With reference to our previous update on establishing a dedicated global team whose mission is to formulate an optimal proposal for the ICL's Global Human Rights Policy, based on global best practices, we are pleased to share with you that a draft of the policy is currently under review by the relevant professional parties at ICL, and once it is approved, we will of course keep you informed.

The main issues the global policy will concentrate on are:

1.1. Freedom of Occupation

1.2. Prevention of Harassment and Discrimination

1.3. Freedom of Association

1.4. Safety at Work

1.5. Prohibition of Employing Minors

1.6. Fair Wages, Benefits and Reasonable Working Hours

1.7. Permanent Position Vs. Outsourcing/Contracts

The case presented to the committee was that of a company manager who also owns a farm. The manager reported that he intends to purchase equipment for his farm from a distributor who is contracted with ICL, to the relevant parties in the company, in order to check whether there is a conflict of interest in such activity. The manager provided proof that the price of the equipment he intends to purchase is the market price and the transaction was approved by the authorized parties in the company, so there is no conflict of interest in this case.

The Committee discussed hypothetical cases where such a transaction may be a conflict of interest:

· A case where the manager is influential in the company's relationship with the distributor and therefore may also affect the price of the equipment he purchases for his private farm – is an actual conflict of interest.

· A case where the distributor intends to renew the distribution agreement with the company in the future and the manager may be indirectly involved in the decision whether or not to renew the contract with him – is a potential conflict of interest.

· A case in which the manager, in a role which has nothing to do with the distributor's work with the company and the equipment was purchased at market price - but to an observer employee it may seem a benefit due to the existing relationships between the distributer and the company -is a perceived conflict of interest.

Committee Recommendations:

· In cases where there is a concern for actual, potential and / or perceived conflict of interest, following the Conflict of Interest procedure and reporting to the relevant manager and regional compliance officer before deciding - in this case, the manager acted correctly in reporting and obtaining approval after verifying that the purchased equipment price was sold at market price.

· Following discussions that arose with regard to additional occupations of company employees, the employee has a duty to report any additional occupation that they want to partake of (outside the company) and, accordingly, obtain company approval in advance for the additional occupation. Usually, such an obligation exists in the employment agreement. The Committee recommends that HR refresh the guidelines in the various countries and consider anchoring rules on the issue, including areas where there are few clear guidelines

The committee's discussion focused on a production site in Europe, in which the employment of family members is a widespread issue and requires reference. It should be noted that the issue probably stems from a lack of awareness among employees about the ethical complexity of the topic.

· After discussing the issue with HR representatives, it was decided that the regional hiring procedure in Europe should be updated to require new employees to declare family proximity which, as defined by the employment procedure, would require the approval of a regional HR manager.

· For existing employees, in the event of a family proximity between a manager and an employee in the same department and based on the Conflict of Interest procedure - the managers to whom they are required to report are the relevant manager at the T100 level and, in addition, the Regional Compliance officer.

The topic applies in Israel only.

• In light of several instances brought to the committee regarding frequent use of company vehicles by family members (such as regular commutes by a family member to their workplace which is farther away from their residence than the employees' company office), this topic was discussed. The discussion and conclusions of this section are relevant to Israel only.

The procedure existing in Israel states, regarding leased vehicles the company lets the employee use:

· Authorized to drive in the Company's vehicle: An employee who received a company vehicle and first-family members (wife / husband and children) in accordance with the permits required to present to the leasing center.

· The vehicle is available to the vehicle holder for work and private use. It is forbidden to regularly deliver the vehicle to another party for work or any other need (Such as: traveling to a family member's workplace, a shuttle car and cargo transport, newspaper distribution, etc.). Care must be taken that the use for family needs is proportionate and in accordance with the law. Towing is prohibited with the vehicle.

· The vehicle owner represents the company in the community and is thus required to keep the vehicle as if it were their own. Any deviation from the procedure must be approved by a senior HR VP or by the Global Compensation and Benefits VP. Violation of the instructions in this procedure may result in disciplinary action, up to cessation of work.

Committee recommendations based on the procedure:

• The use of a company car is not permitted regularly by a family member for work or any other need.

• Care must be taken that the use for family needs is proportionate and in accordance with the law.

• In-light of several instances of concern regarding the use of the company vehicle in breach of the procedure or disproportionately - the Committee recommends that HR consider communicating a letter to company car owners with additional emphasis based on the procedure to prevent recurrence of similar events.

• For any questions and / or concerns regarding the use of company vehicles, the Committee recommends contacting the relevant HR functions and following the guidelines.

The issue of communication and interaction between co-workers on social media, including on personal profile pages, was brought up to the committee by virtue of the company's global operational spread, which promotes diversity and inclusion, including tolerance and inclusion of cultural differences between its employees. The committee discussed the need to formulate a set of guidelines / recommendations for employees and managers in social media to minimize situations that could be interpreted as unethical or unprofessional in some places. For example, in Israel it is common to "request friendship" on Facebook / Instagram by both managers and employees. Alongside this, there may be other areas where the company operates as well as cases where employees and / or managers will feel uncomfortable and reluctant to disclose their personal lives to their managers or subordinates.

Committee Recommendations:

The Committee believes that since the issue is in the personal / private sphere, it is difficult to apply a global guideline for it. However, a draft of guidelines on social networking behavior might be considered among managers and employees of the company, who are expected to exercise caution and sensitivity when it comes to social media behavior, including the privacy of their co-workers.

For example, the committee recommends that managers do not initiate friendship requests from their employees on Facebook / Instagram, etc. and that the employee obviously has the right to refuse / not respond to this request.

The committee was presented with an issue where some managers tend not to answer professional emails in writing but prefer to reply orally and / or prefer not to answer at all.

Committee Recommendation:

Such cases where an employee or a manager at ICL does not respond in writing to professional emails sent to them, constitutes a managerial issue and not an ethical issue within the committee's authority and therefore the treatment should be at the managerial level.