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Policy Statement on Responsible Sourcing of Minerals

The U.S. Securities & Exchange Commission (SEC) has adopted rules regarding the reporting and disclosure by manufacturers of their sourcing of certain minerals identified as “conflict minerals”. The mining and sale of conflict minerals and their refined metals- tantalum, tin, tungsten and gold- have been linked to the financing and benefit of armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo (DRC) and adjoining countries.

Hexion Inc. supports the efforts of governments and organizations aimed at ending the violence and human rights violations in the DRC. Accordingly, we have initiated a process to obtain information from our suppliers regarding their sourcing of conflict minerals that are used in the manufacturing of some of our products. Based on the information provided by our suppliers to date, we are not aware that our supply chain contains any conflict minerals sourced from the DRC or adjoining countries. If we discover that a supplier of ours is sourcing minerals that are not conflict-free from that region, we will take appropriate actions.

Our Supplier Code of Conduct sets forth our position on conflict minerals. We expect our suppliers and third parties to conduct business in accordance with our high ethical standards, including the practice of responsible sourcing of materials.

We will disclose our progress in implementing our conflict minerals policy though public reporting, including on our website, in our sustainability report, and through SEC filings.