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To: NCH Associates

From: NCH Board of Directors (Irvin, Ann, John, Lester Jr., Robert, and Walter Levy)

Subject: NCH COMPLIANCE POLICY STATEMENT

NCH has successfully conducted business since 1919 because it sells quality products and services that

deliver value to our customers. NCH cares deeply about our customers and strives for customer retention

and satisfaction. Our Company philosophy has always been to conduct business legally with honesty

and integrity.

This is summed up in our Corporate Philosophy, instituted over 45 years ago, which states:

It is our policy and the responsibility of every associate to conduct NCH's affairs in compliance

with the law and in accordance with correct ethical standards.

NCH and its Board of Directors still firmly believe in that statement and have always provided you with

resources to ensure full compliance with our philosophy and the law. This includes the Legal

Department, the Regulatory Affairs Department and the Human Resources Department.

To enhance the Company’s long-standing efforts to prevent bribery and corruption, NCH Corporation has

established a Compliance Department, which will report directly to the Board of Directors. The Board is

pleased to announce that the Compliance Department will be led by Wilbur Gregory, who has 29 years of

experience with the FBI, both as a special agent and an attorney. Wilbur will join NCH on January 2,

2014.

The Compliance Department will have primary responsibility for the operation of our Anti-Corruption

Compliance Program. This program will include policy creation and distribution, training, monitoring,

auditing and due diligence on certain third parties. The purpose of the program is to ensure that our

Corporate Philosophy and our policies are followed. The Compliance Department has the full support

and approval of the Board of Directors and Senior Management. Compliance is everyone’s job. Thus,

the Board expects that every NCH Associate will comply with our policies, and will ensure that their

colleagues and subordinates understand and follow them as well.

As an integral part of the Corporate Philosophy, NCH has a zero tolerance policy on corruption and

bribery. Bribery is providing a payment or other items of value to induce someone to do something illegal

or against their company’s interest. It therefore violates the central tenet of the relationship that NCH

wants with its customers.

Further, corruption and bribery are wrong morally and legally. The US Foreign Corrupt Practices Act, the

UK Bribery Act and other laws prohibit bribes, no matter whether the bribes are paid directly or indirectly,

such as through business partners, consultants or distributors. Such laws can carry harsh penalties for

both you and the Company, including fines and imprisonment.

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To help both you and the Company avoid these harsh penalties and to ensure that NCH conducts

business in strict compliance with its Corporate Philosophy, the Board of Directors has directed the

distribution of several new and/or revised global policies to all NCH Associates. These include:

(1) Business Courtesies Policy;

(2) Promotions Policy; and

(3) Third-Party Anti-Corruption Due Diligence Policy.

As these policies exist to protect you and the Company, please take the time, effort and care to read,

understand and follow these policies. NCH and its Board require that you fully follow these policies. If you

have any questions or concerns about the policies or a particular situation, please contact the

Compliance Department through email at compliance@nch.com. Because violations of these policies

could result in significant consequences for you and the company, it is important to be safe and prudent.

Regards,

NCH Corporation Board of Directors