Tronox Alkali Purchasing Values

Tronox Alkali Corporation Supplier Code Of Conduct - April 2015

Diversity

Tronox Alkali believes it is vital to support the diverse supplier community through its business establishments. By doing business with innovative and fully competitive minority and female owned suppliers, we are strengthening these communities and benefiting Tronox Alkali.

Responsible Sourcing

Tronox Alkali works to identify and do business with suppliers who aspire to conduct their business in an ethical and responsible manner that supports and respects the protection of responsible sourcing.

Responsible Sourcing Expectations for Tronox Alkali's Suppliers

Tronox Alkali is committed to conducting our business in an ethical and responsible manner that supports and respects the protection of human rights. We will work to identify and do business with suppliers who aspire to conduct their business in a similar manner. Accordingly, Tronox Alkali expects our business partners to embrace values and standards similar to those listed below:

• Tronox Alkali strives to treat all employees with respect. Tronox Alkali refrains from using corporal punishment, violence or threats of violence or other forms of physical coercion or harassment.
• Tronox Alkali will not work with suppliers who use forced or involuntary labor of any type and Tronox Alkali will not tolerate the trafficking or involuntary servitude of any worker.
• Tronox Alkali opposes the exploitation and endangerment of children. Tronox Alkali encourages the protection of children from work that is dangerous or that might harm their health or their education. The term "child" refers to any individual under the minimum age for employment established by law in the jurisdiction where the work is performed.
• Tronox Alkali expects that its suppliers will not discriminate in their hiring and employment practices on grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, marital status, pregnancy, political affiliation, disability or other factors as mandated by applicable law.

On January 1, 2012, the California Transparency in Supply Chains Act of 2010 (SB 657) went into effect, requiring retailers and manufacturers above a certain size doing business in California to disclose measures used to track possible slavery and human trafficking in their supply chains. The disclosure is aimed at providing information to consumers, allowing them to make better, more informed choices about products they buy and the companies they support.

In early 2011, Tronox Alkali formed a global procurement organization to oversee the sourcing of goods, materials and services for Tronox Alkali on a worldwide basis. This global procurement organization has the responsibility to qualify and manage Tronox Alkali's suppliers and to address potential risks in Tronox Alkali's supply chain.

This supplier selection process sets forth Tronox Alkali's plans to qualify all suppliers prior to engaging in business with such suppliers, and includes specific processes to ensure that Tronox Alkali is doing everything in its power to eradicate human trafficking and slavery in its supply chain.

The supplier selection process is consistent with Tronox Alkali's position on supporting and respecting the protection of human dignity around the world. Accordingly, Tronox Alkali includes a formal process as part of its supplier selection process that establishes standards for its suppliers in the areas of labor and human resources, environmental, health and safety and supplied materials. These standards apply to the selection and retention of suppliers that provide goods or services to Tronox Alkali worldwide and establishes a framework that Tronox Alkali considers important to a safe and healthy workplace, and to the maintenance of fair and reasonable labor and human resources practices (including slavery and human trafficking).

Tronox Alkali began worldwide training on the supplier selection process for its global procurement team to ensure that the team understands the importance of the supplier selection process and only engages with suppliers who are qualified and approved in accordance with this process.

Tronox Alkali's Conflict Minerals Statement

Tronox Alkali is committed to sourcing components and materials from companies that share our values regarding respect for human rights, integrity and environmental responsibility. Tronox Alkali is committed to complying with Section 1502 of the Dodd-Frank Act, which aims to prevent the use of minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo (DRC) or in adjoining countries ("conflict minerals").

Suppliers to Tronox AIkali are required to commit to being or becoming "conflict-free" (which means that such supplier does not source conflict minerals) and sources only from conflict-free smelters. Supplier's to Tronox Alkali that are providing 3TG's are required to provide completed EICC-GeSI declarations evidencing such supplier's commitment to becoming conflict-free and documenting countries of origin for the tin, tantalum, tungsten, and gold that it purchases.

Tronox Alkali Commitment to Sustainability

At Tronox Alkali, sustainability is more than an environmental initiative and far more than feeling good about our efforts to do the right thing. It is the basis for sustaining our future and our valuable relationships with our customers, suppliers, employees, and the people who live and work in the communities where we operate.

Tronox Alkali uses Global Reporting Initiative (GRI) as a framework and focus areas are on innovation, operations, and business practices. We are measuring in the following areas:

Operations

• Water Use (gal/ton of product produced)
• Energy Use (mmbtu/ton product produced)
• GHG Emissions (ton/ton of product produced)
• Waste (Ton of hazardous and non-hazardous, on and off site/ton of product produced)

Responsible Care

Tronox Alkali practices the principles of Responsible Care at its facilities and supports the efforts of others throughout the supply chain to do so, too.