Code of Conduct

Introduction
KEMET is committed to carrying out its business in a sustainable way. In order to promote the long-term interests of KEMET and its stakeholders, the company strives to maintain the highest legal and ethical standards in all its business practices. Each employee is expected to act responsibly and with integrity and honesty, and to comply with this code and its underlying policies and instructions.

Compliance with laws
All business and other activities of KEMET shall be carried out strictly in compliance with all applicable laws, and under the principles of good corporate citizenship in each country where such activities take place.

Each employee is expected to comply with the requirements of those laws and regulations that apply to KEMET’s operations and to his/her job, and with the KEMETprinciples of good corporate citizenship.

Openness
KEMET promotes openness and transparency, as well as continuous dialogue with its stakeholders, including customers and other business partners, shareholders, personnel, authorities, local communities and the media. Stock exchange rules and competitive considerations may, however, in some cases restrict such openness and transparency.

KEMET strives to be honest and accurate when communicating with its stakeholders, and KEMET employees shall make their statements in accordance with this principle.

Respect for human and labor rights
KEMET supports and respects the protection of human rights as defined in the United Nation’s Universal Declaration on Human Rights. No employee is allowed to take any action that violates these human rights principles, either directly or indirectly.

KEMET supports basic labor rights as defined by the International Labor Organization. In this respect, KEMET upholds the freedom of association and the effective recognition of the right to collective bargaining. In the case that these rights are restricted by local law, KEMET endeavors to offer its employees alternative means to present their views. KEMET does not accept any form of forced or compulsory labor, or the use of child labor.

Fair employment practices
KEMET promotes freedom from discrimination based on race, ethnic or national origin, color, gender, family status, sexual orientation, creed, disability, age or political beliefs, or other characteristics protected by law. KEMET fosters equal opportunity and employees are selected and treated on the basis of their abilities and merits.

KEMET does not accept any form of discrimination, harassment or bullying from its employees.

Occupational health and safety
KEMET endeavors to create hazard-free workplaces for its employees, contractors, and others working in various locations by applying high standards of occupational health and safety. KEMET strives to assure the safety of its products and solutions through its world-class product and solution development processes.

Each employee is responsible for complying with the safety instructions, for using personal protection equipment when required, and for reporting on any shortcomings regarding safety instructions or protection measures.

Conflicts of interest
KEMET expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of KEMET. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

Anti-corruption
No KEMET company or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favors may be considered bribery, which violates local legislation and internationally recognized principles for combating corruption and bribery.

Environment
KEMET’s target is to develop and produce for its customers environmentally advanced solutions and services that fulfill essential requirements, such as low emissions and high efficiency. Efforts are made to achieve sustainable development by means of raw material selection, processes, products, wastes, and emissions through the use of the latest technical advances. Each employee shall comply with the policies and instructions regarding environmental protection.

Relationship with authorities and local communities
KEMET maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. KEMET seeks to play a role in serving the needs of the local communities whenever possible.

Innovation and protection of proprietary information
KEMET supports and encourages innovation by its employees in all areas of its activities. At the same time, each KEMET employee must respect the intellectual property rights of others.

Accuracy of accounting records
KEMET accounting records must be accurate and reliable in all material respects. Unrecorded funds are prohibited. The records cannot contain any false, misleading, or artificial entries.

Competition and fair dealing
Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the market place, or the exchange of price or other commercial information between competitors, are prohibited. KEMET employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

Anti-fraud
KEMET does not tolerate fraudulent behavior or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

Implementation
KEMET takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. KEMETmonitors the application of this code internally. 

Suppliers and business partners are an important and integral part of the total value chain of the products and services of KEMET. They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as KEMET. KEMET promotes the application of this code by monitoring the actions of its suppliers and business partners.

In the case that questions arise regarding the interpretation of, or compliance with, this code, KEMET Legal Affairs should be contacted.

The application of the code will be reviewed from time to time by the Board of Management, which may decide on necessary revisions or interpretations.

Reporting violations
Any KEMET employee becoming aware of a potential violation of this code must contact his or her superior or KEMET Legal Affairs. The president of the respective subsidiary must be informed, unless he or she is party to the alleged violation, in which case the Group General Counsel of KEMET must be contacted. KEMET will investigate all reported matters with discretion. KEMET shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

Sanctions
Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.