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Safe Harbor Policy

I. Overview

Ingevity’s privacy and information security program includes numerous policies and procedures designed to maintain the confidentiality of Personal Information within its possession. Among these policies is this Safe Harbor Privacy Policy.

Ingevity complies with the U.S.-European Union (“EU”) Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland.

Ingevity has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement as described in Section IV below. For more information on the Safe Harbor framework, visit: http://www.export.gov/safeharbor/.

This policy describes Ingevity’s commitment to privacy and to each of the Safe Harbor Privacy Principles.

II. Scope of the Policy

This policy applies to all Personal Information received, accessed, processed or stored by Ingevity.

III. Definitions

“Business partner” includes any person or entity with whom Ingevity does business, including but not limited to vendors, customers, suppliers, contractors and temporary workers.

“Employee” means any current or former employee of Ingevity.

“Personal Information” is information pertaining to Employees and Business Partners that: (1) is transferred between the EU or Switzerland and the U.S., (2) is recorded in any form, (3) is about, or pertains to a specific individual, and (4) can be linked to that individual.

“Safe Harbor Principles” are the Safe Harbor Privacy Principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.

“Sensitive Personal Information” is Personal Information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

IV. Safe Harbor Privacy Principles

NOTICE

Ingevity informs Employees and Business Partners, including those located in the EU and Switzerland, about the purposes for which it collects and uses their Personal Information, the types of non-agent third parties to which Ingevity may disclose that information, the choices Employees and Business Partners have as well as the means for limiting the use and disclosure of their Personal Information, and how to contact Ingevity with questions and comments regarding Personal Information. Notice is provided in clear and conspicuous language when Employees and Business Partners are first asked to provide Personal Information to Ingevity, or as soon as practicable thereafter, and in any event before Ingevity uses or discloses the Personal Information for a purpose other than that for which it was originally collected.

CHOICE

Ingevity does not use Personal Information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant Employees and Business Partners of such uses and offering an opportunity to opt out.

Ingevity will not disclose Personal Information without first giving the relevant Employees and Business Partners an opportunity to opt-out except when the disclosure is: (i) to service providers Ingevity has retained to perform services on its behalf, (ii) required by law or legal process, (iii) to law enforcement authorities or other government officials, or (iv) necessary and appropriate, in Ingevity’s estimation, to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. To opt out, contact the Ingevity Global Privacy Office (contact information provided below).

ONWARD TRANSFER OF PERSONAL INFORMATION

Ingevity will ensure that any third party to which Personal Information may be disclosed is either Safe Harbor-certified, subject to laws based on the EU Data Protection Directive or the Swiss Federal Law on Data Protection of 1992, or contractually agrees to provide at least the same level of protection for Personal Information as required by the relevant Safe Harbor Principles.

ACCESS

Ingevity provides its Employees and Business Partners with reasonable access to the Personal Information Ingevity maintains about them. Ingevity also provides Employees and Business Partners a reasonable opportunity to correct, amend or delete that information where it is inaccurate. Ingevity may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles.

DATA SECURITY

Ingevity maintains reasonable and appropriate administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Ingevity cannot guarantee the security of Personal Information on or transmitted via the Internet.

DATA INTEGRITY

Ingevity takes reasonable and appropriate steps to ensure that Personal Information it collects is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. Ingevity relies on its Employees and Business Partners to update and correct their Personal Information whenever necessary.

ENFORCEMENT

Ingevity uses a self-assessment approach to assure compliance with this policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Safe Harbor Principles. Interested persons may raise concerns using the contact information provided below. Ingevity will investigate and attempt to resolve any complaints or disputes regarding its use and disclosure of Personal Information in accordance with the Safe Harbor Principles.

For EU and Swiss Employees and Business Partners, if a complaint or dispute cannot be resolved through our internal process, Ingevity will cooperate with, and submit the dispute for resolution to, the relevant EU data protection authorities or Swiss Federal Data Protection and Information Commissioner.

AMENDMENTS OR UPDATES TO THIS POLICY

Ingevity may periodically update this Safe Harbor Privacy Policy, consistent with the requirements of the Safe Harbor principles. Revisions to the policy will be posted here on this web page. The date on the top of this page indicates the effective date (and most recent revision date) of the policy.

INFORMATION SUBJECT TO OTHER POLICIES

Ingevity is committed to following the Safe Harbor Principles for all Personal Information within the scope of the Safe Harbor Agreement. Certain information, however, is subject to Ingevity policies that may differ in some respect from the general policies set forth in this Safe Harbor Privacy Policy.

CONTACT INFORMATION

Questions, comments or concerns regarding Ingevity’s Safe Harbor Policy or the Company’s data collection and processing practices with respect to Personal Information can be addressed by sending an email to ingevity_global_privacy_office@ingevity.com or in writing to:

Ingevity
Global Information Privacy Office
5255 Virginia Avenue
North Charleston, South Carolina 29405
USA