Our Code of Ethics and Business Conduct (the “Code”) sets the standards for how we conduct our business with the highest ethical behavior.

Our Code applies to all officers, directors and employees of Tronox, as well our agents, suppliers, contractors and other partners who provide goods and services to Tronox or act on our behalf. The purpose of the Code is to ensure that Tronox conducts business ethically, honestly, and in full compliance with applicable laws and regulations. This applies to every business decision in every area of the company worldwide.

An important part of the Code is the requirement that all individuals subject to the Code “Speak Up!” and report suspected violations and concerns. Tronox’s Legal Department is responsible for investigating allegations made through Tronox’s “Speak Up!” Ethics and Compliance Hotline. Any concern reported on “Speak Up!” is carefully investigated in a way that ensures that the anonymity of the person reporting the concern is protected and that appropriate action is taken.