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Human Rights

Human Rights Policy

Purpose

Air Products’ approach to human rights has been designed to align with the United Nations Global Compact and core elements of the United Nations Universal Declaration of Human Rights and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.

Through adherence to this policy and our Code of Conduct and Business Ethics (the “Code of Conduct”), we strive to uphold human rights in our operations, businesses, communities and supply chains.

General Principles

Air Products is committed to safeguarding human rights of our employees and in all of our business interactions. We expect our employees and business partners to conduct business according to the highest principles of integrity, ethics, fairness and respect as described in our Code of Conduct. We are committed to contributing to the betterment of the communities in which we operate. Where local law and our human rights standards differ we will follow the higher standard.

Diversity and Equal Opportunity

Air Products is building a diverse, multi-cultural workforce that fosters an inclusive working environment. We are committed to equal opportunity and strive to reflect the diversity of the communities where we do business. We employ local workers, invest in building diverse talent pools and provide training to improve skill levels, where appropriate, in cooperation with worker representatives and relevant governmental authorities. Our global gender equality efforts are fully aligned with the United Nations’ Women's Empowerment Principles.

Through our equal opportunity and diversity and inclusion policies, we expressly prohibit discrimination based on race, color, religion, national origin, age, citizenship, gender, marital status, pregnancy, sexual orientation, gender identity and expression, veteran status, physical or mental disability and other non-business-related factors.

Harassment-Free Workplace

Air Products is committed to a respectful work environment free of any manner of physical and verbal harassment, including bullying, mobbing and sexual harassment. The Company maintains strong procedures to prevent such behaviors, including routinely communicating its expectations and providing training to employees and managers. We expect good faith reporting and thorough investigation of all allegations. We take all violations of this policy seriously and have consequences for violations, including termination of employment.

Freedom of Association

Air Products respects employees' voluntary freedom of association and right to bargain collectively and complies with pertinent local laws where we operate. Some of our employees are represented by officially designated third-parties or designated/elected employee representatives.

Forced Labor

Air Products does not engage in and will not tolerate the use of slavery, human trafficking or the use of forced labor of any kind.

Child Labor

Air Products abides by applicable minimum age laws and regulations as well as the ILO Convention 138 on Minimum Age. We encourage the creation of training, apprenticeship and intern programs tied to education. Air Products does not use or condone the use of child labor in violation of applicable law in the conduct of our business.

Conflict Minerals

Air Products is committed to sourcing materials from companies that share our values around human rights, ethics and environmental responsibility as noted in our Conflict Minerals policy. We expect our suppliers to comply with our Code of Conduct and meet our sustainability expectations, including Conflict Free sourcing.

Compensation and Working Time

Air Products has established competitive pay levels that are based on local markets and job descriptions and are not based on gender, age, ethnicity, nationality or other personal characteristics or beliefs. We provide compensation and benefits that are competitive and comply with applicable laws. Our compensation philosophy is communicated and available to employees.

We are committed to complying with local legal requirements and collective bargaining agreements regarding working time, conditions and appropriate compensation.

Environmental Health, Safety and Security

The safety and health of our people, customers and the communities where we live and operate remains our highest priority. In accordance with our Environmental, Health and Safety (EH&S) policy, we are committed to being an industry leader in EH&S performance, aiming not just to meet but exceed EH&S requirements through a global management system that applies to all of Air Products’ operations.

In support of our sustainability goals and environmental responsibility, we design and operate our facilities in a manner that protects the environment and the health, safety and security of our employees, contractors and the public. Procedures are in place to ensure the timely communication of any threats or security concerns to employees and community agencies and to deal appropriately with such situations. We are committed to developing and producing products that can be manufactured, distributed, used and recycled or disposed of in a safe, secure and sustainable manner.

Anti-Corruption

Air Products specifically prohibits offering, promising, making, requesting, or accepting or agreeing to accept any payments or favors that might be considered improper or illegal. Employees are expected to adhere to existing policies for global competition, anti-corruption, and ethical business conduct. Employees are trained on anti-bribery and corruption topics, including applicable laws and regulations, and are encouraged to report any suspicions of wrong doing via the Company's IntegrityLine.

Implementation

This Human Rights Policy has been communicated to and is accessible to all employees. Employees who believe that there may have been a violation of this Policy should report it through established channels including but not limited to:

• the manager of the department in which the violation occurred;
• any member of Air Products management;
• the employee's HR manager;
• the Equal Employment Opportunity Officer (U.S.);
• the Global Director of Diversity and Inclusion; or
• the IntegrityLine—our Company compliance assistance resource.

We strictly prohibit retaliation in any form against anyone who makes a good faith report about suspected violations or cooperates in an investigation of an alleged violation.

In furtherance of its commitment to Human Rights, Air Products requires its suppliers, vendors and contractors to certify or contractually agree to abide by all laws, rules and regulations in effect in the countries and jurisdictions in which they do business. We may also require suppliers, vendors and contractors to agree to abide by this Policy or demonstrate a commitment to Human Rights via their own policies. This is outlined in our expectations of suppliers.

Administration

The Senior Vice President and Chief Human Resources Officer has overall responsibility for the administration of this policy.

The Executive Vice President, General Counsel and Secretary has overall responsibility for the IntegrityLine and Code of Conduct, including ensuring appropriate follow-through of reported violations.

Human Resources and Supervisors/Managers at all levels are responsible for upholding this policy and fully supporting the Company's efforts to create a respectful, fair and safe work environment; to model their behavior accordingly; and to report non-compliance with this Policy.

Employees are responsible for treating co-workers with respect, valuing different thinking and ideas, working effectively across differences and reporting any violations of the principles presented herein.

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