Ethics & Governance

Ethically Operated and Governed Responsibly

Integrity is one of Calumet’s core Values and guides our culture of compliance. The cornerstone of our Compliance & Ethics Program is our Code of Business Conduct & Ethics. Our Code sets forth our commitment to high ethical standards, and all employees are required to annually acknowledge their commitment to comply with the Code.

In addition to our Code of Business Conduct & Ethics, employees are required to annually certify three other key compliance policies:  the Conflicts of Interest Policy, the Whistleblower & Non-Retaliation Policy, and the Vendor Code of Conduct. Together with the Code, these four Compliance documents are the foundation of our Compliance & Ethics Program.

Employee certifications are monitored by the Corporate Compliance Officer, and certification status is presented regularly to the corporate Compliance Committee and to the Audit and Finance Committee of the Board of Directors. Individuals with overdue certifications are notified and reminded of their compliance obligations, and continuously overdue certifications are escalated to the appropriate supervisors.

Governance

Effective Oversight

A key element of our Compliance & Ethics Program is effective oversight of the compliance activities across the company. Each quarter, the Corporate Compliance Officer presents a detailed update on our Compliance & Ethics Program to the corporate Compliance Committee. The Corporate Compliance Officer also separately provides a compliance report to the Audit and Finance Committee of the Board of Directors. The Board has charged its Audit and Finance Committee to provide Board-level oversight over our Compliance & Ethics Program, and the Corporate Compliance Officer has a direct reporting relationship into that Board Committee.

Continuously Improving Our Ethics & Compliance Program

Compliance Committee

We have a dedicated Compliance Committee made up of a cross-section of senior leaders of the company. It is chaired by our Corporate Compliance Officer. This Committee monitors and evaluates the performance of our Ethics & Compliance Program, and it meets quarterly to discuss the status of the Program and opportunities for improvement.

Compliance Bulletin

The Corporate Compliance Officer regularly distributes company-wide compliance bulletins to educate employees about hot topics in compliance.

Ethics Helpline

We encourage our employees to operate under the philosophy of “If you see something, say something — SPEAK UP.” Our Ethics Helpline, which operates 24 hours a day, seven days a week, gives anyone connected to Calumet a tool to communicate their concerns.

All reports to the Ethics Helpline are confidential, and callers may remain anonymous at their request. Every report is reviewed thoroughly to ensure appropriate action is taken, and we strive to address all
reports within 60 days.

Ensuring Compliance

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Compliance Scorecards

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Documents & Training

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Clear
Priorities

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Quarterly Bulletins

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Visible
Program

Anti-Corruption Compliance

One of our Compliance Functional Areas is anticorruption. We have documented our commitment to anti-bribery and anti-corruption in our Anti-Bribery & Corruption Policy. All employees are required to certify their commitment to this policy on an annual basis.

Further, we have developed and implemented processes that regularly scrutinize all international business partners based on economic sanctions guidance, denied-parties listings, and other sources of international business risk. Business partners that present as higher risk are subjected to greater levels of scrutiny and additional approvals are required prior to onboarding. We have procedures in place that prohibit us from doing business in
embargoed countries.

Risk Committee

The Risk Committee of the Board of Directors separately monitors and provides oversight to all of the risks that relate to Calumet’s businesses. As part of that role, the Risk Committee provides oversight of Calumet’s annual enterprise-wide risk assessment, which separately considers all risks related to Calumet, including Ethics & Compliance risks.

The Risk Committee works with senior management on plans to effectively manage and mitigate identified risks.

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