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Hiring Employees of Independent Auditors Policy

Effective: 1st February 2022

Purpose

The purpose of this policy is to define a process to be utilized when the Company is considering hiring employees, former employees or close family members of employees of its Auditors, Deloitte, who work on the Company’s audit to ensure that the Company’s hiring practices do not impair the independence of the Auditors and to avoid any conflict of interest, actual or apparent, or other prohibition under any applicable laws, regulations or listing exchange standards.

Scope

This global policy applies to all RPM companies globally including wholly- and majority-owned subsidiaries.

Policy

The hiring of any employee of the Auditors, any individual that was employed by the Auditors within the last three years or close family members of employees of the Auditors must be submitted as a “Reportable Event” using the RPM Reportable Event Portal prior to an employment offer being made (Refer to the Reportable Events Policy). All such hires must be pre-approved by RPM.  An offer of employment must not be made prior to approval being received from RPM. This requirement applies to all job positions within the Company irrespective of role or department.  

How to report a suspected violation

A suspected violation of this policy can be reported to your immediate supervisor, Human Resources, or the Legal & Compliance department. Employees are also welcome to contact the Company’s Hotline to report their concerns to RPM. Allegations will be investigated thoroughly and objectively. For more information, refer to RPM’s Hotline and Non-Retaliation Policy.  Any employee who violates this Policy, including the failure to report a Policy violation, directs or who knowingly permits a subordinate to violate a Policy or who engages in retaliatory actions may be subject to disciplinary action up to and including termination.