SUSTAINABILITY REPORT

FOR THE FINANCIAL YEAR

2019

We're

BRENNTAG WORLDWIDE

END-MARKET INDUSTRIES

Coating &

Construction

Cleaning

Cosmetics

Polymers

Food & Nutrition

Pharma

Oil & Gas

Water

Treatment

NORTH AMERICA

5,257

Employees

READING

Pennsylvania

EUR 4.8BN

HOUSTON

External sales

Texas

LATIN AMERICA

1,934

Employees

EUR 0.9BN

External sales

Regional headquarters

More than 640 locations worldwide

EMEA

7,720

Employees

EUR 5.2BN

External sales

ESSEN

Germany

SINGAPORE

Republic of

Singapore

KEY FIGURES

IN EUR M

2019

2018

2017

ASIA PACIFIC

2,581

Employees

EUR 1.5BN

External sales

Sales

12,821.8

12,550.0

11,743.3

Operating gross profit

2,821.7

2,660.9

2,554.1

Operating EBITDA

1,001.5

875.5

836.0

Profit after tax

469.2

462.3

362.0

Free cash flow

837.3

525.2

440.3

Employees

at Dec. 31

17,492

16,616

15,416

Personnel expenses

1,072.6

1,004.7

990.8

including social insurance contributions

Accident rate (LTIR)1)

1.9

1.5

1.7

Employee fluctuation

in %

7.6

8.5

7.7

ISO 9001 certifications

% of operating sites

91

91

86

  1. Number of accidents resulting in at least 1 day's absence/1 million working hours

ABOUT BRENNTAG

Brenntag is the global market leader in the distribution of chemicals and

ingredients­ . Connecting chemical manufacturers (our suppliers) and chemical users (our ­customers), we provide both complete distribution solutions as well as individual ­chemical products.

Brenntag distributes industrial and specialty chemicals for thousands of suppliers. We maintain a global network with more than 640 locations in 77 countries in the regions North America, Latin America, EMEA (Europe, Middle East & Africa) and Asia Pacific. We serve around 195,000 customers worldwide in various end-market industries.

With its corporate strategy1), Brenntag pursues the goal of being the

­preferred distributor for both specialty and industrial chemicals for our customers and suppliers and, at the same time, the industry leader in ­safety, growth and profitability. A positive work environment and responsibility towards our almost 17,500 employees worldwide are fundamental aspects of our corporate strategy and therefore also of Brenntag's sustainability strategy.

  1. For information on Brenntag's vision, objectives and strategy, please seeBrenntag's 2019 Annual Report.

BACK

1

SUSTAINABILITY AT BRENNTAG

"ConnectingChemistry" - this is the brand promise of Brenntag and of each of its employees to our business partners. As the global market leader in the distribution of chemicals and ingre- dients, Brenntag connects chemical manufacturers and users in a value-creating partnership. Brenntag's key role in the value chain offers huge potential - but also entails an obligation to contribute towards greater sustain­ability in the industry.

RESPONSIBLE CORPORATE BEHAVIOUR is part of Brenntag's brand promise andself-image.For us, sustainability entails more than just commercial success. We also aim to achieve sustainable value creation. For this reason, Brenntag also considers the effects of its business activities on the environment and factors in social issues when making strategic decisions.

CONTENTS

  2 Interview with the CEO

03

Global impact.

01

Our future in mind.

Global business.

35

Safety

Our agenda.

44

Environmental Protection

  6

Sustainability at Brenntag

50

Responsibility in the

18

For a Sustainable Future:

Supply Chain

Circular Economy

54

Community

02

The people at Brenntag.

57

Further information

Our most important resource.

57

Report Profile

23

Employees

60

Practitioner's Report

62

GRI Content Index

66

Imprint

NFB

More information

More information online

Denoted

Non-financial

Report (NFB)

Brenntag 2019 Annual Report online:

annualreport2019.brenntag.com.

2

INTERVIEW WITH

DR CHRISTIAN KOHLPAINTNER,

CHIEF EXECUTIVE OFFICER

"

Sustainability must be

an elementary part of our corporate strategy and thus become part of our corporate culture.

Mr Kohlpaintner, you have many years' experience as a manager in the ­chemical industry. How important is the issue of sustainability to you?

I have followed the debate about sustainability as it has developed during the meanwhile almost 30 years that I have worked in the chemical industry. It used to be about specific issues relating to environmental protection, such as efficient water usage. Today, it goes far beyond this: Sustainability is now a central issue that concerns a company's long-term "licence to operate".

How can companies ensure their future viability?

The question of acceptance is of particular importance for all industrial companies. The "licence to operate" requires that companies act sustainably in accordance with the expectations of society; in other words, a company must evolve with society and operate in harmony with social values. That is where their future viability comes from. And the expectations for a company that operates with chemicals are particularly high.

When I talk about society, I mean all relevant stakeholder groups - and that includes our investors in particular. The financial community pays a great deal of attention to the sustainable development of companies and formulates its expectations very clearly in public. Investors are placing more and more value on sustainable portfolios - primarily to achieve long-term investment objectives.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

In this regard, I view the issue in a very holistic way. Sustainability has to flow into our vision, our strategy, our value chain andday-to-daybusiness, and our actions - and in doing so become a business driver. We need to evolve in this direction at Brenntag. Ensuring and driving this change is clearly the responsibility of the CEO. We will continue this journey together at all times at Brenntag. As a company, we must develop robust responses today so that we are still credible and accepted as a company in ten or fifteen years.
I regard sustainability as an element of change and evolution that must take a sensible and comprehensible form - in terms of a cultural change within the company. Sustainability is not an additional task that simply needs to be completed. Sustainability must be an elementary part of our corporate strategy and thus become part of our corporate culture. Therefore, of central importance to me is the question: How do we embed sustainability within our corporate strategy?

TABLE OF CONTENTS

INTERVIEW WITH THE CEO

3

What does this mean for Brenntag?

"Brenntag is in a strong and solid position when it comes to ­sustainability. The next evolutionary stage now follows.

Dr Christian Kohlpaintner, CEO

What role will Brenntag have in the future in matters relating to sustainability?

The key factor is: Brenntag is the global market leader in chemical distribution and must take a stand on certain issues. Without the involvement and commitment of the major players, it won't work. Responsible actions extend far beyond the company's walls. We must ask ourselves: Where can we play our part in ensuring that value chains become more sustainable? Transformation is possible.

What conflicting objectives do you see? How do company growth and sustainability fit together?

I firmly believe that our holistic approach to sustainability is opening up further opportunities for growth. For a long time, it was widely believed that sustainability and successful business were mutually exclusive. Even in the past, I didn't share this view. Addressing sustainability is an essential part of securing the confidence of customers, investors, employees and suppliers. Sustainability must be regarded as a business driver. And it is also in line with my self-image that we operate sustainably in a dual sense, namely with a view to the future and in the interests of our stakeholders.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

Brenntag is in a strong and solid position when it comes to sustainability. The next evolutionary stage now follows. It will start with us providing good sustainable programmes. In addition to strategic embedding, the ­integrated approach is important. This will also bring global business opportunities. Brenntag will have a competitive advantage wherever suppliers and customers place value on sustainability.
Which issues are particularly important to you in terms of future developments at Brenntag?

4

"I firmly believe that our holistic

approach­ to sustainability is opening up further opportunities for growth.

Dr Christian Kohlpaintner, CEO

For example, the topic of the circular economy with the possibilities for recycling and preventing waste offer opportunities to Brenntag and our customers. And sustainability is also important to recruit employees who want to work for a company that credibly pursues sustainability objectives. It is a fact that people will no longer want to perform certain activities in the future. For this reason, I am also addressing the future viability of our working conditions.

We will be working on these and other issues in the coming months with the goal of establishing a clear road map for the evolution of sustainability at Brenntag.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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01

GLOBAL

BUSINESS.

OUR

AGENDA.

Several

thousand

suppliers

More than

10,000

products

More than

640

sites globally

Around

17,500

employees Around

195,000

customers

6

SUSTAINABILITY AT BRENNTAG

We source, transport, store, blend and sell chemicals, chemical products and ingredients all over the world. While we are the global market leader in chemical distribution, our aim is to go beyond this: We want to make value creation sustainable. To achieve this, we address fundamentally important topics: safety and health, conservation of resources, waste prevention and recycling are just a few examples. Awareness of our ­responsibilities - including compliance at all times with laws and regulations - is deeply rooted in our company. It determines our behaviour towards our employees, suppliers and customers as well as society in general and it has a direct influence on the success of our company.

With this awareness in mind, we aim to factor in the effects of our business practices on the environment and society in both our day-to-day activities and strategic decision-making. To this end, we have established corresponding standards and processes in our international corporate structures. We raise our employees' awareness of these issues and provide them with corresponding training. In addition, we support sustainable development through our membership of various organizations and initiatives and regularly discuss sustainability issues with other players in our industry.

NFB

SEPARATE NON-FINANCIAL

GROUP REPORT

Selected content in this sustainability report serves as the separate non-financial Group report (NFB) pursuant to Section 315c in conjunction with 289c ff. of the German Commercial Code (HGB) to ensure compliance with the legal requirements of the HGB. The NFB has been audited by Pricewaterhouse- Coopers GmbH Wirtschaftsprüfungs- gesellschaft pursuant to ISAE 3000 (Re- vised) to obtain limited assurance. The NFB is denoted with a blue line and the

acronym NFB 

NFB

  in the sustainability re-

port.Detailed information on the NFB can be found in the Report Profile on page 57f. Information on the business model can be found in the Combined Group Management Report and the Management Report of Brenntag AG ofBrenntag's 2019 Annual Reporton page 34. Information on environmental protection provisions amounting to EUR 97.8 million for theclean-upof soil and ground water at current and former own or leased locations can be found under note 26 to the consolidated financial statements for the 2019 financial year.

CREATING VALUE -

BRENNTAG'S ROLE

IN THE SUPPLY CHAIN

Brenntag's slogan "ConnectingChemistry" stands for our self-image as well as our objective and the promise that we make to all of our partners in the supply chain. As a provider of a full-line product portfolio and as a "one-stop shop", Brenntag plays a key role in the chemical industry's value chain and, as a strategic partner, contributes to greater efficiency.

CHEMICAL

MANUFACTURERS

WORLDWIDE

  • Several thousand suppliers
  • > 10,000 industrial and specialty chemical products

PURCHASING

TRANSPORT

STORAGE

  • > 640 locations in 77 countries
  • Local purchasing teams and a global sourcing organization with more than 1,000 experts
  • Cost of materials in 2019: EUR 10 billion

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SUSTAINABILITY AT BRENNTAG

7

SUSTAINABILITY STRATEGY AND MANAGEMENT

2019 MATERIALITY ASSESSMENT: In August and Septem- ber 2019, we conducted a new materiality assessment in order to examine and document the extent to which the issues that are material for Brenntag need to be updated.

To meet the requirements of the Global Reporting Initiative (GRI) and the HGB, three dimensions have now been considered for the 2019 materiality analysis in addition to the 2015 materiality analysis: The importance for the stakeholders, the importance for understanding the business performance, the business result or the situation of the company and the

impacts­ on the environment, society and the economy. Against this background, the previously selected 13 topics had to be ­assessed. Those surveyed included internal and external stake- holders. In addition to employees,­ customers, suppliers and association representatives, we included investors for the first time. The results of the survey, which were presented to and discussed with the Board of Management of Brenntag AG,

affirm­ our current sustainability strategy and the activities that are based on it. The relevant topics are shown in the materiality matrix on page 8.

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SUSTAINABILITY ISSUES AND TARGETS: We are continuing to pursue our sustainability targets from 2016. In terms of the targets, we are initiating suit­ able projects aimed at improving our sustainability performance, prioritizing measures and quantifying our progress. ReformulatingGroup-widetargets from 2021 onwards is on our agenda. We are currently working to incorporate the findings obtained from the materiality analysis into our strategic considerations for future sustainability activities and objectives. Overall, we need to further develop oursustain­ ability approach and better integrate it into our corporate strategy.

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See also the

INTERVIEW WITH DR CHRISTIAN KOHLPAINTNER, from page 2.

FILLING

MIXING AND

EXTENSIVE

PACKAGING

BLENDING

TECHNICAL

LABELLING

SUPPORT

  • Repackaging
  • Filling, labelling, barcoding and palletizing
  • Local distribution and marketing teams comprising more than 5,000 experts
  • Product mixing in line with specific customer requirements
  • Blending and technical service in our own application laboratories

WAREHOUSEPACKAGING

MANAGEMENTTRANSPORT

  • Just-in-timedelivery and inventory management
  • Return of packaging drums
  • Efficient logistics and transport management

CHEMICAL USERS

WORLDWIDE

Around 195,000 customers in various end-market industries, e.g.:

  • Coatings & Construction
  • Cleaning
  • Cosmetics
  • Polymers
  • Food & Nutrition
  • Pharma
  • Oil & Gas
  • Water Treatment

8

More information on the SDGscan be found at: www.17ziele.de

See also page 55.

NFB

Our sustainability approach should be seen in a global context and it takes the guidelines of the UN Global Compact (UNGC) into consideration. With regard to the ongoing development of our sustainability strategy, we also incorporate the effects of our business activities on our natural and societal environ- ment. We additionally want to make progress with the global Sustainable Development Goals (SDGs)of the United Nations. We will put more and more emphasis on these with our projects and sustainability activities. As a first step in the direction, three Brenntag employees from USA are taking part in the 10-month"Young SDG Innovators Program". The programme will provide us with helpful impulses for the further development of our SDG approach.

SUSTAINABILITY MANAGEMENT: At Group level, there are numerous strategic guidelines, policies and projects in the area of sustainability that have a global focus. Standards and processes are implemented, established and optimized and responsibilities are allocated at the various levels of the Group. Moreover, in accordance with the Group's guidelines

BRENNTAG MATERIALITY MATRIX

NFB

and objectives, Brenntag's individual companies and sites pursue a large number of activities on their own and in line with local and regional requirements and commitments. We raise our employees' awareness accordingly and provide them with further training.

Brenntag has two working groups in the area of sustainability: an international project team and a steering committee. The international project team which consists of representatives from HSE (Health, Safety and Environment), Com- pliance, Human Resources, Operations, Procurement and Communications, is responsible for the systematic development of sustainability at Group level. The group meets regularly on a project-­ related basis.

high

5

very

Safe handling of chemicals

Respectful and supportive

Occupational health

work environment

and safety

Climate protection

governance

Compliance and corporate

relevance

Water and wastewater

Peopledevelopment and training

Climate adaptation

Sustainable selection of suppliers

Stakeholder

4

Sustainable growth

Waste and packaging

Social

Sustainable

productsand solutions

commitment

Relevance for long-term

business­

development:

medium

very high

high

3

3

4

5

medium

Impact

very high

Safety and environmental protection

Sustainable corporate management

Employees and society

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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SUSTAINABILITY AT BRENNTAG

9

SUSTAINABILITY AT BRENNTAG: OUR TARGETS

TARGETS

BY

STATUS

SAFETY

LTIR1 day/1 million< 1.0 for the

2020

Group accident rate LTIR1 day/1 million

Brenntag Group

in 2019 was 1.9 (2018: 1.5) (page 40).

SUSTAINABLE

Check 80% of our total chemical

2020

The supplier assessments carried out

PROCUREMENT

spend (in EUR) through sustainabil-

by the end of 2019 cover some 72%

ity assessments and audits as part

of Brenntag's total chemical spend

of our membership in "Together

(in EUR) (2018: around 70%) (page

for Sustainability".

50-53).

70% of our suppliers undergoing

2020

The re-assessments carried out by the

re-assessments should be able

end of 2019 led to an improvement

to improve their score by at least

rate of 59% (page 50).

1 point.

ENVIRONMENTAL

To reduce scope 1 and 2 CO2

2020

2019 Brenntag Group (per 1,000

PROTECTION

emissions (per warehouse tonne

warehouse tonnes of goods sold):

of goods sold) by 6% (compared

Scope 1: 19.21 tonnes (2018: 19.71 t)

to 2016).

Scope 2: 4.78 tonnes (2018: 6.93 t)

Change compared to base year 20161):

-0.58% (page 44-45).

COMPLIANCE

To achieve and sustain full cover-

2020

Coverage rate for e-learning at

age in compliance training for the

the end of 2019:

relevant employees.

Code of Business Conduct: approx. 95%

Anti-corruption: approx. 93%

EU cartel law: approx. 96%

We have extended the target achieve-

ment period to the end of 20202)

(page 15-16).

EMPLOYEES

To provide a working environment

ongoing

In 2019, Brenntag's new global

where the best people want to

employer brand "Explore Variety"

work.

was launched, further measures for

our HR development strategy were

implemented and the incorporation

of our HR processes into our global

HR portal was continuously expanded

(page 22ff.).

SUSTAINABLE

To become the preferred distribu­

2020

BASF: project completed; Grüner

SOLUTIONS

tor for sustainable solutions by

Punkt: ongoing; Schütz IBCs: on­going;

setting up pilot projects with 10

Gas Engine Service Program: ongoing;

selected key suppliers.

Alumichem (Circular Economy):­

started (page 18-19).

RATING

To achieve and sustain an Eco-

ongoing

Score in November 2018:

Vadis score of at least 62 points

68 points, gold status (page 53)

and gold status.

  1. The values given for base year 2016 have not been audited by PwC.
  2. Due to improved technical possibilities when using thee-learning platforms, the missing training courses will be carried out in 2020.

NFB

The steering committee comprising individual representatives of the top management from Brenntag's various regions. This is also consulted on a case-by-case basis for strategic discussions in particular and primarily serves as an interface to the operating units and is intended to reinforce ­integration ­relating to the issue of sustainability at an operational ­level. In addition to the two working groups Brenntag has established a sustainability unit. It consists of a team, which is based in Brenntag AG's Corporate Development department, and sustainability managers in the regions. The team initiates and coordinates global projects and initiatives in cooperation with

NFB

these two working groups, promotes the ongoing development of the company's sustainability strategy worldwide and maintains a dialogue with those colleagues responsible for sustainability issues at Group level and in Brenntag's regions. The Board of Management receives reports on a regular basis as well as on a case-by-case and project-related basis and supports the working groups and the sustainability unit in their tasks.

NFB

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

10

For information on Brenntag's ECOVADIS-­RATING,please see page 53.

www.cdp.net

For further information on MANAGEMENT

SYSTEMS AND CER- TIFICATES, please see the Safety chapter on page 35.

In 2019, the sustainability team and the working groups

focused­ on the following issues and projects:

  • Ongoing development of Brenntag's sustainability
    strategy:­ Tracking of Brenntag's sustainability targets for 2020 and development of new targets
  • Sustainable procurement: Initiating sustainability­
    assessments­and audits for suppliers, factoring
    sustainability­aspects into purchasing decisions
  • Launch of a global solar project
  • Continuation and improvement of global energy reporting
  • Establishment of abest-practice platform to save energy by using new technology

QUALITY MANAGEMENT

Brenntag is a chemical distributor which differentiates itself from its competitors through the high level of quality of its products and services as well as its strong customer focus and the excellent level of service provided by its employees. Our Group's sustainability performance has now also become a competitive advantage. We increasingly receive enquiries from our customers who are themselves evaluating their suppliers according to sustainability criteria (for example, in the form of a "Sustainability Balanced Scorecard") and who factor this into their purchasing decisions. For example, we are asked for information about our carbon footprint or how we deal with the issues of recycling and waste. As a result of our sustainability monitoring and our participation in external ratings such as the EcoVadis assessmentor the CDPclimate rating, Brenntag is able to respond to these enquiries and meet the standards to which we are held.

Usingmanagement systems, certificates and audits, we constantly ensure compliance with the quality standards required of us and which we define ourselves. Procedures are in place at our company which ensure that products are procured from reliable sources and meet quality standards. Through various mechanisms, we obtain customer feedback for the continuous monitoring and improvement of our service quality.

The basis for quality management within the Brenntag Group is the internationally applicable ISO 9001 standard. We aim for a global coverage rate of at least 90% at the relevant Brenntag locations.

Year

Relevant

Locations with ISO 9001

Brenntag

certifications

locations

worldwide

abs.

abs.

in %

2015

398

356

89

2016

395

354

90

2017

422

363

86

2018

387

353

91

2019

390

355

91

BRENNTAG EMEA: HARMONIZATION AND STANDARDIZATION WITH SHAPE April 2019 saw the official launch ofSHAPE, which stands for ­Standardization,Harmonization andAutomation ofPro- cesses within BrenntagEMEA. This pro- ject, which will run for several years, aims to standardize structures using new,state-of-the-artinformation technology, to reduce complexity and to pave the way for faster, streamlined processes throughout the region. It will be introduced in the Benelux countries in 2020 as a pilot region and then gradually rolled out in other regions. The entire introduction process will be accompanied by communication and training measures for employees.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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SUSTAINABILITY AT BRENNTAG

11

RISK MANAGEMENT AND COMPLIANCE

Brenntag has always attached great importance to responsi­ ble, prudent and sustainable corporate governance. Our top priority is to comply with statutory requirements and voluntary internal policies on conduct. To ensure this, the management uses various internal control and risk management systemsand has established a compliance organization within the company. Every Brenntag employee is personally responsible for complying with all applicable laws, directives, policies and regulations.

COMPLIANCE MANAGEMENT AND ORGANIZATION: At the top of Brenntag's compliance organization is the Board of Management and, within this body, its chairman. The Governance, Risk & Compliance (GRC) manager in Brenntag AG's Corporate Internal Audit department regularly reports to the Board of Management on compliance issues. The regular meetings of the Supervisory Board's Audit Committee also include reporting on compliance andwhistle-blowingas well as on the ongoing development of theGroup-widecompliance management system­. The GRC manager is supported by the Compliance Committee as an internal advisory body. This committee comprises representatives from the departments Legal, Audit, Accounting & Tax, Controlling, Finance & Investor Relations, Communications, Risk Management, Information Security, HSE as well as Human Re- sources. Issues and measures aimed at observing human rights and fighting corruption are also on its agenda.

At a regional level, the Regional Executive Management is responsible for the compliance issues. Regional compliance

managers­ have been appointed. They receive, assess and report­

any compliance issues and/or questions referred to them, coordinate­ the compliance management system at a regional level­ and regularly exchange information and experience with Brenntag AG's GRC manager. This ensures that our compliance management is closely interlinked with our business activities at regional level.

NFB

RISK REPORTING: The risk inventories performed every six months by our Group companies are an important instrument for global risk control within the risk management system. They involve enquiring about existing risks and assessing these in terms of their probability of occurrence and their potential damage. The risk assessment includes risks and opportunities with a sustain­ ability dimension, such as environmental risks, employee turnover or risks in the area of law/compliance. The Group risk management system also includes sustainability -related aspects concerning environmental and employee matters, human rights, and anti-corruption and bribery matters and the associated risks.

With regard to the non-financial aspects of the German CSR Directive Implementation Act (CSR-RUG), a net assessment of the risks did not identify any material risks which are associated with our business activities or our business relation- ships, products and services and which are very likely to have serious negative effects now or in the future.

CODE OF BUSINESS CONDUCT AND ETHICS: As a global company, Brenntag is subject to a large number of laws, di- rectives, regulations and provisions. In addition to compliance with regulatory frameworks, honesty and integrity are our top priority. All of our fundamental company values, ethical principles, compliance with laws, rules and regulations as well as the relevant guidelines and procedures which are of key significance for Brenntag and its reputation are summarized in a comprehensiveCode of Business Conduct and Ethics.

NFB

For further information on Brenntag's

CONTROL AND RISK MANAGEMENT SYSTEM as well its report on opportunities and risks, please see pages 75ff. ofBrenntag's 2019 Annual Report.

The Brenntag CODE

OF BUSINESS CONDUCT AND ETHICS is available on the company's website atwww.brenntag.com/ sustainabilityunder Service & Contacts.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

12

NFB

TheANTI-CORRUPTION

GUIDELINE is available on our website atwww.brenntag.com/ sustainabilityunder Service & Contacts.

The Code of Business Conduct and Ethics contains requirements for the following areas:

  • Health, safety and the environment
  • Human rights and working conditions
  • Relationships with business partners and public institutions
  • Fighting bribery and corruption
  • Competition and antitrust law
  • Avoidance of conflicts of interest
  • Data protection and information security

The Code is available on the internet and intranet in German, English, Spanish and French. It applies to all employees at all levels of the company and is intended to give them guidance in the legal and ethical challenges of their daily work and to encourage proper conduct. The Code has been distributed throughout the entire Brenntag Group and made available to all of our employees. Its observance is monitored by the management teams of Brenntag's various companies. Any infringement of the Code may lead to disciplinary action and have consequences under labour law or even criminal law for the employee in question.

As well as the Code of Business Conduct and Ethics, there are further Group guidelines which stipulate compliance re- quirements, including an anti-corruption guideline, an insider compliance guideline and an internal control guideline. The Code and all guidelines that are applicable Group-wide can be accessed by all the Group's employees on the intranet.

DATA PROTECTION:To meet the increasing requirements globally in the area of data protection, the Board of Management appointed a Group Data Protection Officer in 2018. As head of the Global Data Protection department she reports independently and directly to the Board of Management. The Global Data Protection department is responsible for develop- ing, implementing and managing the data protection management system for the Group. Data protection coordinators in the various regions support the Global Data Protection department and report to the central unit. A Data Protection Committee was established in the reporting year comprising Board of Management members from Brenntag AG and Brenntag Holding GmbH as well as representatives from the departments Data Protection, Legal, Human Resources, IT, Internal Audit and Compliance. The participants hold regular meetings to discuss recommendations under data protection law and developments within the company. In the reporting

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year, the focus was on the fundamental right to data protection and the right to informational self-determination, in particular in relation to the processing of employee data. In addition to making information on data processing available to Brenntag employees, we do the same for our shareholders and customers through various channels of communication.

PREVENTING CORRUPTION: Preventing corruption is an essential element of Brenntag's compliance management system.Group-widerequirements relating toanti-corruptionare specified in codes and guidelines. They apply to all employees equally and compliance with them is monitored. If our employees­ fail to comply with these requirements, this could have reputational and financial risks for Brenntag. Employee misconduct is not tolerated by Brenntag(zero-tolerancepolicy) and can lead to disciplinary measures or have consequences under labour law.

In addition to the Code of Business Conduct and Ethics, there is a worldwide anti-corruptionguidelinefor the Brenntag Group which specifies what behaviors are expected of employees in this regard. It also provides guidance on how employees should behave in critical situations so that their conduct is compliant and risks are avoided.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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SUSTAINABILITY AT BRENNTAG

13

The anti-corruption guideline contains and specifies requirements for the following areas:

  • Prohibition of corruption and bribery
  • Gifts, hospitality and other benefits
  • Donations and sponsorship, including prohibition of political donations on behalf of the company
  • Prohibition of facilitation payments
  • Relationship with third parties (sales brokers, agents, etc.)

The internal control guideline contains further requirements and measures to counteract corruption and bribery, such as ensuring the separation of functions, complying with the double-check principle and adhering to the requirement to obtain comparative bids from suppliers and service providers.

Internal audits are regularly conducted at our Group companies to ensure compliance with these guidelines. The Internal Audit department conducted 27 audits in 2019. Further elements of the compliance management system relating to the prevention of corruption at Brenntag are target group-­ oriented training courses for employees, which are essentially rolled out via our e-learning systems, and a whistle-blowing system, which can be used to provide anonymous informa- tion. In the reporting year, no cases of corruption at Brenntag were reported.

EXTERNAL TRADE RESTRICTIONS:

DUE DILIGENCE PROCESS AT BRENNTAG

As a global market leader in the distribution of chemicals and ingredients, Brenntag must adhere to all applicable laws on external trade and customs in its countries. This includes restrictions on the import and export of certain goods, services and technologies into or out of countries that are subject to sanctions or embargoes. The same applies to supplies to or from companies or persons that appear on sanction lists. Furthermore, all applicable trade restrictions resulting from international embargoes that typically restrict or prohibit funds transfers or capital transfers to or from certain countries must be adhered to.

In connection with this, Brenntag uses special software to regularly check whether our customers and suppliers are on the sanction lists of the United Nations, the European Union, the USA and various other countries where Brenntag oper- ates. Even a mere suspicion leads to a diligent check being performed based on all available information. If the suspicion

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proves to be founded, delivery of the product or service is suspended and, if necessary, additional action is taken in coordination with the authorities.

HUMAN RIGHTS: Observing human rights is one of Brenntag's top principles and is regarded as an essential element of its general compliance management system. Through its voluntary commitment to the principles of the UNGC, Brenntag seeks to lend further weight to its position. The Brenntag Code of Business Conduct and Ethics stipulates that our company and employees must avoid violations of human rights in any form. We oppose all forms of forced labour or child labour, advocate equal opportunities and fair work conditions, and reject discrimination of any kind.

Violations of human rights can be reported internally via our compliance organization and anonymously via our whistle-­ blowing system. External third parties can also use this system. If any suspected violations of human rights are confirmed, they are strenuously pursued and sanctions are incurred. In the reporting year, no violations of human rights within the corporate Group were reported.

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BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

14

CHEMUK:"Sustainability is already a big topic in the supply chains of the chemical industry and will be more

­influential in the future as a driver for innovation, new products and services," says Richard Ward, ­Commercial Vice President of Brenntag UK & Ireland at UK Chemical Industries Supply Chain Expo & Open Conference (CHEMUK) in May 2019, Harrogate.

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For information on the SUSTAINABILITY ASSESSMENTSand the Supplier Code of Conduct, please see the chapter Responsibility in the supply chain on page 50.

www.unglobalcompact.org

TheSUPPLIER CODE OF

CONDUCTis available on our website at ­ www.brenntag.com/­ sustainabiltyunder Service & Contacts.

For several years, Brenntag has voluntarily undergone a ­sustainability assessmentby the international rating agency EcoVadis every two years. In November 2018, the Brenntag Group achieved a score of 68 points, thereby reconfirming the gold status that it achieved in 2016. Another sustainability assessment began at the end of 2019 and will be completed at the start of 2020. The results will be provided in our sustainability report for 2020. EcoVadis evaluates the sustainability performance of companies in terms of four categories: environment, labour practices, fair business practices and sustainable pro- curement. The review of aspects in the area of human rights is an essential element of this external assessment of Brenntag.

Brenntag believes that a big risk of potential violations of human rights is in our supply chain. Within the framework of our membership of the industry's "Together for Sustainability" initiative, we request that our suppliers undergo EcoVadis sustainability assessments, which also include a review of compliance with human rights. Brenntag's Supplier Code of Conductexplicitly requests that our suppliers support the observance of international human rights and that they avoid violations of human rights. Furthermore, there are additional supplier assessments and audits based on standardized questionnaires that also deal with the observance of human rights.

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A working group was formed in 2017 to concentrate on the issue of human rights in our company and our supply chain. In the year under review, we continued to work on pinpointing where human rights issues affect our company and identifying approaches for a detailed analysis of potential dangers.

UN GLOBAL COMPACT: As a signatory of the United Nations Global Compact (UNGC), Brenntag is required to make the UNGC's principles in the areas of human rights, labour standards, environmental protection and fighting corruption an integral element of its corporate strategy. They supplement our own corporate values and principles which guide our activities. This Sustainability Report also serves as a progress report which must be published annually as part of our participation in the UNGC ("Communication on Progress").

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UN GLOBAL COMPACT:

THE TEN PRINCIPLES

1HUMAN RIGHTS

Businesses should support and respect the

­protection of internationally proclaimed2

human­ rights and ...

3

... ensure that they are not complicit in human rights abuses.

TRAINING:Our compliance programme focuses particularly on observing our Code of Business Conduct and Ethics and antitrust law requirements as well as on the prevention of corruption and environmental and health protection, since it is here that Brenntag sees the greatest risks. We hold regular employee training sessions covering these issues - through regional and global events which employees attend either in person or via e-learning systems. The aim is to keep all of Brenntag's employees' knowledge up to date and to avoid any illegal actions as well as to protect the environment from being damaged and employees from being injured.

There is a global online training moduleon the Code of Business Conduct and Ethics for all employees which was continued in the reporting year. Participation is mandatory for all new employees when they join the Group. Employees can complete the one-hour training module on the internet via the e-learning platform at any time and from any location. A total of twelve topics are covered - including anti-corruption and the observance of human rights - using practical examples and exercise questions. The employees then take a test to ensure that the knowledge has been transferred. Between its launch date in 2016 and the end of 2019, a total­

of approximately 13,600 Brenntag employees worldwide completed this training module, representing around 95% of the relevant employees1).

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COMPLIANCE

LABOUR STANDARDS

Businesses should uphold the freedom of

association and the effective recognition4of the

right to collective bargaining, ...

... commit themselves to eliminating

all forms of forced labour,  ...

... commit themselves to

abolishing child labour and ...

5

... commit themselves to eliminating

7

discrimination­

in respect of

employment and occupation.

6

ENVIRONMENTAL PROTECTION

Businesses should take a precautionary8approach to dealing with environmental challenges, ...

... undertake initiatives to promote 9greater environmental awareness and  ...

... encourage the development and distribution

of environmentally friendly technologies­.

  1. In general, this excludesemployeeswho do not have access to the e-learning platform (primarily warehouse employees). These employees will receive training on the Code of Business Conduct and Ethics using alternative methods.

10FIGHTING CORRUPTION Businesses should work against all forms of corruption, including extortion and bribery.

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16

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There are also in-depth compliance training modules at a regional and global level on the topics of bribery and corruption and on antitrust law. The training modules on European antitrust law and on bribery and corruption are mandatory for all commercially active employees and man- agers. Between its launch in 2017 and the end of 2019, some 2,300 employees in the EMEA region completed the training module on European antitrust law and around 5,400 employees completed the training module on bribery and corruption. This corresponds to approximately 96% of the relevant employees and managers for the antitrust law training module and approximately 93% for the global­ anti-corruption training module. Since the EU's General Data Protection Regulation (GDPR) came into force, there has been a multi-level training concept for the issue of data protection. Employees are informed of and trained on this issue through various channels. The focus of the data protection training modules was on the EMEA region. A total of around 4,500 employees (around 90%) received training via our e-learning platform. There were additional classroom training modules on this issue in some countries.

WHISTLE-BLOWINGSYSTEM:Tried-and-tested processes are in place at Brenntag for the orderly acceptance and processing of Group-wide internal and external complaints as well as compliance reports. Our employees can report relevant information either to their direct line manager or to the regional compliance manager, or alternatively via a central email address or a whistle-blowing system on the intranet or internet. The whistle-blowing system also provides the option of making anonymous reports, e.g. on vio­ lations of human rights or suspected cases of corruption. Third parties can submit complaints and report violations by getting in touch with the compliance contact indicated on Brenntag AG's website. The information received will always be dealt with on a strictly confidential basis. The reports received are examined and appropriate action taken if a compliance infringement has taken place. Email addresses and other whistle-blowing systems have also been set up at a regional level.

Incoming reports mainly concern cases of suspected fraud and theft. Violations of the Code of Conduct and Business Ethics (such as conflicts of interest and discrimination in the workplace) and reports concerning other compliance issues (such as violations of regulations) are also reported. Compliance managers also receive general inquiries, for example about possible conflicts of interest and requests to accept gifts or invita- tions. If a suspicion is confirmed, this will incur the sanctions permitted under labour law.

Year

Number of confirmed

compliance incidents1)

2017

13

2018

11

2019

14

  1. These are cases reported to the GRC manager for which sufficient evidence has been established. Compliance in- cidents may also occur which are reported, assessed and processed at a local or regional level but which are not reported centrally on grounds of insufficient relevance.

STAKEHOLDERS

Brenntag engages in regular, transparent and target group-specific dialogue with its stakeholders. These include the interest groups that are significantly affected by the economic, ecological or social impact of our business or who may be affected in the future. They also include groups that may influence the economic, ecological or social impact of Brenntag now and in the future.

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SUSTAINABILITY AT BRENNTAG

17

KEY STAKEHOLDERS

BRENNTAG

SUPPLIERS AND

CUSTOMERS

EMPLOYEES

VALUE CREATION

BUSINESS PARTNERS

INVESTORS AND

JOURNALISTS

GOVERNMENTS AND

ANALYSTS

AUTHORITIES

BRENNTAG

ENVIRONMENT

ASSOCIATIONS AND

NEIGHBOURS AND

UNIVERSITIES AND

LOCAL RESIDENTS,

ORGANIZATIONS

RESEARCH INSTITUTES

LOCAL COMMUNITIES

We aim to notify our various target groups promptly and appropriately regarding developments at Brenntag and its ob- jectives, thus enabling our stakeholders to obtain a comprehensive picture of our company and its business activities. In return, this dialogue enables Brenntag to identify the needs and expectations of our stakeholders, to evaluate them and to appropriately reflect them in our business decisions. As well as specific business-related issues, sustainability issues such as safety, the environment, the supply chain and compliance also regularly feature in the discussions.

The Brenntag Group pursues dialogue with its stakeholders in various ways. Our employees maintain close contact with suppliers and customers on a day-to-day basis. Systematic customer and supplier surveys are also regularly carried out. We pursue dialogue with business partners worldwide at the many trade fairs where Brenntag presents itself and its portfolio of services. As a member of relevant technical and industry associationsat a local, regional and international level, Brenntag maintains an active dialogue concerning industry-specific issues, including sustainability.

Brenntag'sInvestor Relations and Corporate Communications departments regularly and promptly notify investors, analysts and journalists of developments within the company, e.g. by presenting the company at roadshows, in analyst conference calls, press conferences and events as well as via the company's web- site and various social media channels. At its various locations, Brenntag engages in active discussions with local residents and local authorities. For example, open days provide the opportunity to inform the general public about Brenntag and to get to know one another.

Information about our

INVESTOR­RELATIONS ACTIVITIES can be found

atwww.brenntag.com/investor-relations.

You will find a list of Brenntag's KEY­ MEMBERSHIPSin the Service & Contacts

section­ of our website at www.brenntag.com/ sustainability.

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FOR A SUSTAINABLE FUTURE:

CIRCULAR ECONOMY

Brenntag's goal is to be the preferred distributor for sus­

OPPORTUNITIES

tainable solutions worldwide. To achieve this, we think and

act in a forward-looking way and take a systematic approach

//

Improved sustainability record

to the issue of sustainability. Applying the concept of the

//

Conservation of resources

circular economy will allow us to ensure that chemicals can

// Prevention and reduction of waste

be used more than once. We prevent and reduce waste

// Efficiency increase/utilization of by-products

and provide our customers with flexible opportunities

//

Promotion of innovations

with added value. We differentiate between two different

//

Optimized customer benefit

models that create opportunities for Brenntag, our customers

//

New business opportunities/resales

and society.

// Opportunity for new partnerships

THE MODEL

MODEL 1

CUSTOMER A Model 1:A substance is sold and then returned to Brenntag after it has been used in the production process of the customer. It can then be used by another customer without being treated.

CUSTOMER B

MODEL 2

CUSTOMER AModel 2:A substance is sold and then returned to Brenntag after it has been used in the production process of the customer. It is treated to remove impurities and then resold.

CUSTOMER B

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19

INNOVATION IN THE SUPPLY CHAIN:

RECYCLABLE ACETIC ACID FOR USE AS A DE-ICER

SUSTAINABLE

SOLUTIONS

Alumichem and Brenntag Nordicworked together

"This is due to the sugar residue from its initial use

on a trial project for a year and a half. The Danish

and is a defect that will be irrelevant for certain pur-

company Alumichem specializes in developing

chasers of the recycled product", says Tina ­Klarskov

and producing high-quality aluminates1)for water

Olesen, COO of Alumichem.

treatment processes, the concrete industry and

www.alumichem.com

winter maintenance services. Alumichem's research

The team is satisfied with the results, especially

and development team conducted a trial project

since the product has been accepted positively on

with "used" acetic acid provided by Brenntag to

the market. Nonetheless, there were ­concerns at

determine­

whether this acetic acid could be added

the beginning of the project due to the ­complex

to a de-icer without impairing the latter's effec-

network of laws regarding the handling of

tiveness and quality. The acetic acid came from

­chemicals and waste. An essential aspect of the

another company that had used it as a processing

­facilitation of the circular economy approach

aid to produce a product. For Brenntag, there is an

is that chemicals can be classified as chemical

extensive scope for research and trial projects in

products even after their first use. Classification

relation to the treatment of products (such as acids

as waste would significantly complicate their

and solvents) with the aim of restoring the quality

further use. A positive development regarding the

of the substances as effectively as possible after

further promotion of circular economy models is

their initial use.

­emerging, particularly on the EU legislative level.

The project team had to be patient. ­Success was

Following the successful pilot project, Brenntag

uncertain for some time, as numerous undesired

and Alumichem have no doubt that this kind of

side effects occurred at several stages of the trial.

business model will provide additional potential

In the end, they managed to eliminate all of these:

in the future.

The effectiveness of the de-icer was virtually the

same; only its colour could not be aligned with the

original product.

  1. Salt of an aluminium compound

"Sourcing recycled acetic acid from Brenntag enables Alumichem to ­enhance its sustainability record. Circular economy is not a revolution that will happen overnight. I think it is important that we have patience here, while also playing an active part at each stage as developments occur.

Tina Klarskov Olesen,

Chief Operating Officer, ALUMICHEM

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20

TOM CORCORAN:

Vice­ President Brenntag Food & Nutrition

Tom Corcoran has been leading our ­global Food & Nutrition organization since the end of 2018.

www.food-nutrition.brenntag.com

BRENNTAG FOOD & NUTRITION:

CIRCULARITY WITH FOOD

The circular economy is an area that the Brenntag Food & Nutrition business unit established in 2018 also focuses on. Although food security is one of the pressing global issues of our time due to a growing world pop- ulation, there are still challenges in the food industry such as food waste or its accumulation of vast volumes. For Tom Corcoran, Vice President

of Brenntag Food & Nutrition, innovation and creativity are key to more sustainable solutions in the industry.

With regard to the current challenges in the food industry:

How can Brenntag Food & Nutrition make a valuable contribution through circular economy?

We are working intensively on solutions to reduce food waste. Our experts in the food development teams in all Brenntag regions are ­focusing on this problem. Next to our expertise, innovation and ­creativity play

a decisive role. There was recently a series of trials at Brenntag North Americain which apple and carrot peel were processed to form a powder that can be used to refine the taste of rusks. Apple or carrot powder is also used, among other things, because of its natural colour and texture.

Waste is also created if food spoils quickly. For this reason, we are working to make food more long-lasting. This primarily concerns microbial growth and the deterioration of quality through oxidation. We work with antimicrobial agents and antioxidants to increase shelf life and reduce waste.

In order to implement our ideas, we work closely with our suppliers. The complete traceability of Brenntag's entire supply chain is important to support our suppliers and customers and contribute to a circular economy.

In what other areas does Brenntag Food & Nutrition contribute to a more sustainable society?

We respond to trends within the sector. To changes in demand, for example, as the younger generation is more conscientious about what it eats and prefers vegetarian fare. Today's consumer values quality and

is prepared to pay more for it. In addition to the health effects on people, a vegetarian diet has other benefits compared to the consumption of animal products such as fewer CO2emissions, since local production plays a bigger role, lower water and land usage, the preservation of biodiversity and the protection of animals.

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FOR A SUSTAINABLE FUTURE

21

THE PRINCIPLE:

CLOSING THE LOOP

In implementing sustainable solutions, we try to think along the principles of the circular economy reduce, reuse, recycle, rethinkand to use these principles across the entire value chain.

reduce:In consulting with its customers, Brenntag can contribute to the efficiency of their use of chemicals and thereby reduce both the amount of chemicals in use and the waste they produce.

reuse:Reusing chemicals and packaging is an attractive option in many ways. Alongside suppliers and customers, Brenntag can create a cycle that conserves resources and reduces costs.

recycle:Reprocessing and subsequent recycling are on the programme at Brenntag. At Brenntag's own plant in Switzerland, for example, the company can recycle chemical products themselves. In other countries, Brenntag works with specialised recycling companies for chemicals, plastics and packaging.

rethink:Thinking in loops and longer life cycles leads Brenntag to create new business models and promotes innovation.

Efficient use of chemicals

Prevention of waste

Multiple use of

Chemicals

Packaging

E

R

C

E

U

U

D

T

R

N

OF

S

E

R

A

IO

E

S

O

E

R

N

V

U

C

S

E

R

E

O

C

S

R E T H I NK

N

N

A

E

C

H

H

G

A

N

U

S

LTIGE LÖ

S

S

U

N

S

IO

T

AI

N

T

LU

ABLE SO

L

C

Y

C

E

R

E

Recycling of

Chemicals

Packaging

Plastic

Innovations

New business models

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

02

THE PEOPLE

AT BRENNTAG.

OUR MOST

IMPORTANT

RESOURCE.

77 640100

Sites

CountriesNations

NUMBER OF

EMPLOYEES

EMEA

7,720

North America

5,257

Asia Pacific

Latin America

2,581

1,934

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Employees

23

EMPLOYEES

HEALTH PROMOTION AT BRENNTAG UK & IRELAND:

Become active,­ be healthy and feel good. The participants of the 2019 fitness day demonstrated this awareness with great sustaining power.

Nearly 17,500 people work at Brenntag worldwide. With their expertise and their dedication, they play a key role in the company's success and our long-term competitiveness. Embedded in Brenntag's corporate strategy and vision, the primary goal of our human resources strategy is for us to be regarded globally as the preferred employer in the field of chemical distribution - both for current and potential em- ployees. We see it as our responsibility to offer fair working conditions and an attractive, safe and inspirational working environmentwhile encouraging our employees' personal and professional development in a targeted manner.

HUMAN RESOURCES STRATEGY AND MANAGEMENT

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A globally uniform HR strategy has been developed and the priorities for the coming years have been determined on the basis of our corporate strategy and our corporate values. A key aspect of our HR strategy is to promote employee retention and HR development at every level. This includes embedding globally standardized measures in relation to employee re- cruitment, employee retention, feedback dialogues, HR de- velopment, identification and development of potential, and succession planning.

The Chief Human Resources Officer is responsible for Brenntag's Global Human­ Resources area. The Chief Human Resources Officer reports directly to the CEO and also pursues discussions and dialogues regularly with the entire Board of Management of Brenntag AG, through Board of Management meetings and executive committees such as the Executive Staffing & Development Committee.

Together with the Global HR Leadership Team, which includes the HR officers for Global Development & Talent Manage- ment, Global Compensation & Benefits and for Brenntag's regions, the Chief Human Resources Officer is responsible for implementing our global HR strategy and for putting in place and centrally managing corresponding measures in the Group's various regions.

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For information on our

CORPORATE VISION, please see page 35 ofBrenntag's 2019 Annual Report.

EMPLOYEES

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MARION MESTROM ON DIVERSITY, PERSONNEL DEVELOPMENT AND CAREER PLANNING AT BRENNTAG

MARION MESTROM:

Chief Human Resources Officer

Marion Mestrom has been Chief Human Resources Officer at the Brenntag Group since 2015. She is also chair of the

Committee­ for Diversity & Inclusion and is particularly focused on the advancement of women within the Group.

Brenntag employs around 17,500 people from 77 ­countries worldwide. They work in sales, logistics, service and ­management, to name just a few examples. There is a diverse range of job profiles within the Group. Brenntag therefore needs people who have a wide range of interests and skills. To enable the company's long-term success, they also have to fit together and work as a team. How do you ensure that this happens within the context of the company's global HR strategy?

Diversity is very important to me, and it is also a permanent item on the Management Board's agenda. Diversity has to be lived within the company, as doing so creates enormous op- portunities. We need to welcome and accept diversity, to be open and not prejudiced. If employees are diverse, in terms of their gender or ethnicity, or they bring in new and different ideas and experiences, this allows innovation to arise and creative solutions to be found. It is crucial here that everyone feels equally confident to put themselves and their ideas forward within the company.

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Employees

25

In order to promote diversity and inclusion even further at Brenntag in the future, we established a Committee for Diversity & Inclusion in 2019. I work on this committee together with several top managers from various Brenntag regions. The members bring their experiences to the committee and, in return, put diversity on the region's agenda.

How do you provide suitable opportunities for personnel­ development in terms of the "qualified workforce of tomorrow"?

We can currently see how the world - including the world of work - is changing faster and faster. This makes it all the more important that our employees are prepared for future challenges. However, in order to remain viable in the future, a positive attitude towards change as well as individual initiative are needed: Employees who are open to developing "themselves and learning will be given the corresponding opportunities by us. People also learn through new tasks or an exciting new project.

Advancing and developing our

­employees is important not just for the individual employee but also for the company so that it is in a strong position for the future.

Marion Mestrom,

Chief Human Resources Officer,

Brenntag Group

In addition, personnel development programmes play a key role. Our training options have a long-term focus and consist of a mix of internal and external training courses as well as "micro-­learning". This includes 15-minute videos, short online training modules and TED talks1). Nobody is excluded from personnel development. On the contrary, we see it as an opportunity for every employee who wants to develop further. With regard to our programmes for new employees and our management positions, for some time now our focus has been on the advancement of women to ensure a balanced and diverse group of participants.

  1. TED stands for Technology, Entertainment, Design. Short lectures in which an idea is presented as appealing and entertaining as possible.

How does career and succession ­planning work at Brenntag?

At Brenntag, everyone who wants to should be able to develop themselves in a targeted manner and allow their talents to unfold. For those who want to make a career at Brenntag, performance is also important, of course. At least once a year, we conduct People Performance Dialogues with all employees. These dialogues take place between an employee and their manager, during which they discuss individual targets as well as growth potential. We want to provide our employees with further training in line with their potential. An employee's personal commitment and willingness to develop will also have a positive impact on potential career opportunities.

Our aim is to be able to provide individual and systematic support within this process, and we are working to achieve this. Advancing and developing our employees is important not just for the individual employee but also for the company so that it is in a strong position for the future.

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26

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More about

EXPLORE VARIETY can be found on the Brenntag career pages atwww.brenntag.com.

HR PORTAL:In order to implement and manage our globally standardized HR processes in the areas of employee recruitment, employee retention, feedback dialogues, HR development, identification and development of potential, and succession planning, we have introduced a global HR management system and already replaced many of the previous applications in our heterogeneous HR system landscape by the new system. In the year under review, for example, our recruitment module including an external and internal job platform went live globally. The learning module in this system should be introduced by the end of 2020, replacing our existing e-learning system. This will enable us to manage all HR processes throughout the Group in an integrated sys- tem. In the year under review, our feedback dialogues and target agreements were made available via the system for approximately 90% of our employees, while annual salary reviews were conducted using the HR portal for almost half of our employees.

JOB ARCHITECTURE:A framework that comprises and organizes all positions worldwide at Brenntag. The global job architecture offers us the transparency to identify career opportunities within a job family and across several job families, for example, and to devise and offer needs-based training and development measures. At the same time, the global job architecture serves as a basis and resource for implementing and enhancing measures in relation to employee recruitment, employee retention, feedback dialogues, HR development, identification and development of potential, and succession planning, all of which are described in the following sections.

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RECRUITMENT AND RETENTION OF TALENTS

We strive to provide a working environment where the best people want to work. It is the people who make up Brenntag, our market-leading position, safety culture and diversity. These are the foundations of our new "Explore Variety"employer brand that we introduced worldwide in the year under re- view. In doing so, we are taking another step towards positioning ourselves as the global employer of choice for current and future employees.

EMPLOYER BRAND:A modern, attractive employer brand with a uniform presence on all job markets is not just about the company's external image, but also strengthens the common identity of the people within the company. "Explore Variety" is a promise to future employees as well as to those who have been working at Brenntag for a long time and are familiar with the compa- ny. It focuses attention on the people­ who contribute to the company's success by passing on their knowledge and passion, by ensuring diversity and by energizing the employer brand. Team spirit, a familiar atmosphere, a good work culture and career opportunities are what set Brenntag apart as an em- ployer, today and in the future.

JOB PORTAL:In addition to the new employer brand, a new global job applicant platform has been launched. It allows applicants to search for all vacant positions worldwide at Brenntag and apply directly online. The new applicant platform is thus a further indicator of the wide-ranging diversity that Brenntag has to offer. Brenntag employees from all over the world can also view job advertisements via the "Career Center" on Brenntag's internal HR portal.

DIVERSITY THAT CONNECTS: By contributing with their different talents, Brenntag employees create a common identity.

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FEEDBACK DIALOGUES:Annual feedback dialogues, which take place for all employees, are an instrument which is used to ensure long-term employee retention at our company. In all Brenntag companies, the dialogue between employees and their line managers promotes a feedback culture while also encouraging a change and performance culture. These meetings consider employees' performance and discuss their goals and personal expectations as well as individual development measures. By integrating our globally standardized "People Performance Dialogue" into the Brenntag HR portal, we are able to conduct and track the process efficiently.

HUMAN RESOURCES DEVELOPMENT AND TALENT MANAGEMENT

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Employees

27

640

locations in

77 countries -

this creates great cultural diversity at Brenntag.

The objective of the Global HR Development & Talent Management Team is to develop and implement suitable human resources development concepts based on our global HR strategy and in line with our corporate strategy. Brenntag's HR development strategy includes measures for all groups of employees to ensure that our employees receive appropriate training and that crucial positions are filled at Brenntag in good time and in line with requirements.

Monitoring the level of employee turnoveron the basis of employee termination provides an indicator which can be used to identify a specific need for action. This key figure is centrally determined every quarter for each Brenntag company and

reported to the Group's HR management. Due to regional­ and country-specific variations, the figures are analyzed at local­ level. In the event of atypical deviations, the causes are iden- tified, and suitable measures are considered as needed.

IDENTIFICATION AND DEVELOPMENT OF POTENTIAL: In order to foster internal careers and to ensure the emergence of a new generation of Brenntag managers and experts, there is

  1. global concept for identifyinghigh-potential employees who fulfil our global criteria and are distinguished by their particularly strong performance. This approach enables us to identify employees with strong development potential at an early stage so that we can enhance their skills and provide the structure to prepare them for the next potential step in their career.

Our global development programme "Connecting ­Potential" for high-potential employees who are at the start of their career takes place annually with a total of approximately 60 participants in all regions. We also initiated additional global development programmes for further management levels

in the year under review. For example, our global programme "Leading with impact"for experienced high-potential employees was successfully launched and the customized "Leader Excellence Acceleration Program" was set up. The modular programme was developed in partnership with a renowned business school and tailored to the needs of our top management level. The programme will start for the first time in spring 2020.

SUCCESSION PLANNING: Succession planning and structured, proactive HR development are closely associated with the identification of potential, which puts these issues on the list of priorities for our HR strategy. As part of our global "People Review" process, management and HR officers proactively develop strategic succession scenarios, identify employees for vertical and horizontal career moves on a structured basis and devise corresponding development options and needs. Due to its importance, the Chief Human Resources Officer regularly discusses succession planning for global executive management with the Board of Management. The global standard process is continuously expanded to include key positions at additional levels.

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More information about

theLEADING WITH

IMPACTprogramme ­ on page 28.

EMPLOYEE TURNOVER indicators can be found on page 33.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

28

TEAM BRENNTAG KOREA:The Employee Engagement Workshop in Korea gave employees new impulses and promotes cooperation and open communication.

For information on COMPLIANCE TRAININGS, please see the Sustainability at Brenntag chapter on page 15f.

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PROGRAMMES AND TRAINING:At Brenntag, we want to create a working environment where each individual can recognize and take advantage of the development opportunities that exist at our company. In line with the Group's global concept, Brenntag-specific skills and expertise are taught through a globally uniform approach. Under the umbrella of the "Brenntag Academy", target group-specific and individual measures and training are offered at a global, regional and local level and, depending on the nature of this measure or training, are provided either in conventional events attended in person or through online training events.

Our global e-learning management system provides our employees with a flexible and digital-based opportunity to enhance their knowledge and skills independently and ­efficiently. By offering a comprehensive range of specific and interdisciplinary training with presentations, videos and additional reference materials for self-learning, we foster a culture of autonomous learning. We also reach all of our employees with access to a PC via our online platform, making it easier for them to take part in mandatory global and

regional compliance­ trainings, such as on the Brenntag Code of Business Conduct and Ethics, anti-corruption, antitrust law, fraud prevention and the EU's General Data Protection Regulation. In 2020, the existing system will be replaced by the learning module in our Brenntag HR portal so that all HR processes and measures can be linked to each other in a standardized system. To facilitate this, we analyzed our em- ployees' learning needs in the year under review based on current requirements and selected a corresponding range of training measures.

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At Group level and in Brenntag's re- gions, programmes are in place to meet the specific needs of our managers and junior staff, in order to prepare them for their responsibility as managers or experts and to support them in their role. As well as providing and enhancing management skills, in these development programmes Brenntag aims to encourage the systematic and sustainable sharing and transfer of knowledge.

In the year under review, the new global­ development programme"Leading with impact" began for the first time with 24 participants. It is aimed at selected motivated and successful manag- ers, team leaders, project managers and functional heads who have a decisive influence on our business. The programme brings together experienced high-potential employees at global level and helps them to further develop their personal and leadership skills so they can drive innovation and change and secure Brenntag's global success.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

Various further training measures that place a particular em-

phasis on personal development in addition to expert know­

ledge are offered to our specialist employees and managers in

Germany, Austria and Switzerland. For example, "MOVE" is a

workplace-based development programme which is offered to

dedicated employees in specialist careers. The programme,

which has been in existence since 2008, was redesigned in

2019 due to advanced developments and changes in learn-

ing methods. The areas of focus in the new format include

communication skills, self-reflection, personal autonomy

and flexibility as well as digitalization. The new programme

"MOVE - New Learning Journey" started at the end of 2019

with 12 participants­

.

In many countries, trainee programmes enable university­

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graduates to combine their theoretical knowledge with

practical experience while gaining an insight into our com-

pany's many different areas. The specific trainee programmes

for management or specialist careers which are offered in

Germany,­

Austria and Switzerland also provide an incentive

to gain international experience. To date, more than 30 career

entrants have completed these trainee programmes.

Due to the various regional and local requirements of the

working environment as well as cultural differences, Brenntag

largely takes charge of and manages individual further train-

ing and development measures on a decentralized basis.

Our employees receive training in accordance with their du-

ties in the company and their personal development needs.

The training measures, which take the form of face-to-face

events, courses and workshops as well as online seminars,

cover technical topics - including sales, logistics, chemistry,

environmental protection and quality management - as well

as personal development measures such as intercultural train-

ing, negotiating skills, presentation techniques and conflict

management. In every Brenntag region, occupational safety

is a core topic for training, since protecting our employees'

health and safety is a top priority for us.

APPRENTICESHIPS:As a recognized training company, Brenntag

offers an extensive range of training positions in a forward-­

looking industry in Germany, Austria and Switzerland. Via

the dual education and training system, we are currently

training 80 young people to become management assistants

in wholesale and foreign trade, management assistants in

operations logistics, office managers, IT experts, warehouse

staff, laboratory technicians, chemists, process mechanics

and production staff. Alongside comprehensive apprentice-

ship opportunities and the acquirement of specific skills and

expertise, priority is given to the transfer of our corporate

culture and company-­specific working processes as well as

the personal development of the apprentices. Brenntag trains

junior managers and experts in a targeted manner, thanks to

the wide array of apprenticeships on offer in the various oc-

cupational areas. Once they have successfully completed their

apprenticeships, Brenntag offers young key players attractive prospects and challenges. In the year under review, Brenntag received 4 out of a possible 5 stars in the "Germany's best trainers" survey by the business magazine Capital (issue 11/2019), making it one of Germa- ny's top training companies.

EMPLOYEE COMMUNICATION AND INVOLVEMENT

In addition to development prospects, open communication and an opportunity to play a part in shaping the company are important aspects which help to promote employee motivation and loyalty. Brenntag's employees are regularly kept informed of current issues and company matters through their line managers and also through our internal print and online media. Conversely, our employees are able to discuss issues directly with their line managers or with the personnel managers responsible at any time.

Depending on the country-specific leg- islation, employees can also contact the persons representing their interests on elected co-determination bodies. Brenntag respects its employees' right to freedom of association and collective bargaining and will not pursue or tolerate any measures which are intended to restrict these rights.

The internal online portal "LINK" supports and promotes the flow of informa- tion, communication and cooperation between Brenntag employees across different locations. This platform brings together our employees and facilitates the transfer of knowledge while offering an opportunity to share information, experiences and best-practice methods from different areas.

Employees

29

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For information on training courses in the area of OCCUPATIONAL SAFETY, please also see the Safety chapter on page 39ff.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

30

See also the

INTERVIEW WITH MARION MESTROM on page 24f.

Brenntag also has idea management systems and platforms at many levels, which employees can use to become actively involved and submit their suggestions and ideas for improving organizational aspects, processes and operations.

The purpose of the "Brenntag Outstanding Performance Award" is to acknowledge and reward those employees who have ­delivered outstanding performance on an annual basis. Receiving the award, or simply being nominated for it, represents an award in itself, for both the individual employee and the Brenntag unit that he or she represents; it thus reflects the high standards in place in terms of leadership, training and commitment to achieving top performance. Each Brenntag region and the company's headquarters in Essen presents the global and regional awards every year to employees who have achieved outstanding success in the areas of sales, safety or professional performance.

HEALTH AND WORK-LIFE BALANCE

Brenntag's identity as an attractive and responsible employer includes promoting the health of our employees and their work-life balance. In all regions, we therefore offer measures which are in line with local social systems, while frequently going beyond national practices and statutory requirements. In countries with inadequate social security arrangements for example, supplementary private health insurance and life assurance policies are offered. In many countries, Brenntag also covers part of the cost of preventative measures or medical examinations and pays for vaccinations for its employees and their families. Brenntag also promotes its employees' physical fitness. For instance, individual companies contribute towards gym memberships or initiate campaigns and events which provide tips on healthy eating and lifestyles. Joint participation in company runs and other sporting competitions are also very popular. Many Brenntag companies help their employees to reconcile work and family life by offering flexible working time models and holiday arrangements as well as other supportive services such as childcare or care for rel- atives. Regular initiatives also take place at many Brenntag locations, when employees can show their relatives where they work or when families are invited on group excursions.

DIVERSITY, EQUAL OPPORTUNITIES AND INTEGRATION

Our culture of fairness, of mutual appreciation and support, is the foundation of our day-to-day activities and is embedded in our core values. For us, diversity means recognizing, valuing and respecting differences. It fosters a dynamic work environment where everyone can learn from each other. Diversity­

is a fundamental feature of Brenntag. This also includes the cultural backgrounds, qualifications and needs of our

employees. At its more than 640 sites in 77 countries, Brenntag employs people from almost 100 different nations and a wide range of backgrounds. By sharing­ their knowledge, experience, ideas and passion, our employees contribute to the success of our company. We work in ­multinational, interdisciplinary teams around the world to create value for our partners and employees.

In order to firmly embed diversity, equal opportunities and inclusion, not just in our business strategy and our objectives but also in our culture, we launched an internationally organized committee for diversity and inclusion at the start of 2019. The committee is comprised of representatives from various areas across all regions and aims to increase awareness of diversity and inclusion in our daily business and at all levels of our organization. To support our managers with their duty to deal with differences appropriately and create an inclusive work environment on this ­basis, in 2019 we held a workshop on "dismantling subconscious prejudices" with the aim of increasing their awareness of this issue. We plan to focus more on this issue from 2020 onwards and raise its importance within the organization. As a first step, a mentoring programme and other employee training measures will be introduced.

We celebrate the wide-ranging diversity of our employees. Guaranteeing equal opportunities is a matter of course for Brenntag, as is counteracting and eliminating any form of discrimination and harassment. The recruitment, remuneration and development of employees solely reflect their qualifications and abilities in relation to their respective duties. For Brenntag, it is a matter of course and of the utmost importance that employees, business partners and third parties do not suffer any discrimination on grounds of their ethnic

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

Employees

31

"INITIATIVE WOMEN INTO LEADERSHIP": Brenntag is a founding member of the "Initiative Women into Leader- ship" (IWiL). After a successful graduation, the first mentee year had their farewell with a festive ceremony at Brenntag's headquarters in Essen. The new mentee year of the IWiL programme will also take place with the participation and support of Brenntag.

origin, gender, marital status, age, religion or belief, skin col- our, physical and mental abilities or sexual orientation. This is stipulated in our Code of Business Conduct and Ethics. Violations of this code are investigated by our compliance organizationwith the necessary rigour and, if a violation is found to have occurred, remedial and disciplinary action is taken.

REMUNERATION AND PENSION SCHEMES

Brenntag's remuneration policy is defined by factors such as attractiveness, fairness and competitiveness. Employees' qual- ifications, experience and level of responsibility are the main criteria. We offer a competitive remuneration and benefits package. Remuneration may vary in line with local market conditions, regulations and legislation. The value-based remuneration system for management level consists of three components: a fixed annual base salary, a short-term variable­ annual bonus and long-term variable remuneration. The ratio­ of fixed to variable remuneration depends on a specific man- ager's influence on the company's success. Variable remuneration is closely linked to personal performance and the company's results, and is also dependent on whether targets for key performance indicators (KPIs) are met. In addition to the aforementioned remuneration components, managers receive contractually agreed non-cash remuneration and other benefits.

There are both defined benefit and defined contribution pension plans for the employees of the Brenntag Group. The pension commitments vary depending on the legal, tax and economic circumstances in the individual countries and the employee's years of service with the company and pay grade. In addition to employer-financed company pension schemes, Brenntag also supports private pension schemes through various options and pension plans. For in- stance, through a deferred compensation scheme employees are able to forgo payment of specific pay components in favour of an employee-funded company pension commitment.

SeeCOMPLIANCE INCIDENTS on page 16.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

32

EMPLOYEE STRUCTURE

The number of employees indicated is shown on the basis of the Group's headcount as at the end of the year (Dec. 31).

EMPLOYEES BY REGION AND GENDER

EMPLOYEES IN MANAGEMENT POSITIONS1)BY GENDER

2019

2018

2017

2019

2018

2017

abs.

in %

abs.

in %

abs.

in %

abs.

in %

abs.

in %

abs.

in %

EMEA

7,524

43.0

7,162

43.1

7,023

45.6

Women

72

19.1

78

20.1

58

15.3

Women

2,831

37.6

2,677

37.4

2,634

37.5

Men

304

80.9

310

79.9

320

84.7

Men

4,693

62.4

4,485

62.6

4,389

62.5

Brenntag

Group

376

100.0

388

100.0

378

100.0

North America

5,257

30.0

5,174

31.1

4,747

30.8

Women

1,183

22.5

1,162

22.5

1,034

21.8

Men

4,074

77.5

4,012

77.5

3,713

78.2

EMPLOYEES BY TYPE OF EMPLOYMENT AND GENDER

Latin America

1,934

11.1

1,610

9.7

1,453

9.4

Women

742

38.4

654

40.6

545

37.5

2019

2018

2017

Men

1,192

61.6

956

59.4

908

62.5

abs.

in %

abs.

in %

abs.

in %

Asia Pacific

2,572

14.7

2,486

15.0

2,043

13.2

Full-time

16,838

96.3

15,978

96.2

14,805

96.0

Women

1,034

40.2

987

39.7

958

46.9

Women

5,398

32.1

5,093

31.9

4,812

32.5

Men

1,538

59.8

1,499

60.3

1,085

53.1

Men

11,440

67.9

10,885

68.1

9,993

67.5

Other

segments

205

1.2

184

1.1

150

1.0

Part-time

541

3.1

550

3.3

519

3.4

Women

91

44.4

87

47.3

73

48.7

Women

438

81.0

441

80.2

394

75.9

Men

114

55.6

97

52.7

77

51.3

Men

103

19.0

109

19.8

125

24.1

Brenntag

Apprentices

113

0.6

88

0.5

92

0.6

Group

17,492

100.0

16,616

100.0

15,416

100.0

Women

45

39.8

33

37.5

38

41.3

Women

5,881

33.6

5,567

33.5

5,244

34.0

Men

68

60.2

55

62.5

54

58.7

Men

11,611

66.4

11,049

66.5

10,172

66.0

Brenntag

Group

17,492

100.0

16,616

100.0

15,416

100.0

EMPLOYEES BY TYPE OF EMPLOYMENT AND GENDER

2019

2018

2017

EMPLOYEES BY TYPE OF CONTRACT AND GENDER

abs.

in %

abs.

in %

abs.

in %

2019

2018

2017

Sales

6,446

36.9

6,348

38.2

5,859

38.0

abs.

in %

abs.

in %

abs.

in %

Women

3,242

50.3

3,079

48.5

2,897

49.4

Permanent

Men

3,204

49.7

3,269

51.5

2,962

50.6

contracts

15,401

88.1

15,881

95.6

14,367

93.2

Distribution

2,528

14.5

2,305

13.9

2,160

14.0

Women

5,006

32.5

5,253

33.1

4,794

33.4

Women

270

10.7

250

10.8

210

9.7

Men

10,395

67.5

10,628

66.9

9,573

66.6

Men

2,258

89.3

2,055

89.2

1,950

90.3

Fixed-term

Warehouses

5,318

30.4

4,977

29.9

4,647

30.2

contracts

1,978

11.3

647

3.9

957

6.2

Women

561

10.5

535

10.7

516

11.1

Women

830

42.0

281

43.4

412

43.1

Men

4,757

89.5

4,442

89.3

4,131

88.9

Men

1,148

58.0

366

56.6

545

56.9

Administration

3,200

18.3

2,986

18.0

2,750

17.8

Apprentices

113

0.6

88

0.5

92

0.6

Women

1,808

56.5

1,703

57.0

1,621

58.9

Women

45

39.8

33

37.5

38

41.3

Men

1,392

43.5

1,283

43.0

1,129

41.1

Men

68

60.2

55

62.5

54

58.7

Brenntag

Brenntag

Group

17,492

100.0

16,616

100.0

15,416

100.0

Group

17,492

100.0

16,616

100.0

15,416

100.0

1)Comprises the global executive management and local management groups.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

NEW EMPLOYEES BY TYPE OF ENTRY

2019

2018

2017

abs.

in %

abs.

in %

abs.

in %

New hires

2,701

74.3

2,824

72.2

2,346

94.0

Company

acquisitions

934

25.7

1,090

27.8

149

6.0

Brenntag

Group

3,635

100.0

3,914

100.0

2,495

100.0

NEW EMPLOYEES BY REGION

2019

2018

2017

abs.

in %

abs.

in %

abs.

in %

EMEA

1,296

35.6

1,212

31.0

855

34.3

North America

1,107

30.5

1,321

33.8

908

36.4

Latin America

579

15.9

412

10.5

198

7.9

Asia Pacific

589

16.2

938

23.9

516

20.7

Other

segments

64

1.8

31

0.8

18

0.7

Brenntag

Group

3,635

100.0

3,914

100.0

2,495

100.0

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EMPLOYEE TURNOVER2)BY REGION

2019

2018

2017

abs.

in %

abs.

in %

abs.

in %

EMEA

529

6.2

501

6.1

446

5.6

North America

538

8.2

620

10.2

488

8.9

Latin America

135

6.1

122

6.5

131

7.4

Asia Pacific

353

11.4

385

13.0

326

12.7

Other

segments

21

8.8

16

7.8

6

3.7

Brenntag

Group

1,576

7.6

1,644

8.5

1,397

7.7

Employees

33

EMPLOYEES BY AGE3)

2019

2018

2017

abs.

in %

abs.

in %

abs.

in %

< 20

48

0.4

33

0.3

26

0.2

20 - 29

1,598

13.1

1,562

13.7

1,453

13.6

30 - 39

3,792

31.0

3,580

31.3

3,216

30.1

40 - 49

3,499

28.6

3,297

28.8

3,124

29.3

50 - 59

2,706

22.1

2,461

21.5

2,322

21.8

> 59

592

4.8

509

4.4

528

5.0

Brenntag

Group

12,235

100.0

11,442

100.0

10,669

100.0

AVERAGE AGE AND LENGTH OF SERVICE BY REGION3)

2019

2018

2017

2019

2018

2017

Ø-age

Ø-length of service

in years

in years

EMEA

44

43

44

11

11

11

Latin

America

40

40

40

7

7

7

Asia Pacific

39

38

38

7

6

6

Other

segments

43

43

45

9

10

11

Brenntag

Group

42

42

42

9

9

10

  1. Termination of employees on the basis of the Schlüter formula.
  2. Excluding employees in the North America region; due to the legal situation in
    North America, the data in the region are not recorded in full for all employees and therefore cannot be evaluated on a valid basis.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

03

GLOBAL

IMPACT. OUR FUTURE IN MIND.

68 points

  • gold status in the EcoVadis sustainability rating

TABLE OF CONTENTS

SAFETY

35

SAFETY

Safety is of paramount importance at Brenntag and is part of our corporate strategy. "We are the safest chemical ­distributor"

  • this is the primary objective of our corporate vision. World- wide, we operate in accordance with the "Safety First" principle as our most important company value. This applies both to the safety and health of our employees, as well as to product safety and environmental protection. We are bound by the highest standards in the industry and adopt policies which often ex- ceed statutory requirements. We are working continuously to further improve safety within our company. We invest in our infrastructure and train our employees with this goal in

mind. Our goal is to keep our Group accident rateLTIR1 day/1 millionbelow 1.0 by 2020.

HSE STRATEGY AND MANAGEMENT

Brenntag has implemented a global health, safety and environment (HSE) strategy. This contains our principles in the areas of safety, product stewardship, the environment, adherence to laws (compliance) and quality. The global strategy is implemented in the regions as part of their own HSE programmes.

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Brenntag's global business operations and highly diversified customer and supplier structure imply a diverse range of operating conditions (legisla- tion, cultures, industry standards and other demands). In order to fulfil the resulting requirements as effectively­ as possible, Brenntag adopts a predominantly decentralized approach to its HSE management.

The operations and HSE managers responsible­ at regional level, together­ with the central Corporate Health,

Safety­ & Environ­ment department, form Brenntag's Global HSE Team. The team develops and coordinates globally­ applicable policies, programmes and other activities and regularly shares its experiences.

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For information on the current GROUP

ACCIDENT RATE,

see page 40.

SAFETY

HSE ORGANIZATION AT BRENNTAG

BOARD OF

MANAGEMENT

Operations and HSE managers

Chairman

of the regions

Corporate Health, Safety &

(North America, Latin America,

GLOBAL HSE TEAM

Environment department

EMEA, Asia Pacific)

GLOBAL HSE TEAM

Regular exchange

Team composition

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

36

HSE AT BRENNTAG: OUR APPROACH

COMMITMENT TO THE PRINCIPLES OF OUR RESPONSIBLE CARE/RESPONSIBLE DISTRIBUTION PROGRAMME

Product stewardship

Occupational health

Comprehensive protection of

and product safety

and safety, including

the environment (air, water,

transportation

soil, raw materials and waste)

THE BRENNTAG APPROACH

SAFETY AND SAFETY

HSE PROGRAMMES

CLEAR GUIDELINES

APPROPRIATE

REGULAR INTERNAL

CULTURE AROUND

AND REGULAR

AND PROCEDURES

TECHNOLOGY

AND EXTERNAL

THE WORLD

TRAINING

REPORTING

For information on the ENVIRONMENTAL

PROVISIONS, see page 142f. ofBrenntag's 2019 Annual Report.

For theMANAGEMENT SYSTEMS see page 37.

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The chairman of the team regularly reports to the Board of Management of Brenntag AG. In order to further deepen their working relationship, every Board of Management member takes part at least once a year in the Global HSE Team's regular phone conferences or meetings.

There are HSE organizations with similar structures within the regions, countries and down to the individual locations. All of this has created a global network of HSE managers and teams at the various levels within Brenntag. These experts regularly share their experiences in their teams, develop measures to remedy identified deficits and work together on further improving the company's safety culture.

Decisions taken by the teams are then incorporated into the regulations and programmes within the respective organization in a suitable format. The local management in the respective company unit or country is responsible for defining processes, procedures and measures in accordance with local regulations and taking account of local requirements.

Compliance with the HSE programme is reviewed through regular internal and external audits. The decision on the frequency of these audits depends on various factors, such as the risk potential being assessed, legal regulations and customer requirements.

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Brenntag manages HSE data in various databases at regional level that are forwarded to the company's central HSE department. Working together with external experts, the environmental risks including historical data are continuously examined and evaluated at each site. This allows conclusions to be drawn about potential contamination, among other things. This information is collated in a centralized ­environmental database and serves as a basis for the environmental provisionswhich are determined annually.

Brenntag has implemented various management systemsin order to ensure its compliance with applicable HSE standards. Our performance is also regularly assessed and certified by independent third parties.

To ensure effective chemicals manage- ment, data that are necessary for the safe handling of our products during

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

storage, transport and within the delivery chain are stored

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in central databases at Brenntag. In Europe, for example, a

central SAP-based system is used for this purpose, making it

possible to implement relevant changes to European legisla-

tion in all countries at the same time and provide employees

with access to them. All European companies are connected

to this database.

Certified and assessed

ISO 14001

OHSAS 18001

SQAS-ESAD2)

operating locations1)

(Europe)

abs.

in %1)

abs.

in %1)

abs.

in %

2015

105

26

59

17

78

73

2016

108

27

67

19

80

77

2017

109

26

65

17

72

71

2018

108

28

64

19

72

73

2019

115

29

72

21

61

64

  1. The percentage figures for ISO 14001 include purelysales-based locations as well as warehouse locations. The OHSAS 18001 figures exclusively refer to warehouse locations.
  2. SQAS-ESAD(Safety and Quality Assessment System, European Single Assessment Doc- ument) is a catalogue featuring more than 500 detailed questions on the handling of chemicals. It is intended to provide a uniform assessment of the HSE and quality management system of chemical distributors and is associated with the Responsible Care/Responsible Distribution industry initiative.

PROCESS SAFETY

Process safety measures depend on the particular type of process and the risks associated with it. Many requirements are regulated by local legislation and industry directives, ­although standards often vary widely from country to ­country. If Brenntag considers these regulations to be insufficient, we establish our own more stringent measures, which are

defined­ in our HSE manuals.

The following aspects and levels of process safety are covered:

  • Use of suitable equipment
  • Work instructions on how to use the equipment
    correctly­ and safely and how to perform the process
  • Suitable technical and organizational safety measures that help to control process risks and prevent errors
  • Regular reviews (inspections, audits)
  • Regular checks of whether the specified inspections, audits and reviews have been conducted as scheduled and corrective measures have been implemented

PRACTICAL EXAMPLES

Brenntag EMEAhas specified four of its procedural instructions as "Critical Procedures". Failure to adhere to the measures described could lead to significant risks. These include the handling of flammable liquids. Additionally, in 2018 a special

compliance audit programme was developed for these instructions and an audit catalogue was created. An audit team of 18 Brenntag experts from several countries was then trained in accordance with this catalogue. In 2019, these experts audited a total of 29 Brenntag locations extensively. During these audits, risks were identified, assessed and classified, and the timeframe for eliminating the risk in question was specified. The auditors were also involved in implementing the agreed action plans. As a rule, the various locations welcome information about existing risks and how to improve process security. In turn, the auditors can expand their knowledge by auditing locations outside their own region. Since the auditors do not just document the risks but also collect best-practice solutions to specific problems, the entire Group benefits from this knowledge transfer. Management also regarded the results achieved as a success. A further 34 audits are planned for 2020.

The multi-stage plan to improve the fittings and safety of pallet shelves in accor­ dance with the corresponding guidelines is now complete in Europeapart from a small number of exceptions. In North America, work in this area still requires more time.

The integrated IT system for stock man- agement, product tracking and transport management at Brenntag North Americaand Brenntag UK & Irelandhas been enhanced and an improved version developed. This system makes it possible to track goods on a paperless and real-time basis as they are moved from our suppliers to our plants and to the customer, thereby minimizing the risk of product mix-ups and incorrect deliveries. It is planned to gradually roll out the new version across Europe over the coming years.

SAFETY

37

FURTHER EXAMPLES

are presented on our website at www.brenntag.com/ sustainabilityunder Projects Worldwide.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

38

Since 2002 Brenntag has been participating in the chemical industry's "Responsible Care" programme.

NFB

In 2018, the global Misload Control and Prevention programme was launched. To begin with, a globally standardized definition was specified and a data analysis was initiated: A misload occurs when Brenntag or a service provider operating on behalf of Brenntag delivers an incorrect product or a product in the incorrect packaging or a product to the incorrect location. In 2019, Brenntag EMEAincreased its efforts to avoid and reduce misloads. It is a complex issue, as there are many points between ordering and delivery where an error could occur. Accordingly, an eight-member task force was established with representatives from HSE, Operations, Sales, HR, various EMEA national organizations and the Group headquarters. The task force gathers ideas and develops measures to reduce and prevent misloads. As part of a targeted campaign, training and communication measures are also conducted for the relevant employee groups from Sales, Customer Service, Production Planning, Storage, Logistics and Transport in order to increase awareness of the problem and attentiveness among them. The package of initiatives and measures developed by the task force also includes a new online training course and a range of information materi- al. In addition, internal processes and IT are optimized and experiences are shared in detail within the countries of the EMEA region.

PRODUCT STEWARDSHIP AND SAFETY

Brenntag takes appropriate measures to ensure the proper handling of our products. This mainly relates to procurement, packaging, classification and labelling, handling, storage and transportation. We produce product dossiers and safety instructions and ensure disposal. We act in accordance with the applicable standards and regulations and also cooperate closely with the industry's national and regional umbrella associations of which our national companies are members.

RESPONSIBLE CARE/RESPONSIBLE DISTRIBUTION: For many years now, Brenntag has taken part in the Responsible Care/Re- sponsible Distribution (RC/RD) programme of the International Chemical Trade Association (ICTA). As such, we implement the eight guiding principles laid down in this global programme covering the following areas:

  • Legal requirements
  • Management of risk
  • Policies and documentation
  • Provision of information
  • Training
  • Emergency response
  • Ongoing improvements
  • Community interaction

NFB

The policies of the RC/RD programme

have been incorporated into our HSE

strategy and programmes and therefore

play a key part in the safe handling of

chemical products and, as a result, in the

protection of soil, air and water as well as

occupational safety within our company.

Adherence to these policies is verified

and documented by external assessors.

Brenntag has also specified that all

operating­

companies join the RC/RD pro-

gramme. Due to the fact that an RC/ RD

programme is not offered by national

organizations in every country in which

Brenntag operates, programmes have

been developed and existing processes

optimized in the individual regions to

verify internally that the guidelines in

force in the relevant countries are ad-

hered to. In this way, Brenntag compa-

nies play their part in the global obliga-

tion towards Responsible Care.

Brenntag's high standards in process

safety and product responsibility con-

tinuously earn the company external

recognition. In 2019, all North American

sites where chlorine is filled and bleach

is produced were rewarded for their ex-

emplary safety performance - with six

of them obtaining "Diamond Level". The

Chlorine Institute, a national industry

association, grants its so-called Diamond

Level award to sites which have record-

ed zero workplace accidents or incidents

and zero environmental releases over a

period of at least five years.

NFB

Year1)

Proportion of Brenntag legal

entities participating in the

RC/RD programme2)

abs.

in %

2015

108

76

2016

113

76

2017

114

76

2018

106

81

2019

108

78

  1. The values given for 2015 to 2016 have not been audited­ by PwC.
  2. These data do not include pure sales and service en- tities with revenue of under EUR 100,000 or acquired entities which, as at December 31, 2019, have been part of the Brenntag Group for less than a year.

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39

As a chemical distributor, Brenntag generally operates in a complex regulatory environment. Examples of this in Europe would be the REACH Regulationor the Biocidal Products Regulation of the European Union. Our transnational teams of experts, consisting of a network of experienced HSE and regulatory specialists, ensure that our operational processes and work- flows comply with the relevant regulations. They work closely­ with management in both purchasing and sales to ensure that Brenntag complies professionally, fully, and efficiently with the numerous­ regulatory requirements.

Our product and sales managers are trained and experienced in supporting our suppliers and customers in fulfilling regulatory requirements according to their wishes by:

  • Ensuring aREACH-compliant supply and usage system
  • Providing support in relation to many further questions
  • Safeguarding optimal communication within the ­ supply chain
  • Identifying alternative substances

OCCUPATIONAL SAFETY

Our top priority is to ensure the safety of our employees and to protect their health. This means that we continually work towards improving the company's safety culture and take necessary and appropriate measures to prevent accidents and incidents.

TRAINING AND EQUIPMENT:Regular training of our employees is important in order to raise their awareness of potential hazards and to enable them to work safely. This training goes above and beyond the statutory requirements, and ranges from safety instructions for new employees to comprehensive training measures that are specially tailored for the work situation and the risk potential of specific occupational groups or individual employees. Training is given by HSE managers and also by external experts, both in the form of face-to-face events as well as digitally. In the year under review, we continued to focus on training our employees at all levels on a wide range of issues. For example, Brenntag North America­offered a specific training programme for managers and line managers which is run by an external provider and has proven its value over many years. The programme provides them with the techniques and skills they need to make lasting improvements to the safety culture within their area of responsibility. 72 participants completed the programme in the year under review.

NFB

Brenntag continuously invests in its equipment and infrastructure in order to optimize plant safety and work processes at its sites and thus further minimize safety risks and hazards. For exam- ple, Brenntag audited safety harnesses used for work operations on road tankers and rail tank cars in the year under review by launching a long-term project to improve this safety equipment. To ­begin with, this involved carrying out detailed site-based reviews of the various systems in place. Using action plans, the companies at Brenntag North Amer- icaachieved around 75% of the agreed improvements by the end of 2019 and invested several million dollars in the process. Brenntag EMEAlaunched this project at a later stage and is therefore still at the planning stage with regard to the structured implementation of improvements. However, it has already made some investments. The project is continuing in 2020.

ACCIDENT REPORTING: Accidents at work,

near misses and similar occurrences­are recorded and evaluated centrally according to a standardized system. Any important conclusions are communicated throughout our organization. Further- more, the findings and the measures derived from these are incorporated into the global HSE guidelines, regional HSE manuals and prevention and training measures. As an enhancement to the existing accident reporting system, Brenntag introduced the so-called "poten- tial hurt level" model at the end of 2019. With this model, accidents are assessed not just according to the actual severity of the injuries suffered but also according

NFB

Further information on REACHcan be found on the website of the Federal Environment Agency www.Umwelt- bundesamtes.de/themenin the area chemicals.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

40

NFB

SAFETY

to how severe the injuries could potentially have been when the accident occurred. The aim of this enhanced assessment is to focus our countermeasures better on the most important aspects of accidents.

GROUP ACCIDENT RATE1)

LTIR1 DAY2)

1.9

1.6

1.7

1.5

1.5

2015

2016

2017

2018

2019

1)The values given for 2015 to 2016 have not been audited by PwC.

  1. LTIR1 day(Lost Time Injury Rate): number of industrial accidents resulting in at least one day's absence from work per one million working hours.

This ongoing process of improvement has enabled us to steadily reduce the number of reportable industrial accidents within the Group over many years. Unfortunately, this trend has not progressed as continuously in recent years, and we have to report a year-on-year increase for 2019 for the second time since 2017. Overall, however, we were able to reduce the Group accident rate between 2010 and 2019 by 58%. In 2019, the value was 1.9.

In 2019, the accident rate rose in all four regions. However, the trends have varied. After recording good results in 2018, there were slight increases in both Asia Pacific and Latin America in the year under review. In North America, the total number of reported accidents fell significantly. Compared to previous years, however, an unusually high number of these accidents led to work absences and therefore to an increase in the relevant accident rate. The negative trend at Brenntag EMEA was strongly influenced by high accident numbers at specific locations.

A closer analysis of the accidents shows that slips/trips/falls, contact with chemicals, accidents involving vehicles and

accidents­ involving equipment/tools are the most common causes of injuries and absences from work at Brenntag. Our

measures are therefore focused on making improvements in these areas. With regard to injuries resulting from contact with chemicals in particular, which is an industry-specific injury, a wide range of measures enabled us to reduce the number of incidents Group-wide by 75% between 2010 and 2018. However, there was a significant increase again in the year under review. Almost all of this was due to chemical burns or irritation to the neck and head, and in particular to the eyes. Our priority here must be to continue working on preventing direct contact with chemicals. ­However, we also need to improve the correct use of personal protective equipment such as safety goggles and visors by conducting training sessions and regular checks. Although the number of injuries caused by slips/trips/falls was reduced again in the year under review, it still remains at a high level. In almost all cases, these accidents were caused by a lack of attention and incorrect behaviour. At the end of 2018, Brenntag established a task force that will continue working on the campaign to reduce these accidents. Having stayed relatively constant for many years, the number of accidents involving vehicles (forklift trucks, trucks, cars, motorbikes) almost doubled in the year under review. This was primarily due to an increase in traffic accidents that were difficult, if not impossible, to avoid for the Brenntag employees concerned. However, there was also a slight rise in the number of accidents involving internal transport. This increase occurred despite extensive preventative programmes that have been established in the Brenntag regions in recent years. The focus ranges from driving safety training, including for sales employees, to the use of devices to analyze driving in trucks, to improved road signage for internal transport and for pedestrians at the locations.

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SAFETY

41

More than 1,300 employees in 20 countries within the EMEA regionreceived online training from an external provider in each quarter on a topic related to safe driving. After two years, the programme is now completed.

Since 2014, Brenntag North Americahas had particularly posi­ tive experiences using a system that records driving behaviour and traffic situations with a video camera in its trucks. If necessary, truck drivers can then analyze critical situations and unsafe behaviour with their direct managers using video clips. The technology used was replaced with an improved version, and the partnership with the external service provider­

for the video programme was extended by several years. The Brenntag fleet in North America covered around 50 million miles in 2019. Since the programme was introduced, the number of accidents per 1 million miles travelled has decreased by 75%.

Brenntag EMEAcontinues to conduct special hazard analyses for transport on the grounds of its sites. Wherever there is increased potential for accidents, suitable measures are im- plemented: ranging from the simple installation of mirrors to the clear separation of pedestrian paths and vehicle roadways, right up to investment in vehicles and construction activities.

CAUSES OF LOST TIME INJURIES 2019

(IN %)

20

28

6

22

24

Slips, trips, falls

Manual handling

Contact with chemicals

Vehicles, forklifts

Facilities, equipment, tools

BRENNTAG HONDURAS - HONOURED: For the third time in a row, the Brenntag terminal location received an award from the municipality of Puerto Cortés for the exemplary implementation of local environmental regulations.

Brenntag's primary objective is to prevent all types of accidents and incidents. With a view to the development of the number of accidents, we are continuously working on further improving our safety culture.

BEST PROGRAMME:A key element of our efforts to increase safety is the global­ Brenntag Enhanced Safety Thinking (BEST) programme. It focuses on the safety behaviour of Brenntag employees at all levels within the company, which is a key cause of accidents in more than 75% of cases. Two BEST employee surveys were conducted between 2015 and 2018. According to the findings of the last survey, the participants believe that the safety culture is overall at a high level. Internal communication was regarded as having room for improvement. There were large regional differences. The results were incorporated into various action plans for the coming years that take account of the varying circumstances locally.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

42

"SAFETY WEEK" AT BRENNTAG-BENELUX:Safety at work is just as important as safety on the way to or from work. Safety tranings and crash tests during the Safety Week at Benelux locations were a special

­opportunity to prepare for critical situations in the car.

FURTHER EXAMPLES are presented on our website atwww.brenntag.com/ sustainabilityunder Projects Worldwide.

In order to expand the BEST ideas beyond occupational safety and into the personal sphere of Brenntag employees, Brenntag developed the BEST - Personal Safety Action Plan (PSAP). Since 2018, all Brenntag employees worldwide were asked to create a PSAP and list the risks that they encounter daily while at work as well as in their personal lives. Together with their respective line managers - who had been given special training in this area - they developed individual plans consisting of measures to prevent accidents and incidents. New PSAPs are developed every year.

PRACTICAL EXAMPLES

The following practical examples and highlights from our regions provide an insight into our diverse range of practices and safety culture at Brenntag.

Brenntag locations and individual companies frequently dedicate an entire day to the issue of safety. Brenntag Latin America, for example, holds its CASA1)Day every year. Many companies in Brenntag EMEAorganized a day or a week for the first time during 2019 with various initiatives relating to the issue of "Safety First".

  1. CASA is the name of the HSE programme at Brenntag Latin America and stands for quality (CALIDAD), safety and health (SEGURIDAD & SALUD) and the environment
    (MEDIO AMBIENTE).

AlsoBrenntag UK & Ireland had its first Safety Day. The event centred on a promise by every person to pay attention to their own safety and that of their colleagues each and every day. Under the slogan "See, Stop, Do", everyone has been called on to take action: Whenever I see danger, I stop what I am doing and I do something about it. Russel Argo, President at Brenntag UK & Ireland, emphasized that everyone at Brenntag has the right to stop unsafe activities in order to have a positive impact on the company's security culture. The feedback on the Safety Day, the results of the BEST surveys, the analysis of current trends regarding the issue of safety and comparisons between PSAPs were used to analyze the issue of "Safety First" in detail during the year. The focus was on personal accident prevention above all else. There was a concerted effort to address the question of how important various factors are for the safety of each

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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SAFETY

43

and every employee at their work station and where there could be potential for accidents or injuries. The findings were systematized and culminated in "risk maps" for work areas and sites.

Brenntag Beneluxbrought another element into play in relation to safety in the workplace during its first Safety Week in 2019: The risk of accidents and injuries in private and on the way to and from work. Numerous external partners also took part in the individual events, visits and discussions that spanned a number of days. Key issues included how to act in the event of a fire and fire-extinguishing techniques, safety training and vehicle crash tests, and ergonomically correct sitting postures in the workplace.

Brenntag South Africaalso held its first workplace safety week. Together, employees practised how to perform first- aid measures, identify potential dangers in the workplace in advance and fight fires. Information was also provided on how to better protect one's health in the workplace as well as nutritional tips. Special recognition was given on this occasion to forklift drivers, who have to exercise particular caution while handling dangerous machinery day in and day out.

The emergency teams and Brenntag employees demonstrated their skill and reliability at Brenntag's Dos Hermanasand Cartagenasites in Spain on September 13, 2019: The Dos Hermanassite had to be temporarily evacuated that day after a fire broke out at a different, neighbouring facility. A strong wind caused sparks from the fire to fly and reach the Brenntag facility. Thanks to the dedicated work of the emergency team, two fires caused by the sparks were immediately extin- guished, preventing worse things from happening. How safe

the Brenntag facilities are was demonstrated in Cartagena­ . There, the grounds of the site were completely flooded in the early hours of the morning by heavy rainfall. The water level was half a metre in some places. Preparations had been made the previous day as part of an emergency plan. This meant that, despite the flooding, there was no ongoing risk from chemicals in storage. Although the clean-up operation lasted several days, the damage at the site was fully rectified - in particular due to the dedication of the team.

It was also evident at the Grez-en-Bouèresite in France on June 3, 2019 that courageous intervention combined with the correct training will pay off. There, two Brenntag employees, trained as first-aiders, became lifesavers after a colleague collapsed and a short time later stopped breathing. They performed cardiac massage until the emergency services arrived and also used the defi- brillator on hand at the site. Thanks to their exemplary actions, their colleague survived.

34 of the 53 Brenntag EMEAsites with more than 40 employees recorded zero lost-time injuries (LTI) in the year under review. Four of the 34 sites have gone ten years without an accident-related work absence, and a further eleven sites have gone five years without one.

Overall, we were able to reduce the

group accident rate by

58%

from 2010 to 2019.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

44

ENVIRONMENTAL PROTECTION

For further information on Brenntag's

HSE STRATEGY AND ORGANIZATION, please see the Safety chapter on page 35f.

NFB

The responsible use of natural resources has always been very important to Brenntag. As part of our business activi- ties, we consume water, electricity and different types of fuel, while producing waste, waste water and various emissions. Moreover, as a chemical distributor we deal with products that could damage the environment if not handled with the necessary care.

All around the world, we aim to protect resources and use them optimally, and to minimize the impact that our business activities have on the soil, water and air. At the same time, Brenntag supports its customers with sustainable solutions and helps to preserve the environment with ecologically

efficient­ products, processes and services.

When it comes to protecting the environment and climate, Brenntag also acts in accordance with the "Safety First" principle and has incorporated the fundamental aspects of its ­activities into its global HSE strategy.Brenntag's sites around the world implement numerous environmental protection and efficiency measures in the context of local and regional outline conditions and legislative requirements, tailored to their individual activities. These internal measures focus on energy and water consumption, the protection of soil, water and air, waste reduction, and transport and fleet management.

NFB

During the reporting year, the global ­activities of the Brenntag Group resulted­ in a total of 244,414.91 tonnes of CO2emissions (Scope 1 and 2). Energy consumption at our sites (offices and ware- houses) accounted for around 44% of these, while the vehicle fleet (trucks, company cars and other vehicles) accounted for around 56%. This means we were able to record a year-on-year decrease in total Scope 1 and 2 CO2emissions for the first time despite the inclusion of data from various company ac- quisitions. CO2emissions per warehouse tonne of goods sold decreased by 9.95% compared to the previous year. Compared to the base year 20161), we also recorded a decline in CO2emissions, namely of 0.58%. The reason for this was a drop in electricity consumption in Europe and North America. Most of the reduction is attributable to our site in Thetford in the UK, which ceased production of sodium hypochlorite due to the modernization of the facilities, and to numerous energy efficiency measures in North America.

ENVIRONMENTAL

PROTECTION

NFB

ENERGY

We calculate our consumption of resources on the basis of the data which we collect through our HSE programmes. Brenntag has established Group-wide energy reporting in order to make its own energy consumption and associated CO2emissionsmore transparent. Sites' energy consumption data are collected quarterly and are compiled and evaluated centrally by Brenntag's sustainability team. These data enable us to identify energy-saving potential. Our target is to reduce the Scope 1 and 2 CO2emissions (per warehouse tonne of goods sold) by 6% by 2020 compared to 2016.

  1. The values given for the 2016 base year have not been audited by PwC.

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Environmental Protection

45

ENERGY CONSUMPTION BRENNTAG GROUP1)

NFB

2019

20183)

Base year: 20163)

Total

Per 1,000

Total

Per 1,000

Total

Per 1,000

warehouse

warehouse

warehouse

tonnes of

tonnes of

tonnes of

goods sold

goods sold

goods sold

Electricity (in MWh)

138,811

13.6

153,894

15.6

146,904

16.5

District heating (in MWh)

7,914

0.8

-

-

-

-

Gas (in MWh)

302,710

29.7

290,213

29.4

178,702

20.1

Diesel (in 1,000 litres)

44,393

4.4

44,717

4.5

36,290

4.1

Petrol (in 1,000 litres)

6,277

0.6

6,550

0.7

6,141

0.7

Other4)(in 1,000 litres)

3,960

0.4

3,944

0.4

3,870

0.4

CO2EMISSIONS5)BRENNTAG GROUP1)

2019

20183)

Base year: 20163)

Total

Per 1,000

Total

Per 1,000

Total

Per 1,000

warehouse

warehouse

warehouse

tonnes of

tonnes of

tonnes of

goods sold

goods sold

goods sold

Scope 2

Electricity (in tonnes)

46,982

4.6

68,476

6.9

63,666

7.2

District heating (in tonnes)

1,686

0.2

-

-

-

-

Scope 1

ENVIRONMENTAL

Gas (in tonnes)

55,550

5.5

53,296

5.4

32,818

3.7

PROTECTION

Diesel (in tonnes)

117,749

11.6

118,707

12.0

96,336

10.8

Petrol (in tonnes)

14,449

1.4

15,011

1.5

14,072

1.6

Other4)(in tonnes)

7,999

0.8

7,862

0.8

7,933

0.9

Scope 1 + 2 (in tonnes)

244,415

24.0

263,352

26.6

214,825

24.1

Change compared to base

year 20162)(in %)

-

-0.58

-

10.41

-

-

  1. The data of the reporting year do not include the following operating units: Brenntag International Chemicals, Raj Petro Specialities Pvt. Ltd.,
    Alphamin­ Group, Canada Colors and Chemicals (included since Q2/2019), Pachem Distributing Inc., Conquimica S.A., Quimisa S.A. and Tee Hai Chem Pte Ltd. (included since Q4/2019) and all companies in Africa and the Middle East.
  2. The values given for the base year 2016 have not been audited by PwC.
  3. As part of our ongoing improvement process, the energy consumption reported for 2018 and the CO2emissions reported for 2016 to 2018 were again reviewed and adjusted.
  4. Gas oil, kerosene, propane gas
  5. As and from the 2019 reporting year, CO2emissions have been calculated for electricity using the respective country-specific factors as per IEA (2019), for district heating using the factor as per UBA (2018) and for all other energy types using the energy-specific factors defined in the UK Government GHG Conversion Factors for Company Reporting (2019). For the preceding reporting years, CO2emissions were calculated for electricity using the respective country-specific factors as per the Greenhouse Gas Protocol Factors (2012) and for all other energy types using the energy-specific factors defined in the UK Government GHG Conversion Factors for Company Reporting (2016).

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

46

DON'T STOP FIGHTING THE ENERGY MONSTERS

Our internal energy-saving campaign

"Fight the Energy Monsters" launched in 2018 was a success and enjoyed strong uptake­

across all regions and areas of work. As part of it, we continued our efforts to ­reduce energy consumption and the ­associated CO2emissions in the year under review.

NFB

DISCLOSURE INSIGHT ACTION

www.cdp.net

The numerous measures implemented globally in 2019 to increase energy efficiency include for example the repacement of conventional lighting with energy-saving LED light bulbs at various locations. In addition, existing technology needs to be replaced with technology that operates using low-emission energy sources. For this reason, additional forklifts and vehicles that run on diesel or petrol were replaced by electrically powered vehicles in the year under review. Some of the company's locations also began purchasing "green electricity" in 2019, in addition to the own production of solar and wind energy at several sites.

To achieve even greater CO2savings in the future, we launched a global project in 2019 to enable the company to produce its own electricity from renewable sources. We have a large number of rooftops on our warehouses that are suitable for solar arrays in particular. These are to be installed at many Brenntag locations worldwide so that we can meet our future electricity needs with our own "green electricity" as far as possible. In 2019, suitable service providers were initially identified to implement this plan. In 2020, the first solar arrays are to be installed at selected pilot locations. In subsequent years, this will gradually be extended to other locations.

In 2019, Brenntag took part in the climate rating initiative of the international organization CDPonce again and was given a rating of C ("Awareness"). CDP compares thousands of companies­ worldwide every year (currently more than 8,000) with regard to their strategic approach to the challenges of climate change and assesses their climate management system based on a comprehensive catalogue of criteria. By participating in the initiative, Brenntag is aiming to enhance its energy reporting using recognized standards. At the same time, it also allows us to address our customers' and investors' requirements for greater transparency and comparability in our energy consumption reporting and to demonstrate our progress in the areas of energy efficiency and energy management.

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Environmental Protection

47

PRACTICAL EXAMPLE

In 2019, numerous energy-saving measures and comparative measurements of consumption were carried out at several locations in Brenntag Italyto continue monitoring and further reducing CO2emissions in the future: The increased use of inverters in numerous devices helped to optimize the energy consumption. In addition, the switch to LED lighting systems was realized at several locations in the region. These measures will continue and expand into 2020.

TRANSPORT/FLEET MANAGEMENT

As a distributor, Brenntag maintains its own fleet of vehicles. To keep fuel consumption and harmful emissions to a mini- mum, structured transport logistics are used at our sites to avoid unnecessary trips and to make the trips taken by our vehicles as efficient as possible. In regular training courses, Brenntag drivers receive instruction on matters such as fuel-­ conscious driving.

More and more Brenntag companies use telematic systems in order to optimize the use of their vehicle fleets. They record­ vehicle and trip-related data such as fuel consumption, speed and driving duration. These on-board units facilitate safe and eco-efficient driving, for example by providing visual and acoustic warning signals for the driver or by displaying vehicle speed, braking behaviour and engine idling.

PRACTICAL EXAMPLE

The initiative to reduce CO2as part of fleet management at Brenntag Iberiaencompasses various measures, such as purchasing additional electric forklifts. In 2019, it lowered CO2emissions in the region by 24,200 kg. The focus here is also on the safety-first principle, or safe driving: As part of the Road Safety Plan, Brenntag employees receive more detailed instruction on proper and responsible driving, which should also lead to environmentally friendly driver behaviour. A reward system also promotes carpooling as another way of reducing the risk of accidents and lowering CO2emissions. In

addition, work is being done to improve the maintenance and fitting of the vehi­ cle fleet. For example, air-conditioning units that meet the latest technical and ecological standards have been installed on the lorries. The region also fulfils 95% of the requirements under the EMEA Best Defensive Driving pro- gramme.

WATER

Brenntag uses water in its business operations,­ for example to produce solutions, to clean pipe systems and to cool or heat chemicals and tank facili- ties. Water consumption varies widely at Brenntag's sites and is subject to fluc- tuations, as it is largely dependent on the nature and scope of the products handled and services provided. In ad- dition, water is needed to operate the buildings and plants, for example in the sanitary facilities or to clean surfaces.

Brenntag obtains around 90% of its water from the public water supply net- work. Water consumption is currently not recorded and consolidated on a Group-wide basis.

FURTHER EXAMPLES are presented on our website atwww.brenntag.com/ sustainabilityunder Projects Worldwide.

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48

Brenntag Latin Americaregularly measures water consumption at all of its sites as part of its extensive CASA programme. There are several reasons for consumption fluctuating over time: Company acquisitions and changes in the number of employees increase or reduce water needs. Water-intensive processes, such as hydrostatic testing of new tanks or test operations on fire protection systems, also occur at irregular­ intervals. Absolute water consumption in the Brenntag Latin America region rose by 6% in 2019 compared to the previous year. The increase in water consumption was from the Brenntag Latin America North region; Brenntag Latin America

South was able to reduce its consump- tion. The reasons for the increase included leaks and the rise in water-­intensive processes. In Mexico, consumption was higher due to the purchase of a boiler and the watering of new green areas on the company premises. Brenntag Caribbean produced significantly more product blends in 2019, which is why the tanks had to be cleaned more fre- quently.

BRENNTAG LATIN AMERICA: WATER CONSUMPTION

TOTAL

PER WAREHOUSE TONNE OF GOODS SOLD

(IN MILLIONS OF LITRES)

(IN LITRES)

86.0

81.0

80.0

70.1

73.4

67.6

57.4

56.9

60.3

61.4

Information on

ENVIRONMENTAL PROVISIONS can be found on page 142f. ofBrenntag's 2019 Annual Report.

2015

2016

2017

2018

2019

2015

2016

2017

2018

2019

NFB

PROTECTION OF SOIL, WATER AND AIR

NFB

measures will be derived and imple-

We work continuously on minimizing the environmental im-

mented. Whenever new buildings or

pacts of our business activities on the soil, water and air.

plants are constructed or necessary

Our HSE strategy and various measures such as investments

modernization­

and renovation work is

in infrastructure, optimized work procedures and employee

undertaken, environmental protection

qualifications are implemented with a view to identifying

issues are considered and reflected both

environmental­

risks early on and to avoiding environmentally

in terms of the construction approach

related incidents. Brenntag's sitesin all of its regions comply

and plant engineering.

with the applicable rules and regulations relating to the pro-

tection of the environment as well as our Group's stringent

All of Brenntag's sites implement suit-

internal environmental and safety standards.

able environmental protection meas-

ures. Basic measures include multilayer

With many of Brenntag's sites having been used industrially

soil protection in warehousing areas,

for decades, including those purchased through acquisitions,

double-­walled tanks and collection

there is historical soil and groundwater contamination at

tanks, closed water cycles, multistage

the sites, which we are combatting with appropriate reme-

water purification and treatment pro-

diation measures. The soil and groundwater situation at all

cesses, and modern air and exhaust air

of the sites is reviewed and recorded annually in coopera-

purification systems.

tion with external partners, and the necessary remediation

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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Environmental Protection

49

In the rare event that chemicals are released during process- ing, when being placed in or moved between containers or during transportation, Brenntag has strict and effective measures in place to quickly rectify the problem and clean up and dispose of the chemicals. Spillages are recorded, categorized and evaluated using a standardized system.

PRACTICAL EXAMPLES

WASTE/RECYCLING

The Brenntag sites have implemented processes for the handling of waste and also take-back and recycling systems for various types of packaging and containers, each in line with the site's type and volume of business. As part of this, we maintain a close dialogue with manufacturers and with the

national umbrella­ associations of chemical dealers, with the common goal of reducing the volume of waste in the industry and ­increasing recycling rates.

The principle of"reduce, reuse, recycle, rethink" - the 4R's - represents our goal of reducing packaging material by reusing it and by using better recycling methods. We have optimized our packaging cycle: AtBrenntag EMEA, several hundred thousand IBCs (intermediate bulk containers) circulate annu- ally. They are in use for two years on average and are handled three times a year.

We also ensure that unnecessary waste is avoided right from the outset and that the volume of waste is reduced by giving our employees intensive and regular training in the handling, storage and transportation of chemical products.

RECYCLING AT BRENNTAG SWITZERLAND: Solvents in particular can be processed in the company's own recycling plant and thus are ready for further use.

SUSTAINABLE SOLUTIONS FOR

OUR CUSTOMERS

Brenntag's employees have in-depth expertise in the fields of chemicals, components, procedures, processes and application technologies. They are experts on the industries of individual customers, cooperate closely with the manufacturers, and are familiar with applicable safety and quality regulations. Our technicians who work in numerous application industries assist our customers in developing tailored formulations and advise them on ways to optimize the use and handling of the products.

Brenntag also continuously works to add new products to its portfolio which increase efficiency, reduce consumption or decrease environmental impact when applied, thereby providing sustainable alternativesto conventional products. In this regard, our target is to implement pilot projects with ten selected key suppliers by 2020 and in doing so become the preferred distributor for sustainable solutions.

Brenntag's expertise and portfolio thus help improve the level of efficiency within the supply chain and support its customers to optimize their use of resources and improve productivity.

Also see CIRCULAR

ECONOMYpage 18-21.

SUSTAINABLE

SOLUTIONS

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50

RESPONSIBILITY IN THE SUPPLY CHAIN

For theSUSTAINABILITY

ASSESSMENTS please also see the corresponding sections in this chapter on page 52.

SUSTAINABLE

PROCUREMENT

As the global market leader in the distribution of chemicals and ingredients, Brenntag serves as an important link between the manufacturers of chemical products and the companies that process these products. We maintain a close and ongoing dialogue with our suppliers and customers through our regional and global procurement and distribution organizations as well as our HSE structures. The majority of these business relationships and partnerships go back many years.

NFB

Brenntag has set itself the goal of monitoring its own supply

chain more closely with regard to the various sustainability

aspects and gradually making it more sustainable. Among our

sustainability targets for 2020, we aim to analyze a specific

percentage of our total chemical spend (in EUR) through sus-

tainability assessments or audits as part of our membership

of the "Together for Sustainability" initiative (TfS). In 2016, we

set a target of 50% for our coverage rate, which we achieved

by the end of 2017 with a rate of around 64%. We adjusted

the target accordingly and are now aiming for a coverage rate

of 80% by 2020. By the end of 2019, we analyzed some 72%

of our total chemical spend (in EUR) at least once using sus-

tainability assessments or audits.

COMMITTED TO MORE TRANSPARENCY:

David O'Connell (right) and Stefan Emmerling

(left) discuss the results of the supplier assessments and audits of selected suppliers.

NFB

In addition to achieving greater transparency in relation to sustainability performance through a higher coverage rate, Brenntag also prioritizes improvements in its suppliers' sustainability performance. We have therefore specified another target in the area of sustainable procurement: By 2020, we want 70% of our suppliers undergoing a re-assessmentto have improved their score by at least one point compared to their previous assessment. In 2019, some 59% of our suppliers were able to improve their score through a re-assess­ ment. Around 1,100 of our suppliers completed an assessment between the launch of the programme in 2015 and the end of 2019.

SUPPLIER MANAGEMENT

Brenntag's purchasing organizations have over 1,000 employees globally, including local and regional purchasing teams, specialists in sourcing chemical products from Asia, and product managers for specific chemicals and customer industries. These employees are in contact with several thousand suppliers worldwide. As a trading company, business relationships with suppliers have a direct influence on the product portfolio and are therefore a key differentiation point for distributors. These relationships are often more accurately described as sales partnerships rather than conventional purchasing relationships. For this reason, Brenntag maintains regular, close communication with its suppliers. At various levels throughout the Group, there are standardized processes in place for relationship management with suppliers. In our company, supplier relationships are a management issue and a key element of strategic decision-making.

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RESPONSIBILITY IN THE SUPPLY CHAIN

51

SUSTAINABLE PROCUREMENT AT BRENNTAG

SUPPLIERS

Suppliers are asked for a

Results of conducted

sustainability assessment by rating

EcoVadis assessment

company EcoVadis

Results of conducted

Suppliers are asked for

on-site audit by using external

sustainability audits

audit companies

Brenntag: EcoVadis assessment

Rating of Brenntag's sustainability performance

Result of Brenntag's

EcoVadis assessments

CUSTOMERS

Activities within the scope of TfS membership

Voluntary activities

Results of Brenntag's supplier assessments and audits

Results of supplier assessments and audits conducted by other TfS members

In selecting new suppliers and evaluating existing supplier rela- tionships, both economic and quality criteria and issues of environmental protection and safety, labour and social standards as well as compliance and governance are relevant for Brenntag. In 2019, an internal process was developed to ensure and check that sustainability criteria are adequately taken into consideration when purchases are being made. The process is set to be introduced and implemented in 2020. We also expect the Group-wideroll-out of our project SHAPEin the coming years to deliver key benefits for our supplier management activities.

A project team is in charge of advancing the topic of sustainable procurement within our international corporate structures. The team consists of representatives from the purchasing units of the four Brenntag regions, the Brenntag Global Sourcing Organization and Brenntag's sustainability team. The sustainability manager regularly reports on the topic of sustainable procurement to Brenntag AG's Board of Management.

NFB

SUPPLIER CODE OF CONDUCT: Brenntag has drawn up a code of conduct specifying what we expect of our suppliers in the areas mentioned. The code is based on the principles of the United Nations Global Compact, the chemical industry's global Responsible Care programme and Brenntag's Code of Business Conduct and Ethics. It can be found on the company's website and is therefore available to all suppliers. In order to verify compliance with the code of conduct, we invite selected suppliers to undergo a sustainability assessment or audit.

NFB

TheSUPPLIER CODE OF

CONDUCT is available on our website atwww.brenntag.com/ sustainabilityunder Service & Contacts.

More on SHAPEin the chapter Sustainability at Brenntag on page 10.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

52

NFB

For more information, see www.tfs-initiative.com.

Brenntag´s membership in TfS provides it with access to the results of all the ASSESSMENTSwhich TfS member companies conduct with their suppliers.

For CDP, see the Environmental Protection chapter on page 46.

SUSTAINABILITY ASSESSMENTS FOR SUPPLIERS: Within the scope of its membership of the"Together for Sustainability" (TfS) industry initiative, Brenntag requires a certain number of its suppliers to undergo sustainability assessments every year. We thereby achieve greater transparency in relation to our suppliers' sustainability performance and are able to ­better consider sustainability issues in our purchasing decisions.

We work together with EcoVadis, which is a leading provider of sustainability assessments and is well established in the chemical industry. EcoVadis evaluates companies in terms of four categories: environmental protection, labour practices, fair business practices and sustainable procurement. Based on the responses provided by the companies in a comprehensive online questionnaire and on their accompanying documen- tation, EcoVadis awards scoring points and creates a detailed profile of strengths and weaknesses.

ECOVADIS SCORING OF BRENNTAG'S SUPPLIERS

SHARE OF TOTAL CHEMICAL SPEND IN EUR (IN %)

63.9

28

8.1

no score

score: 1-44

score: 45-100

Brenntag evaluates its suppliers' assessment results. It found that suppliers which represent some 64% of our total chemical spend scored 45 points or higher. According to the EcoVadis assessment system, these companies have, as a minimum, a structured and proactive sustainability approach, policies and tangible actions in relation to the areas evaluated and a basic reporting system or set of performance indicators. Depending on their performance, Brenntag requests that its suppliers take corrective measures (corrective action plan) or it arranges a supplementary audit. In the year under review, the focus was on the suppliers that scored less than 45 points and/or had an outdated scorecard (older than three years). The targeted improvements will be evaluated as part of a re-assessment.

NFB

The sustainability team and the purchasing units at Brenntag maintain regular contact to discuss the topic of sustainable procurement and to develop our objectives. We regularly train our purchasing staff on the assessment procedure and therefore also on sustainability issues, enabling them to assist and to advise their suppliers during the review process.

SUSTAINABILITY AUDITS OF SUPPLIERS: In the event that a sustainability audit is conducted at a supplier's location, auditing is based on a catalogue of ­requirements developed by TfS and covers the areas of sustainability manage- ment, environment,­ health and safety, labour and human rights, and corporate governance. The results of all audits are shared within TfS. Brenntag reviews its suppliers' audit results. If necessary, it agrees on corrective measures with the company and the auditor and follows up on their implementation.

BRENNTAG AS A SUPPLIER

For a number of years now, Brenntag has registered an increasing demand for information on how we deal with sustainability issues - particularly on the part of its customers. We are regularly asked to document our sustainability performance. We are pleased to respond to these needs by making our principles and activities transparent and measurable in various ways. As well as our annual sustainability re- port, this also includes our own regular EcoVadis assessment, issue-specific audits at our locations and our participation in the climate rating initiative of the international organization CDP.

As a TfS member, Brenntag can also provide its customers with information about its suppliers' sustainability score and thus make its supply chain even more transparent.

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RESPONSIBILITY IN THE SUPPLY CHAIN

53

ECOVADIS SCORE:In its most recent EcoVadis assessmentin November 2018, the Brenntag Group achieved a score of 68 points, thereby confirming the gold status (Gold Recog­ nition Level) that it achieved in October 2016. This result puts us among the top 1% of companies assessed in our industry category. As specified in our sustainability objec- tives, we will endeavour to maintain our gold status and our score. At the end of 2019, a new sustainability assessment was started, which will be completed in early 2020.

SAFETY DATA SHEETS:As a distributor, Brenntag plays a major role in safeguarding the seamless flow of information along the supply chain and must ensure complete product documentation. Together with every product sold, Brenntag therefore sends its customers safety data sheets that contain specific and detailed information on the appropriate and safe handling of the chemicals in question. We thereby make a very concrete contribution to greater transparency and safety in the supply chain. In 2019, Brenntag sent around 600,000 safety data sheets to customers in the EMEA region and the USA alone.

TOGETHER FOR SUSTAINABILITY

NFB

Brenntag has been involved in the chemical industry's "Together­ for Sustainability" initiative (TfS) since October 2014 and became a full member in October 2016 when it achieved an EcoVadis score of over 60 points - the first and, as of the end of 2019, only chemical distributor to do so.

Top1%

In the EcoVadis sustainability assessment, we are among the top 1% of all companies assessed in our industry category.

TfS was established in 2011 and now counts 25 members. Its goal is to establish a uniform global programme for the responsible procurement of goods and services in the chemical industry, to achieve transparency in relation to sustainability performance throughout the supply chain and to make further improvements to its suppliers' ­ecological and social standards. For this purpose, all TfS members regularly evaluate and review their suppliers by means of a standardized process using assessments and audits. This information is shared confidentially and used jointly within the network, which provides efficiency benefits for every participant and creates more transparency. At present, we are working even more intensively at Brenntag to use the findings we have obtained to improve our suppliers' sustainability performance.

As a member, Brenntag has a seat and voting rights at the general assembly, the top decision-making body of TfS. In addition, Brenntag employees in Europe, Asia, Latin America and the USA are involved in working groups. Together with representatives of the other TfS members, they are working, for example, to further develop the audit programme, to increase awareness of the initiative and its objectives at events in the industry and to convince other suppliers of the added value created by the voluntary sustainability assessments and audits. Our involvement with TfS provides us with an opportunity not just to advance the issue of sustainability within the chemical ­industry's supply chain but also to learn from best-practice experiences of the other members and to further professionalize our sustainability approach in the area of supplier management.

RATING

The results of the

ECOVADIS RATING are available on our website atwww.brenntag.com/ sustainabilityunder Service & Contacts.

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54

COMMUNITY

Brenntag is present at more than 640 sites in 77 countries worldwide, where it is an employer, a business partner and a neighbour in local communities in many different countries and cities. We see ourselves as part of these communities, as a "corporate citizen", and we maintain a lively dialogue with them and aim to contribute to a positive environment.

Brenntag's social commitment is underpinned primarily by our employees. They collect money and donations and invest their expertise, their time and their manpower in support of charitable causes. In many cases, Brenntag supports their contribution either financially and organizationally or else by releasing them from their work duties.

PROMOTION OF EDUCATION

The promotion of education is a focus of Brenntag's activities and the projects it supports in all of its regions. A large number of our sites have been cooperating with schools, universities and institutions for many years now with the common aim of encouraging young people's interest in chemistry and our industry, sensitizing them regarding the handling of chemicals and supporting their education.

Tours of plants took place at Brenntag North Americato show young school students first-hand how diverse the job profiles and duties are at a chemical dis- tributor. For this, Brenntag employees from Accounting, Customer Service and other divisions shared their experiences with the school students, in relation to their training and education or how they came to work at Brenntag, for example.

As part of the "JuWiChem1)meets Indus- try" series of events, which Brenntag Germanycontinued in 2019 together with the business chemists' association Gemeinschaft Düsseldorfer Wirtschafts- chemiker e. V. (GDW), the students dealt with the importance of sustainability in the chemical industry. Brenntag invited them to the headquarter in Essen, where the students used case studies to develop concrete recommendations with the support of Brenntag specialists. These will be analyzed as part of Brenntag's sustainability programme and considered for further developments.

  1. "Junge WirtschaftschemikerInnen"
    (Young business chemists)

BRENNTAG PHARMA & COSMETICS: a series of lectures and workshops,

Brenntag team presented the students of Liverpool John Moores University, among other things, the natural skin care trends of tomorrow.

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Community

55

COMMON SUSTAINABILITY GOALS: The United Nations' Young SDG Innovators Program provides innovative impulses with regard to Brenntag's sustainability strategy.

f. l. t. r.: Dan Merkel, Talitha Poore and Marie Wardenski from Brenntag North America.

LOCAL COMMITMENT

Brenntag aims to provide assistance exactly where it is ­needed. Because local needs vary from country to country due to national, cultural and structural differences, the Brenntag sites decide autonomously where and to what extent they get involved in social initiatives. Because the company pursues many different activities, only a few examples are listed here.

PRACTICAL EXAMPLES

In partnership with the children's charity "Little Lambs", Brenntag South Africasupports disadvantaged children in remote communities. At Easter in 2019, they were given sweets as well as washing utensils and rubber boots. The latter were provided so that the children, who otherwise often go barefoot, would have better protection against sickness in the winter months.

"Giving is gaining: We love, care, give and share". This was the motto of the first blood donation initiative of Brenntag Asia Pacificin Singapore, which provided many blood donors with an opportunity to engage in a completely new type of social involvement. In India, a two-day "blood donation camp" was organized on the Brenntag premises in Mumbai, with several local doctors and nurses getting involved. Brenntag also invited employees of other companies to take part. This initiative was well received by everyone involved, and the two-day blood donation camp is expected to become a twice-yearly event in the future as a result.

FURTHER EXAMPLES

are presented on our website at www.brenntag.com/ sustainabilityunder Projects Worldwide.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

56

TEAMBUILDING WITH A CAUSE: of Brenntag India were

with the successful

of eleven wheelchairs, were then donated.

Brenntag India'ssocial involvement takes many forms. Voluntary monthly donations made by Brenntag employees are passed on to local non-governmental organizations (NGOs). On the first Friday of every month, Brenntag employees have an opportunity to support selected NGOs in their work for half a day. Personal items that are no longer used or needed are donated regularly. One team-building measure in the reporting year was an initiative to assemble eleven wheelchairs, which were subsequently donated.

Employees of Brenntag Malaysiaalso organized a team event to support a good cause: The Food & Nutrition team spent a day at a special residential facility with children in need aged between 5 and 17. As well as engaging in shared activities, interactive games and conversations, numerous items of everyday use, such as bed linen, were donated to the facility.

Employees of Brenntag Germanylent their support to two preschools in ­Essen: As part of a number of initiatives, the inside and outside areas of the preschools were enhanced, an exterior wall was covered with wood panelling and rooms inside were newly painted. In addition, there were experiments for the children on the topic of water.

BothBrenntag North America andBrenntag Latin America have supported­

the charitable organization Water For People since the beginning of 2018 and provided financial assistance again in 2019. Water For People champions access to high-quality drinking water and sanitation worldwide by drawing on the support of local communities, companies and governments.

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REPORT PROFile

57

REPORT PROFILE

ABOUT THIS REPORT

REPORTING PRINCIPLES

Brenntag's Sustainability Report for the Financial Year 2019 is its seventh sustainability report. Brenntag reports on its sustainability activities every year. The report for 2020 will therefore be published in 2021. This report complies with international standards for sustainability reporting - the Global Reporting Initiative (GRI) and the principles of the United Nations Global Compact (UNGC).

  • This report has been prepared in accordance with the
    GRI Standards (2016): Core Option. The GRI Content Index can be found on page 62.
  • This Sustainability Report for the Financial Year 2019 is also an annual progress report (Communication on Progress - COP) for theUNGC, which Brenntag joined in October 2014. This report has therefore also been published on the organization's website.

SEPARATE NON-FINANCIAL GROUP REPORT

NFB

The content in this report marked with a blue line and the

acronym  

  forms the separate non-financial Group report (NFB)

NFB

pursuant to Section 315c in conjunction with 289c ff. of the

German Commercial Code (HGB) to ensure compliance with

the legal requirements of the HGB. The NFB is based on the

standards of the Global Reporting Initiative as a framework.

The NFB has been audited by PricewaterhouseCoopers GmbH

Wirtschaftsprüfungsgesellschaft (PwC) pursuant to ISAE 3000

(Revised) to obtain limited assurance. The Practitioner's Report

can be found on pages 60 and 61.

References to information not contained in the combined

Group management report or the management report of

Brenntag AG are not part of the NFB.

IDENTIFICATION OF MATERIAL CONTENT:­

The issues presented in the materiality matrix on page 8 form the basis for determining the NFB content. The matrix is the result of a materiality assessment which is based on the principles defined by the Global Reporting Initiative: sustainability context, materiality, completeness and stakeholder inclusiveness. In order to determine the material topics­ for the NFB, Brenntag has adhered to the definition of Section 289c, para. 3, sentence 1 of the German Commercial Code (HGB). These topics were assessed for the NFB using the following criteria:

  • Topics that are necessary to under- stand the business performance, the
    business results, the company's­ posi- tion and the effects of Brenntag's activities on the non-financial aspects (environmental, social
    and employee matters, respect for human rights, anti-corruption and bribery matters, and responsibility in the supply chain)
  • Topics rated as "very important" in at least one of the dimensions
  • Topics that form part of Brenntag's Group strategy and/or sustainability targets

NFB

www.unglobalcompact.org

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

58

NFB

This materiality process identified the following topics as

being­ material to Brenntag within the meaning of the law:

BRENNTAG: MATERIAL TOPICS PURSUANT TO SECTION 289C, PARA. 3, SENTENCE 1 OF THE GERMAN COMMERCIAL CODE

ASPECTS

TOPIC AND

PAGE REFERENCE

NFB

The contents and data provided in this report have been determined on the basis of internal processes. They derive from Brenntag's existing management and data recording systems and from company documents and have been obtained from the operational units of Brenntag's regions as well as the

Environmental matters

Employee matters

Respect for human rights

Anti-corruption and bribery matters

Social matters

Responsibility in the supply chain

  • Safe handling of chemicals (page38-39)
  • Climate protection (page44-47)
  • Occupational health and safety (page 35,39-40)
  • HR development and training/ Respectful and supportive work environment
    (page 24-31)
  • Compliance and governance (page11-16)
  • Compliance and governance (page11-16)
  • Identified as being immaterial to thenon-financial report within the meaning of the law
  • Sustainable selection of suppliers (page50-53)

responsible corporate departments. The content of this report has been reviewed by employees with the relevant specialist expertise. The content of the NFB has also been audited by PwC pursuant to ISAE 3000 (Revised) to obtain limited assurance.

The data published in this sustainability­ report have been compiled and processed with the greatest care. However, we are unable to completely rule out the possibility of transcription errors.

To provide better readability, we consistently use the term "employee" in the sustainability report. This refers to all

Social matters were identified as being immaterial to Brenntag within the meaning of the law and were therefore not included in the NFB. We have reported on the social activities and wide-ranging involvement of our employees in the Community chapter on page 54. In addition to the aspects covered by the law, Brenntag has identified "Responsibility in the supply chain" as being material within the meaning of the law. As the market leader in chemical distribution, we believe we have a responsibility to promote the non-financial aspects within the chemical industry's supply chain.

DATA BASIS

This sustainability report covers Brenntag AG, which is included in the consolidated financial statements, as well as the fully consolidated subsidiaries which are also included, along with structured companies. For information on the group of consolidated companies and consolidation method,­ see page 110 and page 115 as well as the list of companies included in the consolidated financial statements on page 175 of Brenntag's 2019 Annual Report. Any deviations from these parameters are indicated in the relevant section of this sustainability­ report.

The reporting period for this sustainability report covers the 2019 financial year (January 1, 2019 to December 31, 2019) of the Brenntag Group and follows on from the Sustainability Report for the Financial Year 2018, which was published in April 2019. Any deviations regarding the reporting periods for individual data and contents are noted separately.

our employees of any gender.

BOUNDARIES OF MATERIAL TOPICS PURSUANT TO GRI (103-1)

The diagram on page 59 shows the boundaries of the material topics pursuant to the GRI (103-1). The relevant GRI standards covered by each topic are also indicated. For topics that are not covered by the GRI guidelines, we have referred directly to the corresponding management approaches in the report and, if necessary, to our website as an additional source of information. We have combined the management approaches for the GRI-relevant standards and presented them for economic, ­environmental and social topics.

As a result of the materiality analysis performed in 2019, the following overview shows an updated presentation of the material topics and boundaries.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

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MATERIAL TOPIC

REPORT PROFile

59

RELEVANT

RELEVANT

RELATED GRI STANDARD 2016 OR MANAGEMENT APPROACH FOR

WITHIN THE

OUTSIDE THE

ADDITIONAL MATERIAL TOPICS

ORGANIZATION

ORGANIZATION

SUSTAINABLE GOVERNANCE

Compliance and governance

Sustainable growth

Climate adaptation

Sustainable selection of suppliers

SAFETY AND ENVIRONMENTAL PROTECTION

Safe handling of chemicals

Climate protection

Waste and packaging

Water and effluents

Sustainable products and solutions

EMPLOYEES AND COMMUNITY

Occupational health and safety

HR development and training

A respectful and supportive work environment

Social commitments

  • GRI 205:Anti-corruption
  • GRI 206:Anti-competitive Behavior
  • GRI 307: Environmental Compliance
  • GRI 406:Non-discrimination
  • GRI 407: Freedom of Association and Collective Bargaining
  • GRI 408: Child Labor
  • GRI 409: Forced or Compulsory Labor
  • GRI 410: Security Practices
  • GRI 411: Rights of Indigenous Peoples
  • GRI 412: Human Rights Assessment
  • GRI 417: Marketing and Labeling
  • GRI 418: Customer Privacy
  • GRI 419: Socioeconomic Compliance
  • GRI 201: Economic Performance
  • p.2-4,6-17,18-21
  • Brenntag 2019 Annual Report p.35-36
  • https://www.brenntag.com/corporate/en/about-brenntag/strategy-and-organisation/vision-and-values/index.jsp
  • p.44-47
  • GRI 204: Procurement Practices
  • GRI 308: Supplier Environmental Assessment
  • GRI 414: Supplier Social Assessment
  • GRI 416: Customer Health and Safety
  • GRI 306: Effluents and Waste
  • GRI 302: Energy
  • GRI 305: Emissions
  • GRI 306: Effluents and Waste
  • GRI 303: Water
  • GRI 306: Effluents and Waste
  • GRI 416: Customer Health and Safety
  • GRI 417: Marketing and Labeling
  • p.18-21, 49
  • GRI 403: Occupational Health and Safety
  • GRI 404: Training and Education
  • GRI 401: Employment
  • GRI 402: Labor/Management Relations
  • GRI 405: Diversity and Equal Opportunity
  • GRI 406:Non-discrimination
  • GRI 407: Freedom of Association and Collective Bargaining
  • GRI 413: Local Communities

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

60

PRACTITIONER'S REPORT

INDEPENDENT PRACTITIONER'S REPORT ON A LIMITED ASSURANCE ­ENGAGEMENT ON NON-FINANCIAL REPORTING1)

TO BRENNTAG AG, ESSEN

We have performed a limited assurance engagement on the separate non-financial group report, which comprises the information marked with a blue line and the ­abbreviation "NFB" next to the line, in the company's sustainability ­report for the 2019 financial year (hereinafter the "Non-­financial Report"), pursuant to § 315b Abs. (paragraph) 3 HGB ("Handelsgesetzbuch": "German Commercial Code") of the Brenntag AG, Essen (hereinafter the "Company") for the ­period from 1 January to 31 December 2019.

RESPONSIBILITIES OF THE EXECUTIVE DIRECTORS

PRACTITIONER´S RESPONSIBILITY

Our responsibility is to express a ­limited assurance conclusion on the Non-­ financial Report based on the assurance

engagement­we have performed.

Within the scope of our engagement, we did not perform an audit on ­external sources of information or expert ­opinions, referred to in the Non-­financial Report.

The executive directors of the Company are responsible for the preparation of the Non-financial Report in accordance with §§ 315c in conjunction with 289c to 289e HGB.

This responsibility of Company's executive directors includes the selection and application of appropriate methods of non-­ financial reporting as well as making assumptions and estimates related to individual non-financial disclosures which are reasonable in the circumstances. Furthermore, the executive­ directors are responsible for such internal control as they have considered necessary to enable the preparation of a Non-­financial Report that is free from material misstatement whether due to fraud or error.

INDEPENDENCE AND QUALITY CONTROL OF THE AUDIT FIRM

We have complied with the German professional provisions regarding independence as well as other ethical requirements.

Our audit firm applies the national legal requirements and professional standards - in particular the Professional Code for German Public Auditors and German Chartered ­Auditors ("Berufssatzung für Wirtschaftsprüfer und vereidigte Buch­ prüfer": "BS WP/vBP") as well as the Standard on Quality ­Control 1 published by the Institut der Wirtschaftsprüfer (Institute of Public Auditors in Germany; IDW): Requirements to quality control for audit firms (IDW Qualitätssicherungsstandard 1: Anforderungen an die Qualitätssicherung in der Wirtschafts- prüferpraxis - IDW QS 1) - and accordingly maintains a comprehensive system of quality control including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.

We conducted our assurance engagement in accordance with the International­ Standard on Assurance Engagements (ISAE) 3000 (Revised): Assurance Engage­ ments other than Audits or Reviews of Historical Financial Information, issued by the IAASB. This Standard requires that we plan and perform the ­assurance engagement to allow us to conclude with limited assurance that nothing has come to our attention that causes us to believe that the Company's Non-financial Report for the period from 1 January to 31 De- cember 2019 has not been prepared, in all material aspects, in accordance with §§ 315c in conjunction with 289c to 289e HGB.

In a limited assurance engagement the assurance procedures are less in extent than for a reasonable assurance engage- ment, and therefore a substantially lower level of assurance is obtained. The assurance procedures selected depend on the practitioner's judgment.

  1. PricewaterhouseCoopers GmbH has performed a limited assurance engagement on the German version of the separetenon-financial group report and
    issued­ an independent assurance report in German language, which is authoritative. The following text is a translation of the independent assurance report.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

Practitioner's Report

61

Within the scope of our assurance engagement, we performed amongst others the following assurance procedures and further activities:

  • Obtaining an understanding of the structure of the sustainability organization and of the stakeholder engagement
  • Inquiries of personnel involved in the preparation of theNon-financial Report regarding the preparation process, the internal control system relating to this process and selected disclosures in the Non-financial Report
  • Identification of the likely risks of material misstatement of theNon-financial Report
  • Analytical evaluation of selected disclosures in the
    Non-financial Report
  • Comparison of selected disclosures with corresponding data in the consolidated financial statements and in the group management report
  • Evaluation of the presentation of thenon-financial information

ASSURANCE CONCLUSION

Based on the assurance procedures performed and assurance evidence obtained, nothing has come to our attention that causes us to believe that the Company's Non-financial Report for the period from 1 January to 31 December 2019 has not been prepared, in all material aspects, in accordance with §§ 315c in conjunction with 289c to 289e HGB.

INTENDED USE OF THE ASSURANCE REPORT

We issue this report on the basis of the engagement agreed with the Company. The assurance engagement has been performed for purposes of the ­Company and the report is solely intended to inform the Company about the results of the limited assurance engagement.

The report is not intended for any third parties to base any (financial) decision thereon. Our responsibility lies only with the Company. We do not assume any responsibility towards third parties.

Frankfurt am Main, 17 April 2020

PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft

Nicolette Behncke

Wirtschaftsprüfer (German public auditor)

ppa. Juliane von Clausbruch

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

62

GRI CONTENT INDEX

GRI STANDARD AND DESCRIPTION

REFERENCES

COMMENTS AND ONLINE RESOURCES

UNGC

GRI 101:

Foundation 2016

SR: p. 7-10,57-59

GRI 102:

General Disclosures 2016

Organizational profile

102-01

Name of the organization

102-02

Activities, brands, products, and services

SR: p. 6-7

AR: p. 34

102-03

Location of headquarters

102-04

Location of operations

SR: inner fold-out page

AR: p. 175-183

102-05

Ownership and legal form

AR: p. 9, 34

102-06

Markets served

AR: p. 43-45

102-07

Scale of the organization

SR: inner fold-out page

AR: fold-out page, p. 96-97

102-08

Information on employees and

SR: p. 32-33

other workers

102-09

Supply chain

SR: p. 6-7,50-53

102-10

Significant changes to the organization

SR: p. 50-53

and its supply chain

AR: p. 34, 39-40

102-11

Precautionary Principle or approach

AR: p. 36, 75-77

102-12

External initiatives

SR: p. 14-15, 36, 38, 53

102-13

Membership in associations

Strategy

102-14

Statement from senior decision-maker

SR: p. 2-4

Ethics and integrity

102-16

Values, principles, standards, and

SR: p. 6-7,10-15

norms of behavior

Governance

102-18

Governance structure

AR: p. 12-17,18-20,24-31

Stakeholder engagement

102-40

List of stakeholder groups

SR: p. 17

102-41

Collective bargaining agreements

102-42

Identifying and selecting stakeholders

SR: p. 16-17

102-43

Approach to stakeholder engagement

SR: p. 16-17,50-53,54-56

102-44

Key topics and concerns raised

SR: p. 7-9,16-17,18-21

Reporting practice

102-45

Entities included in the consolidated

AR: p. 109, 175-183

financial­

statements

102-46

Defining report content and topic

SR: p. 7-9,57-59

boundaries

102-47

List of material topics

SR: p. 8, 59

102-48

Restatements of information

SR: p. 45, 58

AR: p.103-109

102-49

Changes in reporting

SR: p. 57-59

AR: p. 103-109,110-112

102-50

Reporting period

SR: p. 57

102-51

Date of most recent report

102-52

Reporting cycle

102-53

Contact point for questions regarding

SR: p. 66

the report

102-54

Claims of reporting in accordance with

the GRI Standards

102-55

GRI content index

SR: p. 62-65

102-56

External assurance

SR: p. 60-61

SR:Brenntag Sustainability Report for the Financial Year 2019

AR:Brenntag 2019 Annual Report

Brenntag AG

www.brenntag.com

Messeallee 11, 45131 Essen, Germany

In the reporting period, there were no significant changes to the supply chain.

https://www.brenntag.com/media/documents/sustainability_reports/brenntag_ list_of_memberships_20150630.pdf

https://www.brenntag.com/corporate/en/about-brenntag/strategy-and-­organisation/vision-and-values/index.jsp

Due to its large number of international locations and the broad range of ­labour regulations applicable to these locations, Brenntag does not record this data in a consolidated Group-wide format.

2019

annually

Core

6

10

3

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

GRI CONTENT INDex

63

GRI STANDARD AND DESCRIPTION

REFERENCES

COMMENTS AND ONLINE RESOURCES

UNGC

ECONOMIC

GRI 103

Management Approach 2016

103-1

Explanation of the material topic and

SR: p. 59

its Boundary

AR: p. 35-36

103-2

The management approach and its

SR: p. 6-10

components

AR: p. 35-36

103-3

Defining report content and topic

SR: p. 7-10,11-16

Boundaries

AR: p. 40-46

GRI 201: Economic Performance 2016

201-1

Direct economic value generated and

AR: fold-out page,

distributed

p. 94, 129

201-3

Defined benefit plan obligations and

AR: p. 129, 145-152

other retirement plans

GRI 204: Procurement Practices 2016

204-1

Proportion of spending on local suppliers

SR: p. 50-53

GRI 205: Anti-corruption 2016

205-1

Operations assessed for risks related

SR: p. 11-12

to corruption

205-2

Communication and training about anti-­

SR: p. 11-12,15-16

corruption policies and procedures

205-3

Confirmed incidents of corruption and

SR: p. 12

actions taken

GRI 206: Anti-competitive Behavior 2016

206-1

Legal actions for anti-competitive behavior,

AR: p. 84-85

anti-trust, and monopoly practices

Local and regional purchasing is of only minor significance for the business model of a chemical distributor, in particular in the area of commodities.

Within the scope of internal audits, a total of 26 Brenntag companies were reviewed in relation to corruption risks, etc. in the reporting year.

10

10

10

ENVIRONMENTAL

GRI 103

Management Approach 2016

103-1

Explanation of the material topic and

SR: p. 59

its Boundary

103-2

The management approach and its

SR: p. 6-10,18-21,35-39,

components

44-49

103-3

Evaluation of the management approach

SR: p. 9, 16-17,18-21,

35-39,44-49

GRI 302:

Energy 2016

302-1

Energy consumption within the organization

SR: p. 45

302-3

Energy intensity

SR: p. 45

302-4

Reduction of energy consumption

SR: p. 44-47

GRI 303:

Water 2016

303-1

Water withdrawal by source

SR: p. 47-48

303-2

Water sources significantly affected by

SR: p. 47-48

withdrawal of water

GRI 305:

Emissions 2016

305-1

Direct (Scope 1) GHG emissions

SR: p. 45

305-2

Energy indirect (Scope 2) GHG emissions

SR: p. 45

305-4

GHG emissions intensity

SR: p. 45

GRI 306: Effluents and Waste 2016

306-2

Waste by type and disposal method

SR: p. 49

306-3

Significant spills

SR: p. 38, 48-49

SR:Brenntag Sustainability Report for the Financial Year 2019

AR:Brenntag 2019 Annual Report

Waste volumes are not recorded or consolidated on a Group-wide basis at Brenntag.

In the reporting period, there were three additional significant spills through which liquid chemicals were discharged into the environment. The chemicals were immediately removed and there was no damage to the environment.

7, 8

8

8, 9

7, 8

8

7, 8

7, 8

8

8

8

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

64

GRI STANDARD AND DESCRIPTION

REFERENCES

COMMENTS AND ONLINE RESOURCES

UNGC

GRI 307: Environmental Compliance 2016

307-1

Non-compliance with environmental laws

The Brenntag Group paid fines of approx. EUR 5,000 in the reporting period due

and regulations

to non-compliance with environmental regulations.

GRI 308: Supplier Environmental Assessment 2016

308-1

New suppliers that were screened using

SR: p. 50-53

environmental criteria

SOCIAL

GRI 103:

Management Approach 2016

103-1

Explanation of the material topic and

SR: p. 59

its Boundary

103-2

The management approach and its

SR: p. 6-17,23-28,39-42

components

103-3

Evaluation of the management approach

SR: p. 9, 23-28

GRI 401:

Employment 2016

8

8

401-1

New employee hires and employee turnover

SR: p. 27, 33

401-2

Benefits provided to full-time employees

SR: p. 30-31

that are not provided to temporary or

part-time employees

GRI 402: Labor/Management Relations 2016

402-1

Minimum notice periods regarding

operational changes

GRI 403: Occupational Health and Safety 2016

403-2

Injuries, occupational diseases and

SR: p. 39-42

work-related fatalities

GRI 404: Training and Education 2016

Brenntag reports the total number and ratio of new employees as well as the total number and ratio of employee turnover by region.

Due to our company's decentralized and international structure, it is not possible to provide a complete list of the benefits which our employees receive. For this reason, only a few examples are provided in this report.

Brenntag informs its employees of impending operational changes at an early stage and comprehensively, while complying with applicable national and

international­notification periods.

6

6

3

404-2

Programs for upgrading employee skills and

SR: p. 26-30

Brenntag offers its employees target group-specific and individual measures

transition assistance programs

and training at a global, regional and local level and provides them either in

conventional events attended in person or through online training events. The

global e-learning management system provides employees with an opportunity

to enhance their knowledge and skills independently and efficiently.

404-3

Percentage of employees receiving regular

Annual feedback meetings take place for all Brenntag employees in which the

performance and career development

employees' performance is considered and their goals and personal expectations

reviews

as well as individual development measures are discussed.

GRI 405: Diversity and Equal Opportunity 2016

405-1

Diversity of governance bodies and

SR: p. 24-25,30-31,32-33

Brenntag reports its employee structure by region and age group. The age group

employees

AR: p. 24-31

structure does not include any employees in the North America region - age

data have not been fully recorded for all employees due to North American

legislation. Valid evaluation of this data is therefore not possible.

405-2

Ratio of basic salary and remuneration of

SR: p. 31

The recruitment, remuneration and development of employees solely reflect

women to men

their qualifications and abilities in relation to their respective duties.

GRI 406: Non-discrimination 2016

406-1

Incidents of discrimination and corrective

SR: p. 13, 16

Brenntag reports on the total number of confirmed compliance incidents. For

actions taken

confidentiality reasons, we do not disclose the exact number of complaints by

type. Accordingly, we do not explicitly report the number of complaints relating

to discrimination.

GRI 407: Freedom of Association and Collective

Bargaining 2016

407-1

Operations and suppliers in which the right

SR: p. 13-14, 29, 50-53

As part of our TfS membership, we request that our suppliers undergo sustain-

to freedom of association and collective

ability assessments, which also include a review of protection of the right of

bargaining may be at risk

association and the right to collective bargaining. Brenntag's Code of Business

Conduct and Ethics as well as our Supplier Code of Conduct also require the

protection of human rights, equal treatment and fair working conditions.

6

6

6

3

SR:Brenntag Sustainability Report for the Financial Year 2019

AR:Brenntag 2019 Annual Report

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

TABLE OF CONTENTS

GRI CONTENT INDex

65

GRI STANDARD AND DESCRIPTION

REFERENCES

COMMENTS AND ONLINE RESOURCES

UNGC

GRI 408: Child Labor 2016

408-1

Operations and suppliers at significant risk

SR: p. 10-12,13-16,50-53

for incidents of child labor

GRI 409: Forced or Compulsory Labor 2016

409-1

Operations and suppliers at significant risk

SR: p. 10-12,13-16,50-53

for incidents of forced or compulsory labor

GRI 410: Security Practices 2016

410-1 Security personnel trained in human rights policies or procedures

GRI 411: Rights of Indigenous Peoples 2016

411-1 Incidents of violations involving rights of indigenous peoples

GRI 412: Human Rights Assessment 2016

412-1 Operations that have been subject to human SR: p. 10-12,13-14 rights reviews or impact assessments

412-3 Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening

Brenntag will review the relevance of this aspect.

We have not received any reports on incidents for the reporting period.

For every company acquisition, aspects such as compliance and employment agreements are examined in addition to commercial factors as part of due diligence. We disclose information about these transactions in the annual report (page 39-40).

For information on the due diligence process on acquisitions, please see our website at https://www.brenntag.com/corporate/de/nachhaltigkeit/­ management-nachhaltigkeit/compliance/index.jsp.

5

4

1

1

1

2

GRI 413: Local Communities 2016

413-1 Operations with local community ­engagement, impact assessments, and development programs

GRI 414: Supplier Social Assessment 2016

414-1 New suppliers that were screened using social criteria

GRI 416: Customer Health and Safety 2016

416-2 Incidents of non-compliance concerning the health and safety impacts of products and services

GRI 417: Marketing and Labeling 2016

417-1 Requirements for product and service

information­and labeling

SR: p. 54-56

SR: p. 50-53

SR: p. 38-39

Brenntag does not systematically assess the impact of its community and social activities.

Within the framework of its HSE Group guidelines, the Brenntag Group has also specified processes and criteria for dealing with subcontractors that carry out construction, repair and maintenance work at Brenntag locations. Their purpose is to prevent accidents and incidents, enable work activities to be performed safely and protect the health of subcontractors.

There were no incidents during the reporting period.

1

417-2 Incidents of non-compliance concerning product and service information and labeling

417-3 Incidents of non-compliance concerning marketing communications

GRI 418: Customer Privacy 2016

418-1

Substantiated complaints concerning

SR: p. 10-12

breaches of customer privacy and losses of

customer data

GRI 419: Socioeconomic Compliance 2016

419-1

Non-compliance with laws and regulations

AR: p. 84-85

in the social and economic area

SR:Brenntag Sustainability Report for the Financial Year 2019

AR:Brenntag 2019 Annual Report

There were no incidents during the reporting period.

There were no incidents during the reporting period.

Brenntag reports on the total number of confirmed compliance incidents.

For confidentiality reasons, we do not disclose the exact number of complaints by type. Accordingly, we do not explicitly report the number of complaints

relating to data protection measures.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

66

IMPRINT

Issuer

Concept and text

Brenntag AG

Corporate Development, Brenntag AG

Messeallee 11

Kirchhoff Consult AG, Hamburg, Germany

45131 Essen, Germany

T +49 (0) 201 6496 0

Design and layout

F +49 (0) 201 6496 1010

Kirchhoff Consult AG, Hamburg, Germany

info@brenntag.de

www.brenntag.com

Print

WOESTE DRUCK + VERLAG GmbH & Co KG,

Contact

Essen, Germany

Brenntag AG

Corporate Development

Production management

Dr Dirk Eckert

Labude. corporate products, Essen, Germany

T +49 (0) 201 6496 1317

sustainability@brenntag.de

Picture credits

Page 19: © Tina Klarskov Olesen/ALUMICHEM

Project Management/Editor-in-chief

Page 49: © www.temm.ch/M. Eberhard

Dr Dirk Eckert

Other pictures: Brenntag

Corporate Development, Brenntag AG

Katharina Kasper

This Sustainability Report is a translation of the

Corporate Development, Brenntag AG

original German version. In case of any differ-

ences only the German version is binding.

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

BRENNTAG AGSUSTAINABILITY REPORT FOR THE FINANCIAL YEAR 2019

BRENNTAG AG

Messeallee 11

45131 Essen Germany www.brenntag.com

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Brenntag AG published this content on 29 April 2020 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 30 April 2020 08:22:09 UTC