Code of Conduct for Employees and Company Representatives

Introduction

This Code of Conduct ("Code") outlines the company's commitment to ethical and responsible behavior by all employees and company representatives. It serves as a guide for decision-making and conduct and promotes a culture of integrity, transparency, and compliance.

Scope

This Code applies to all employees, regardless of their position, location, or employment status. It also applies to company representatives, including consultants, contractors, agents, and others acting on behalf of the company.

Values and Principles

The company is committed to the following core values and principles:

• Integrity: We act with honesty, fairness, and transparency in all our dealings.
• Respect: We treat each other with dignity and respect, valuing diverse perspectives and fostering a positive work environment.
• Compliance: We comply with all applicable laws, regulations, and company policies.
• Accountability: We hold ourselves and each other accountable for our actions and decisions.
• Sustainability: We strive to conduct our business in a manner that is environmentally and socially responsible.

Specific Conduct Guidelines

To uphold these values and principles, all employees and company representatives must adhere to the following:

1. Conflicts of Interest:

• Avoid any personal or professional interest that could conflict with the company's interests.
• Disclose any potential conflicts of interest to the company immediately.
• Refrain from engaging in any activity that could compromise their objectivity or judgment.

2. Anti-Corruption and Bribery:

• Do not offer, promise, give, or accept any bribe, kickback, or other illegal payment.
• Do not participate in any activity that could be perceived as bribery or corruption.
• Comply with all anti-corruption laws and regulations in the countries where we operate.

3. Fair Dealing:

• Conduct business with honesty and integrity, avoiding any unfair or deceptive practices.
• Treat all customers, suppliers, and competitors with respect and fairness.
• Comply with all applicable competition laws and regulations.

4. Confidentiality:

• Maintain the confidentiality of company information and trade secrets.
• Do not disclose confidential information to unauthorized individuals.
• Use company information and resources only for authorized purposes.

5. Workplace Conduct:

• Treat all colleagues with respect and dignity, creating a safe and inclusive work environment.
• Avoid discrimination, harassment, bullying, or any other form of inappropriate behavior.
• Report any such behavior to the company immediately.

6. Responsible Use of Company Resources:

• Use company resources only for authorized purposes and avoid waste or misuse.
• Safeguard company assets and property.
• Comply with all company policies on resource usage.

7. Reporting and Compliance:

• Report any suspected violations of this Code, applicable laws, or company policies to the company immediately.
• Cooperate fully with any investigations.
• Retaliation against anyone reporting such violations is strictly prohibited.

8. Social Responsibility:

• Conduct business in a manner that is mindful of the company's social and environmental impact.
• Comply with all applicable environmental laws and regulations.
• Support the communities where we operate.

9. Continuous Improvement:

• Strive to continuously improve our ethical and responsible practices.
• Participate in training and development opportunities.
• Provide feedback and suggestions for improving this Code and the company's ethics and compliance program.

Disciplinary Action

Violations of this Code may result in disciplinary action, up to and including termination of employment or termination of contract. The company may also take legal action against individuals who engage in misconduct.

Reporting Mechanisms

Employees and company representatives are encouraged to report any suspected violations of this Code through the following channels:

• Direct supervisor
• Human Resources department
• Ethics hotline
• Anonymous reporting website

The company will investigate all reports of misconduct promptly and confidentially.

Conclusion

This Code is a living document and may be amended from time to time. All employees and company representatives are expected to familiarize themselves with the Code and comply with its provisions.

By adhering to this Code, we can create a positive and ethical work environment, maintain our reputation for integrity, and ensure the long-term success of the company.