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Statement regarding Brazil

November 11, 2011

Holcim hereby informs that it is aware of the report issued by the Secretariat of Economic Law of the Ministry of Justice  (SDE), regarding the administrative proceeding which seeks to evaluate the conduct of cement producers including Holcim (Brasil) S.A. in Brazil. The Company clarifies that, in the context of the proceeding, it has always supplied all information requested by the SDE.

However, regarding Holcim (Brasil) S.A., the Company does not agree with the conclusions recorded in the Report. Holcim (Brasil) S.A. confirms, as it has already done to the SDE in several occasions, that it has not engaged in any illicit conduct.

The report issued by SDE must be submitted to the Administrative Council for Economic Defense (Cade), which must evaluate and judge said proceedings. There is therefore still no conclusive decision or judgment regarding the case and Holcim (Brasil) S.A. will continue to conduct its defense as it has been doing.

As these are ongoing proceedings, Holcim is not in a position to comment further.

In 2003, the Board of Directors and the Executive Committee of Holcim Ltd have decreed a Code of Conduct binding for all Group companies and its employees. The Code of Conduct provides for respect for principles and rules of fair competition prohibiting anti-competitive behavior and the abuse of a dominant market position. Non-compliance may be subject to disciplinary sanctions including termination of employment. To embed these principles, Holcim has a dedicated global fair competition directive and a centrally coordinated training program. In addition, Group companies are regularly reviewed in this respect by independent attorneys.

The Code of Conduct is available at
Corporate Governance