Ecolab Inc

###### Political Action
Engaging with policymakers is one means
of furthering our sustainability objectives.
We communicate with policymakers in
proactive policy discussions, bringing our
market segment and scientific expertise to
the table on water, waste, food safety and customer health
issues to ensure public policy decisions are grounded in
principles of sound science. Ecolab engages with federal and
state legislative and regulatory bodies, industry and customer
trade associations and non-governmental organizations that
provide a forum for environmental policy discussion relevant
to our industry. These include a diverse set of stakeholders
which focus on water-related issues and climate mitigation and
adaptation issues to influence climate policy.

Ecolab associates also can support the company's political
action committee, the Ecolab Inc. Political Action Committee
(ECOPAC). ECOPAC, which is funded by voluntary contributions
from Ecolab associates, is a nonpartisan committee that
supports candidates for Congress who share our basic
philosophies and values. It contributes to legislators from
across the country where the company transacts business.
Contributions are determined by a board of Ecolab executives
based on criteria including representation of Ecolab facilities
and/or significant base of employees, committee membership,
committee leadership, positions on issues and partisan
balance. ECOPAC does not support candidates for state, local
or presidential office. A list of all political contributions by
ECOPAC and Ecolab is posted semi-annually to the Ecolab
[website under Political Contribution Reporting.](https://investor.ecolab.com/corporate-governance/political-contribution-reporting/)

- Works with governments, academia, nongovernmental organizations, business associations and other interested stakeholders to develop effective and sustainable solutions to safety, health and environmental challenges we all face in our business activities.

- Engages directly with policymakers in proactive policy discussions to bring our market segment and scientific expertise to the table on energy, water, waste, food safety and customer health issues that may be impacted by climate change.

- Applies these principles and policies throughout our global footprint.

- Continues to provide transparent public reporting of our sustainability metrics and progress against our specific goals and targets and continues our commitment to annual third-party auditing of our greenhouse gas emissions inventory.

- Annually reviews the company's performance in implementing this position and update it as needed.

## Responsibility

The Corporate Sustainability department is responsible for the implementation of this position and development and execution of the Company's sustainability strategy, integrating sustainability principles and commitments globally. Ecolab's Safety, Health and Environment (SHE) Committee of the Board has the highest level of responsibility for all sustainability matters, including climate-related oversight.

#### Trade Association Memberships

Ecolab, like most businesses, belongs to trade associations that support initiatives important to Ecolab's business and our customers' industries. We engage with our key trade associations to achieve the following:

1. We work with trade associations to better understand the policy and regulatory environment that will impact our business operations,
2. We advocate through the association to ensure that our views on matters of importance to Ecolab and our customers are adequately communicated and represented to law and policy makers, and
3. Our associates access educational, training and professional networking opportunities.

Ecolab joins trade associations that it feels will benefit our business and shareholders, but trade associations have diverse memberships and diverse member views. The positions taken by trade associations or their members may not always align with Ecolab's business objectives, and Ecolab may adopt policies and positions that are different from the views of trade associations of which Ecolab is a member or their members. Ecolab raises its concerns, as needed and as appropriate, on issues that it believes are important to Ecolab and its stakeholders.

Some of the trade associations to which Ecolab belongs engage in lobbying activities to support these initiatives. These trade associations may use a portion of the membership dues paid by Ecolab for such lobbying activities. Ecolab itself also engages in certain lobbying activities, but does not engage in grassroots lobbying communications and is not involved with tax-exempt organizations that write or endorse model legislation. For this purpose, "grassroots lobbying communications" means communications directed to the general public that (a) refer to specific legislation or regulation, (b) reflect a view on the legislation or regulation and (c) encourage the recipient of the communication to take action with respect to the legislation or regulation. When Ecolab lobbies on individual issues of interest, various laws and regulations may apply, including the U.S. Lobbying Disclosure Act and the E.U. Transparency Register and its Code of Conduct, and Ecolab takes appropriate actions to comply with these laws.

A committee of management consisting of the Senior VP of Government Relations, the Assistant Secretary or Secretary, the Chief Operating Officer, the Senior VP of Regulatory Affairs, and the Executive VP for Global Markets reviews proposed and existing significant trade association memberships at least semi-annually to assess their effectiveness and to determine if continued membership is appropriate. The committee escalates membership decisions to the CEO in situations in which the committee believes membership in a trade association could be materially misaligned with Ecolab's stated values. The Governance Committee of the Board of Directors reviews Ecolab's significant trade association memberships, as well as Ecolab's policies and practices relating to trade association memberships, on an annual basis.

###### Political action

Public policy
Engaging with policymakers is one means of furthering our sustainability objectives. We communicate with policymakers in proactive policy discussions, bringing our market segment and scientific expertise to the table on water, waste, food safety and customer health issues to ensure public policy decisions are grounded in principles of sound science. Ecolab engages with federal and state legislative and regulatory bodies, industry and customer trade associations and non-government organizations that provide a forum for environmental policy discussion relevant to our industry. These include a diverse set of stakeholders which focus on water-related issues and climate mitigation and adaptation issues to influence climate policy.

We maintain a formal process to manage all direct and indirect engagement with policy makers and related organizations to ensure we have a common approach consistent with our business strategy. This process covers the scope and business impact of specific policy issues and is integrated into the annual business continuity and risk management assessment process so any activities that influence policy are evaluated for alignment with Ecolab's strategic corporate business strategy. If inconsistent, these are immediately flagged for action by the Government Relations team.

###### Political contributions
[Ecolab's Political Contribution Policy](https://s24.q4cdn.com/931105847/files/doc_downloads/political_contribution/ecl-webdoc-14080.pdf) provides an approval process for corporate political contributions by a committee of executives, as well as an annual review of the policy and political contributions by the Governance Committee of the Ecolab Board of Directors. In 2022, Ecolab Inc. contributed $30,000 to the Democratic Governors Association, $30,000 to the GOPAC, Inc., and $15,000 to the Republican Governors Association.

Ecolab associates can also support the company's political action committee, the Ecolab Inc. Political Action Committee (ECOPAC). ECOPAC, which is funded by voluntary contributions from Ecolab associates, is a nonpartisan committee that supports candidates for U.S. Congress who share our basic philosophies and values. It contributes to legislators from across the country where the company transacts business. Contributions are determined by a board of Ecolab executives based on criteria including representation of Ecolab facilities and/or significant base of employees, committee membership, committee leadership, positions on issues and partisan balance

ECOPAC does not support candidates for local or presidential office. A list of all political contributions by ECOPAC and Ecolab is posted semiannually [to the Ecolab website under Political](https://investor.ecolab.com/corporate-governance/political-contribution-reporting/) [Contribution Reporting.](https://investor.ecolab.com/corporate-governance/political-contribution-reporting/)

###### Membership of associations
Industry and policy groups have a unique ability to influence standards, regulations and practices. Ecolab engages with a broad range of industry groups, sharing expertise and insights to help these membership organizations enhance sustainability leadership across their respective industries.

In 2022, Ecolab actively participated in sustainability-related work groups within the following, among others: A.I.S.E. (International Association for Soaps, Detergents and Maintenance Products); American Chemistry Council; American Cleaning Institute; American Hotel & Lodging Association; Chemical Footprint Project; The Conference Board; Consumer Brands Association; Consumer Goods Forum; Corporate Eco Forum; Council of Great Lakes Industries; Food Marketing Institute; Global Food Safety Initiative; Household and Commercial Products Association; International Organization for Standardization; National Association for Environmental Management; National Association of Manufacturers; National Restaurant Association; Steel Manufacturers Association; United States Council for International Business; and World Environment Center

###### POLITICAL ACTION

Public Policy
Engaging with policymakers is one means of
furthering our sustainability objectives. We
communicate with policymakers in proactive
policy discussions, bringing our market segment
and scientific expertise to the table on water,
waste, food safety and customer health issues to
ensure public policy decisions are grounded in
principles of sound science. Ecolab engages with
federal and state legislative and regulatory bodies,
industry and customer trade associations and nongovernment organizations that provide a forum
for environmental policy discussion relevant to our
industry. These include a diverse set of stakeholders
which focus on water-related issues and climate
mitigation and adaptation issues to influence
climate policy.

We maintain a formal process to manage all direct
and indirect engagement with policy makers and
related organizations to ensure we have a common
approach consistent with our business strategy.
This process covers the scope and business impact
of specific policy issues and is integrated into the
annual business continuity and risk management
assessment process so any activities that
influence policy are evaluated for alignment with
Ecolab's strategic corporate business strategy. If
inconsistent, these are immediately flagged for
action by the Government Relations team.

###### Political Contributions
[Ecolab's Political Contribution Policy provides an](https://s24.q4cdn.com/931105847/files/doc_downloads/political_contribution/ecl-webdoc-14080.pdf)
approval process for corporate political contributions
by a committee of executives, as well as an annual
review of the policy and political contributions by
the Governance Committee of the Ecolab Board of
Directors. In 2021, Ecolab Inc. contributed $30,000
to the Democratic Governors Association, $30,000
to the GOPAC, Inc. and $5,000 to the Republican
Governors Association

Ecolab associates can also support the company's
political action committee, the Ecolab Inc. Political
Action Committee (ECOPAC). ECOPAC, which is
funded by voluntary contributions from Ecolab
associates, is a nonpartisan committee that
supports candidates for U.S. Congress who share
our basic philosophies and values. It contributes
to legislators from across the country where the
company transacts business. Contributions are
determined by a board of Ecolab executives based on
criteria including representation of Ecolab facilities
and/or significant base of employees, committee
membership, committee leadership, positions on
issues and partisan balance. ECOPAC does not
support candidates for local or presidential office.
A list of all political contributions by ECOPAC and
Ecolab is posted semiannually to the Ecolab website
[under Political Contribution Reporting.](https://investor.ecolab.com/corporate-governance/political-contribution-reporting/)

We employ a cross-functional group of leaders within the company to evaluate opportunities, the impact of specific policy proposals and the direct or indirect impact to the company. We also evaluate proposals alongside public commitments related to climate.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]We employ a cross-functional group of leaders within the company to evaluate opportunities, the impact of specific policy proposals and the direct or indirect impact to the company. We also evaluate proposals alongside public commitments related to climate.

Describe the process(es) your organization has in place to ensure that your external engagement activities are consistent with your climate commitments and/or climate transition plan?[…]We employ a cross-functional group of leaders within the company to evaluate opportunities, the impact of specific policy proposals and the direct or indirect impact to the company. We also evaluate proposals alongside public commitments related to climate.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes