EMEA MANAGEMENT POLICY

JUNE 11TH, 2010

Ecolab is the global leader in cleaning, sanitizing, food safety and infection prevention products and services.  Headquartered in St. Paul, Minn., U.S.A., Ecolab delivers comprehensive programs and services to foodservice, food and beverage processing, healthcare and hospitality markets in more than 160 countries.

Ecolab has a long history in Europe, the Middle East, and Africa, having opened our first office in the region over fifty years ago.  Headquartered in Zurich, Switzerland, since 2008, the company employs a workforce of more than 7,000 employees in 35 countries across EMEA.

Ecolab leads the industry through innovation and expertise, qualities which enable us to provide customers with cutting edge products and services.  Our solutions are developed to provide the best results at the lowest total environmental impact. Sustainability is at the center of design strategies for our products and services.

From concentrated, solid formulations to innovative packaging and dispensing methods, our products are designed to help increase safety, lower the use of water and energy, and reduce amounts of chemicals and waste released to the environment.  Supported by the expertise of our associates and combined with our dedication to social responsibility, these offerings provide value to our customers and help foster a more sustainable world.

Across Europe, a number of guiding principles underwrite our commitment to provide our customers and business partners with world-class service, products, and to protect the environment:

• LEGAL COMPLIANCE: Our products, systems and services as well as our business operations always comply with applicable national, European Union and international regulations.

• DECISION-MAKING: Ecolab makes sound decisions based on scientific evidence — and considers the total, long-term environmental impact of each product and process we evaluate.

• PRODUCT FORMULATIONS: When Ecolab replaces product ingredients, reformulations will maintain environmental responsibility, performance, cost and user safety. Replacements will not compromise on health, safety or the environment.

• RESEARCH AND DEVELOPMENT: Ecolab has systematically built a system of “checkpoints” that measure total impact all the way from concept development through product launch. This holistic approach to research and development will provide even greater insight into the total impact of products on the environment.

• MANAGEMENT RESPONSIBILITIES: We expect our associates in Europe to contribute to quality targets, to the prevention of environmental pollution and the upholding of work safety standards within their area of responsibilities as defined by job profiles.  Management is charged with defining learning goals and follow-up on training.

• THE SYSTEMATIC APPROACH: Ecolab strives to maintain and continuously improve management systems in Europe covering quality, environmental protection and safety.  Failure prevention, risk minimization and systematic correction in case of deviation are key elements of our systematic approach.  These management systems are guided by the European headquarters and shall comply with international certification standards for management systems and all other relevant regulatory requirements.

©2010 Ecolab USA Inc. All rights reserved.