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      1. Human Rights Policy

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        Commitment to Human Rights

        Corning believes in the fundamental dignity of the Individual, which is one of our core Values. The very foundation of this Value is respect for the rights, freedoms and standards of treatment to which all people are entitled—human rights. To view Corning's Human Rights Policy please click here.

        At Corning, we uphold these rights, regardless of race, sex, nationality, ethnicity, age or other status. ?Respect for human rights is practiced the same way we practice our other Values: everyday, as a part of every interaction with each other and those with whom we do business. It is a responsibility we take seriously. The Corporate Relations Committee of our Board of Directors provides oversight on issues related to our human rights policy, risks and responses. The Senior Vice President of Human Resources has internal oversight over employee and contingent worker human rights matters and our Senior Vice President and Chief Supply Chain Officer oversees the application of the policy to third party suppliers. The Senior Vice President of Human Resources relies upon Corning’s global and regional human resource personnel for day-to-day responsibilities to implement our programs and policies regarding employee and contingent worker human rights matters worldwide. We are committed to maintaining and improving our oversight systems and processes, which include due diligence targeting high-risk locations, supplier audits and compliance oversight within our supply chain, ongoing health and safety audits within our facilities, regular climate surveys that employees can complete anonymously, and a secure code of conduct hotline that any party can access. Our policy is communicated to workers and suppliers, who are expected to act in accordance with our policies as a condition of working for or doing business with Corning.

        Corning also supports the advancement of human rights through our global efforts to make the world more connected, to expand technology access, and to promote sustainable technological innovations. ?We are committed to continuous improvement, valuing the Individual, and being a responsible member of the communities in which we live and work around the globe.

        Approach to human rights due diligence

        The?Corning Code of Conduct?describes the company's business conduct principles, or core values, which set forth global legal and ethical expectations for all members of Corning's workforce and third parties?who act on Corning’s behalf. The principles in this Code of Conduct remain consistent with Corning’s longstanding business conduct principles, its Values, and our shared ethical standards for conducting business with uncompromising honesty and integrity. In our view, human rights due diligence requires a holistic approach. We assess our own business as?well as those who are acting on our behalf — in supply roles, and in mergers and acquisitions — to identify the salient human rights issues applicable to our business. We have a grievance mechanism in place via a third party reporting service, which can be used?by employees or others who are or become aware of an issue to raise a concern regarding any possible adverse human rights impacts.?Please see the section “Raising, addressing and resolving concerns” below.? We also implement an annual corporate Climate Survey and biennial Climate Surveys for each business during which we obtain feedback from our Corning colleagues on a variety of issues, including ethics and compliance, and we take improvement actions based on the results. We comply with all applicable laws and honor the principles of internationally recognized human rights when faced with conflicting requirements.

        Assessing human rights and salient risks

        Our assessment of human rights aligns with our corporate Human Rights Policy and includes these points of review: a fair, safe and healthy workplace; a workplace free from unlawful discrimination, harassment, bullying or victimization; freedom of association; and prohibition on and prevention of any use of child labor or forced labor. ?Evaluations are integrated into other assessment and management processes such as our Enterprise Risk Management process and are based on material issues regardless of where they’re identified within the value chain. Corning established a?sustainability goal?to address? Environmental, Social and Governance (ESG) issues in its Enterprise Risk Management process.? The ESG issues include human rights. In addition, we use the tool Riskmethods to assess risks associated with suppliers and our own operations.? Riskmethods provides enterprise-wide visibility to existing and emerging risks by generating risk scores for suppliers, customers, transportation locations, our own manufacturing locations and entire supply paths.? Riskmethods can also provide risk scores for Tier 2 suppliers and critical industry suppliers.? Each score is comprised of five major areas:? Viability, Delivery, Market/Cost, Image & Compliance and Quality & Performance.? Riskmethods also enables risk prioritization across the enterprise by utilizing these risk scores in combination with internal impact scores.??Based on this assessment process, we have determined that in our various spheres of influence (our own business and in others acting on Corning’s behalf), the sphere with the greatest potential for human rights impact is within our supply chain as indicated in the table below.

        Segment Salient Risk Action Plan to Prevent, Mitigate or Remediate Risk
        Suppliers Assuring conformance with Corning’s Supply Chain Social Responsibility and Supplier Code of Conduct expectations See sustainability goal to ensure that 100% of Corning’s high risk suppliers are certified as socially responsible. See our Supply Chain Social Responsibility pages for more information.
        Corning Employees

        Assuring conformance with the Corning Code of Conduct

        See sustainability goal to ensure that all employees understand the Code of Conduct including how to report allegations of ethical or legal misconduct.
        Corning Employees? Assuring a safe and healthy workplace See our Health and Safety webpages and our sustainability goal for occupational health and safety.
        Mergers and Acquisitions? Failing to recognize human rights issues during the merger or acquisition due diligence and integration processes. Prioritize and address human rights issues relative to risk and compliance as a part of Corning's mergers and acquisitions processes.? A detailed plan to integrate the new acquisition into Corning is generally developed within the first 100 days after the acquisition.

        Suppliers

        At Corning, we recognize that the choices we make for our material and service providers must also reflect our Values. We require our suppliers to share our commitment to maintaining ethical, compliant, responsible, and sustainable operations and practices. In addition to full compliance with all applicable labor and employment laws, we expect our suppliers to be committed to upholding the human rights of workers and to treating them with dignity and respect as generally understood by the recognized international community. This applies to all workers, including temporary, migrant, student, contingent, and direct employees. These expectations are laid out in the Corning Supplier Code of Conduct to drive supply chain Sustainability through supplier performance assurance. For details on our supplier assessment process, see our Supply Chain Social Responsibility pages on our website.

        Within our own operations

        Within Corning, our approach to managing and assuring human rights aligns with the Corning Code of Conduct, which recognizes the right of employees to have a respectful workplace free from unlawful discrimination, harassment, bullying or victimization as well as a safe and healthy workplace.? Our Code of Conduct indicates that we continually aim to be a leader in health and safety in our industries.? Our Occupational Safety and Health sustainability goal to continue to maintain our safety metrics in the top quartile of our industry benchmark values was set based on our assessment of safety performance and our desire to address this salient risk.

        Corning complies with all laws and regulations related to working hours for employees, and ensures that working hours include the minimum breaks and rest periods set by law.? Many of Corning’s manufacturing plants run continuous (24/7) operations and will have either 8-hour or 12-hour shift patterns, or a combination of both, as well as overtime shifts.? Actual shift patterns and duration are based upon production requirements, and hours worked by employees on a week-by-week basis will vary depending upon shifts and scheduling.? In all instances Corning complies with contract terms and legal requirements related to work hours, shifts, overtime, and compensation.

        Corning respects the rights of its employees to peacefully and lawfully form, join, not join, or leave workers’ associations of their own choosing. Where employees are represented by a legally-recognized union, Corning is committed to bargaining in good faith with the employees’ freely chosen representative. All of our businesses respect the rights of workers to communicate openly with management regarding working conditions without fear of retaliation, harassment, intimidation or interference.

        As stated in the Code of Conduct, all members of Corning’s workforce are held to the same high standards.? If the Code of Conduct sets a higher standard than applicable law, we are expected to follow the Code of Conduct and do business in accordance with the Corning Values.? Corning’s success depends on each of us doing the right thing.? No matter our job title, we are all leaders when it comes to ethics and integrity, and we must meet these important commitments:

        • Know and follow the guidance set forth in our Code of Conduct
        • Foster a positive, inclusive work environment and a strong culture of ethics
        • Complete applicable compliance training and certification requirements
        • Report suspected violations of the law or our Code of Conduct
        • Do not engage in workplace retaliation
        • Report any known or suspected retaliation
        • Cooperate with official Corning investigations

        Corning employees, including all supervisors, managers, and other leaders, are responsible for knowing and following the ethical, legal, and policy requirements that apply to their jobs and for reporting any suspected violations of law or the Code of Conduct.? Executives and managers are accountable for creating an inclusive workplace environment that encourages asking questions and raising concerns.

        Assuring human rights through training

        All employees are required to complete training related to Corning’s Code of Conduct. This training ensures that employees are familiar with the areas covered by Corning’s Code, including ethical and legal obligations toward the protection of human rights. Corning’s training also ensures employees know how to report concerns, including through Corning’s anonymous third-party hotline if desired. Corning maintains a strong commitment to preventing retaliation against those who report compliance concerns as set forth in Corning’s?Whistleblower Policy.

        In addition, management personnel within Corning are also required to complete an annual certification attesting that they know and understand the requirements of Corning’s Code of Conduct.

        Others acting on Corning’s behalf

        Upholding Corning’s Code of Conduct and Values is the responsibility of everyone acting on Corning’s behalf. Multiple processes are in place to assure Corning’s principles are being upheld by these parties. Case in point: our approach to health and safety. Under our Health and Safety Policy, Management System, and Strategy, Corning requires Corning employees to select and retain suppliers, contractors, or outsourced manufacturers and service providers who comply with all applicable laws and regulations and meet Corning’s health and safety expectations. In addition, at Corning sites, all visitors, suppliers, contingent workers, and contractors are held to the same safety and health requirements as Corning employees.

        Mergers and acquisitions

        Corning regularly pursues the purchase of business interests. For each business that may be acquired, human rights issues are prioritized and addressed relative to risk and compliance during the acquisition due diligence and integration processes.

        Raising, addressing, and resolving concerns

        When concerns related to human rights, labor practices, environmental, or safety issues arise, our employees and others who are or may become aware of such issues are encouraged to raise questions and report known or suspected misconduct.

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        We provide a variety of mechanisms for reporting and resolving concerns

        • Discuss any issues with or report any perceived wrongdoing to your supervisor
        • Talk with your human resources leader or any other manager.
        • Contact the Law Department at (607) 974-0000 and ask to speak to a lawyer about the Code of Conduct and your concerns.
        • Contact the Finance Division at (607) 974-8242 and ask to speak to the Corporate Controller or Treasurer about the Code of Conduct and your concerns.
        • Contact Corning’s Code of Conduct Line at (888) 296-8173 or at www.ethicspoint.com. These services can be used to make an anonymous report and are available on a 24/7 basis. An outside organization provides these services and your report cannot be traced back to you unless you choose to identify yourself.

        See Corning’s website for more information regarding how to report a concern. Additional information can be found in the Corning Code of Conduct and in Corning’s Whistleblower Policy. Corning prohibits retaliation against anyone who asks a question, reports a concern in good faith, or participates in a company investigation.

        Tracking and monitoring actions taken

        Each functional area with ownership of a salient risk has the responsibility to track actions taken to prevent, mediate or remediate the risk through their established management systems.? For example, Corning established a sustainability goal that all Corning Incorporated employees will understand Corning’s Code of Conduct, including how to report allegations of ethical or legal misconduct. The Compliance team in the Law Department will track progress toward this goal through the existing Climate Survey process.? As another example, Global Safety Services tracks health and safety performance through their existing management system and will compare Corning’s performance with our industry benchmark values to ensure that we maintain our safety metrics in the top quartile, our Occupational Safety and Health sustainability goal.? Lessons learned within the Global Safety Solutions function are regularly shared throughout Corning operations using multiple methods to include written communications and regularly scheduled meetings.

        Communicating

        Corning has established a goal to issue a sustainability report in 2021.? We anticipate using that report as well as our sustainability webpages to communicate how we assess and protect human rights.? Furthermore, our Whistleblower Policy states that any “…complainant will be notified of the outcome of the investigation.” Corning’s Whistleblower Policy would govern any allegation of a human rights impact received through the channels indicated above in the section “Raising, addressing and resolving concerns”.

        Our Policy

        At Corning, we:

        • Respect and support human rights as set out in the ten principles of the?UN Global Compact as well as the UN Guiding Principles on Business and Human Rights.
        • Expect our employees and contractors to comply with this policy, in the context and spirit of Corning’s?Values?and?Code of Conduct, and we seek to work with third parties who support our approach and standards.
        • Comply with applicable laws that support human rights wherever we operate. Where our policy goes further than local laws, we’ll operate to our policy. If our policy conflicts with local law, we’ll follow local law while trying as far as possible to act in accordance with the spirit of our policy.
        • Are committed to providing a fair, safe and healthy working environment for our employees that is free from unlawful discrimination, harassment, bullying or victimization.
        • Do not tolerate or support the use of child labor, forced or compulsory labor in our operations.
        • Respect and support the right of employees to establish, join or not join trade unions or other associations, and we recognize any local rights to collective bargaining.
        • Are committed to being an inclusive employer, promoting and valuing diversity within our workforce, among our customers, suppliers and in the communities in which we operate.
        • Care about the way our suppliers do business, and we will work with them to continuously improve. Our?Supplier Code of Conduct?outlines our expectations in the areas of labor and human rights, as well as health and safety, environment, ethical dealings and supply chain diversity.
        • Do not tolerate bribery and corruption in any form. Bribes, pay-offs, facilitation payments, secret, unjustified or inflated commissions, kick-backs and any like payments are strictly prohibited.

        Employees who suspect any behavior which is inconsistent with this policy should follow the reporting procedures in Corning’s Code of Conduct.? Corning strictly prohibits any form of retaliation for good faith reports, as described in our Code of Conduct and?Whistleblower Policy.

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        Wendell P. Weeks
        Chairman and Chief Executive Officer

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