We always respect the variations in local laws, but look for consistent solutions that can be applied in the numerous countries in which we operate. Strong and open lines of communication among our regions are imperative to a high functioning compliance team around the world.

Strong communication and collaborationare also required here in North America. In the United States, we are subject to various federal regulations ranging from the labeling of products to the physical security of our chemical plants (e.g. Chemical Facility Antiterrorism Standards). Ensuring compliance in these areas requires that members of the Legal Department, and the the compliance team work closely with our internal business units and other corporate functions.

Maintaining Transparency with Business Partners

Communication and collaboration do not end at our four walls. We believe that strong externalrelationships based on communication and transparency iscritical when dealing with our business partners. It is important for business partners to understand each other’s core values, competencies and goals. We encourage an open dialogue with our business partners.

As part of this transparency, we make clear to our suppliers that they must commit to BASF’s Supplier Code of Conduct or have their own Codes, which embrace the principles within the Supplier Code of Conduct. Similarly, in our contractual agreements, we require that our business partners comply with the laws where they operate and embodysimilar ethical values to BASF. We encourage our business partners to contact us early if they have any concerns they wish to discuss.

Embedding Compliance in Business

As reflected in our motto “We create chemistry,” BASF is a company that is based on innovation. We strive to ensure that our compliance program stays ahead of the risks associated with the drive for innovation, including the need to protect our valuable intellectual property rights. We see both opportunities and challenges presented by technology. A simple example is that we promote the use of social media to encourage ideas and discussion about emerging areas. However, we have policies and training courses to remind employees not to post or disclose any confidential and proprietary information on social media outlets.

Our employees are essential toensuring that compliance is embedded in businesses. The people within a business must truly understand and embrace legal and ethical principles for compliance to become part ofhow they do business. They must see their leaders at all levels of the organizationlivethese principles whencarrying out their work and interacting at BASF.

Training, another form of communication,is fundamentaltobridging any gap between compliance and emerging risks created by new technology. We balance inperson and online training to provide our employees with key legal and ethical principles that touches their work and highlights BASF’s strong commitment to compliance. Each year we design our training curriculum and select topics based on a combination of risks we see emerging through our own experiences and industry-wide. We gain this knowledge through compliance reviews, feedback from our businesses and corporate functions, analysis of calls/submissions within our internal Compliance Hotline and other avenues, the exchange of information with our regional Compliance Officers around the world and monitoring key trends in compliance.

Advice to fellow CCOs

A Compliance Officer needs to understand his/her businesses (including the opportunities and challenges presented by technology) and where the businesses are headed to stay ahead of compliance risks. With this information, the Compliance Officer can provide guidance to ensure the businessescreate and market their products in an ethical, compliant and sustainable manner. Staying connected with your internal stakeholders, including the business units and other corporate functions, is critical to maintaining an effective compliance program.