At RPM, we believe in doing the right things, the right way, for the right reasons. This commitment to ethical behavior is deeply ingrained in our corporate structure and is fundamental in our approach to business. Our compliance and ethics program is shaped by The Value of 168^® - the idea that there are 168 hours in a week, and we must use those hours in ways that do the most good, because doing the right thing is good business.

RPM maintains the following policies to uphold our commitment to ethical conduct.

• Code of Conduct and Ethics: Our comprehensive code of conduct guide, “The Values & Expectations of 168,” identifies who we are and what we expect of ourselves and our associates when interacting with others.
• Human Rights Policy: RPM is committed to a wide range of human rights issues, including equal opportunities, non-discrimination and non-harassment, the prohibition of child and forced labor and more. As stated in our Human Rights Policy, we also support the U.N. Guiding Principles for Business and Human Rights, which respects and honors the principles of internationally recognized human rights.
• Hotline and Non-Retaliation Policy: This policy informs employees how to report complaints through our hotline and other channels, how those reports are investigated and our nonretaliation policy. The approach to these topics is also set forth in The Values & Expectations of 168.
• Anti-Bribery and Anti-Corruption Policy: We use our “Route 168” compliance training program to educate our associates that bribery and corruption of any kind will not be tolerated and about ways to spot and report corrupt activity. We investigate all reports of suspected incidents.
• Records and Information Management Policy: This policy defines what constitutes a company record and establishes the timelines for preserving and deleting these records.

We promote ethics and compliance training across the organization through both online and live training sessions as part of our “Route 168” compliance training program. Through our learning management systems and live sessions, associates are trained on a range of topics to reinforce our values and expectations, including data protection, ethical decision-making, conflicts of interest, competition and antitrust compliance, anti-corruption, anti-harassment, non-retaliation, fraud and business integrity. 

As of May 31, 2025, more than 95% of our global associates and management team have completed our code of conduct training.

In addition, all associates have access to RPM Navigator, an internal site for policies, training materials and guidance. Navigator provides information on our compliance hotline; Hotline and Non-Retaliation Policy and other corporate policies; compliance resources; and Supplier, Applicator and Distributor Codes of Conduct. The site has multilingual functionality for ease of use across our global workforce. 

To reinforce our Code of Conduct, we also ask questions within our companywide employee engagement survey focused on compliance training and protocol for reporting concerns. We use these insights to define key performance indicators for our compliance goals.

We encourage our associates to share concerns about ethics or compliance issues through multiple channels, including a supervisor, company leader, RPM's human resources and legal and compliance departments and our anonymous Ethics and Compliance Hotline. In addition, our Code of Conduct and Hotline and Non-Retaliation Policy outline our commitment to respond to any inappropriate conduct or behavior against others, including, but not limited to, harassment and discrimination perpetrated by associates, supervisors, customers or vendors, and any kind of retaliation or harassment.

We have an established enterprise-level risk assessment that covers a range of topics including legal, EHS, HR, finance, operations, security, compliance, sustainability and climate change. Associate surveys, questionnaires and follow-up meetings focus on the specific risk areas identified through the assessment.

RPM also reports the results of assessments to the Board of Directors annually.