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FMC Code of Ethics & Business Conduct

FMC’s Code of Ethics and Business Conduct summarizes the legal and ethical principles that we follow in our daily work. FMC’s commitment to the Code starts at the corporation’s highest level. The FMC Corporate Responsibility Committee manages FMC’s overall compliance with applicable laws and FMC policies (including the Code) and compliance training. This committee consists of our chief executive officer, chief financial officer, executive vice president of human resources, executive vice president and general counsel, vice president and chief compliance officer, and one of our business presidents. The group also considers the appropriate response to significant ethics and compliance matters. The Committee reports to the Audit Committee of the FMC Board of Directors.

In 2016, FMC created the new position of Chief Compliance Officer (CCO). The FMC Board appointed Michael Reilly, Vice President, Associate General Counsel and Chief Compliance Officer. As FMC further extends our global reach, the CCO will design new programs to strengthen employee understanding of business ethics and continue to ensure compliance with applicable laws in every region of the world.

Every new FMC employee receives ethics compliance training, followed by regular recertification (approx every three years) to ensure understanding of and adherence to our Code of Ethics. The Code recertification process for all employees was conducted during 2016.

FMC employees worldwide are encouraged to report suspected violations of the FMC Code and other legal or ethical violations through a confidential and anonymous system managed by Global Compliance, a leading provider of outsourced governance, risk management and compliance services. Employees can contact Global Compliance 24 hours a day, 7 days per week either by phone, web or mail. Global Compliance provides multi lingual service and has trained staff to handle ethics calls.

It is FMC policy to investigate any reported violation of the Code, other FMC policies, or applicable laws, and to take appropriate action based on the results of the investigation. It is also FMC’s policy that every employee may report violations with no fear of retaliation by co-workers, supervisors, or others.