Ethics and Compliance Statement

Our code ofconduct outlines the expectations of behavioural standards across all levels of the organization. It is embodied in our Standards of Business Conduct which includes guidance on:

We encourage employees and stakeholders to report any concerns or violations of our ethics and compliance policies. Reports can be made confidentially and without fear of retaliation. All concerns will be investigated promptly and thoroughly, and appropriate corrective actions will be taken when necessary.

We work with world leading ethics, legal, and compliance advisory firms to regularly review and update our ethics and compliance programs to reflect evolving legal requirements, industry best practices, and stakeholder expectations. Training and awareness initiatives are provided to ensure that our team remains informed and empowered to uphold our values.

– Please refer to our Standards of Business Conduct

1. Ethics Policy
The policy of the Company is to comply with all governmental laws, rules, and regulations applicable to its business.

Local customs, traditions, and values differ from place to place, and this must be recognized.  But honesty is not subject to criticism in any culture.  A well-founded reputation for scrupulous dealing is itself a priceless corporate asset.  The Company expects compliance with its standards of integrity throughout the organization and will not tolerate employees who achieve results at the cost of violation of the law or who deal unscrupulously.  The Company cares how results are obtained, not just that they are obtained.

2. Conflicts of Interest Policy
It is the policy of the Company that all officers and employees are expected to avoid any actual or apparent conflict between their own personal interests and the interests of the Company.  A conflict of interest can arise when an officer or employee takes actions or has personal interests that may interfere with his or her objective and effective performance of work for the Company.  Officers and employees are expected to refrain from taking for themselves opportunities discovered through their positions with the Company and refrain from competing with the Company.

3. Gifts and Entertainment Policy
It is the policy of the Company to base commercial decisions on commercial criteria.  This policy serves the Company’s business interests and fosters constructive relationships with organizations and individuals doing business, or seeking to do business, with the Company.  In many cultures, those constructive relationships may include incidental business gifts and entertainment.  Officers, employees and third parties acting on behalf of the Company providing or receiving third party gifts and entertainment in their corporate capacities are expected to exercise good judgment in each case, taking into account pertinent circumstances, including the  character of the gift or entertainment, its purpose, its appearance, the positions of the persons providing and receiving the gift or entertainment, the business context, reciprocity, and applicable laws and social norms.  Gifts and Entertainment must not be intended to create an improper advantage for the Company.  All expenditures for gifts and entertainment provided by the Company must be accurately recorded in the books and records of the Company.

4. Anti-Corruption Policy
It is the policy of the Company that officers, employees and third parties acting on its behalf are prohibited from offering or paying, directly or indirectly, any bribe to any employee, official, or agent of any government, commercial entity, or individual in connection with the business activities of the Company.  A bribe for purposes of this policy is any money, goods, services, or other thing of value offered or given with the intent to gain an improper advantage for the Company.

No employee or third party should assume that the Company’s interest ever requires otherwise.

5. Trade Laws Policy
It is the policy of the Company that its officers and employees are expected to comply with all trade laws, rules, and regulations (including sanctions, export controls, customs, and antiboycott) that are applicable to the Company’s business.  No officer or employee should assume that the Company’s interest ever requires otherwise.

It is recognized that, on occasion, there may be legitimate doubt as to the proper interpretation of the law or that applicable laws may conflict.  In such circumstances, it is required that officers and employees refer the case through appropriate channels to the Law Department for advice.

6. Antitrust / Anticompetition Policy
It is the policy of the Company that officers and employees are expected to comply with the antitrust and competition laws of a country or group of countries which are applicable to the Company’s business.  No officer or employee should assume that the Company’s interest ever requires otherwise.

It is recognized that, on occasion, there may be legitimate doubt as to the proper interpretation of the law.  In such circumstances, it is required that officers and employees refer the case through appropriate channels to the Law Department for advice.

7. Harassment in the Workplace Policy
It is the policy of the Company to prohibit any form of harassment in any Company workplace.  The objective of this policy is to provide a work environment that fosters mutual employee respect.  Harassment will not be tolerated.

Individuals who believe they have been subjected to harassment or who believe they have witnessed harassment at the workplace should immediately report the incident to their supervisors, higher management, the Human Resources Department or the Law Department.  All complaints will be promptly and thoroughly investigated.  No retaliation will be taken against any employee because he or she reports a problem concerning possible acts of harassment.  Employees can raise concerns and make reports without fear of reprisal.

8. Corporate Assets Policy
It is the policy of the Company that officers and employees are expected to protect the assets of the Company and use them efficiently to advance the interests of the Company.  Those assets include tangible assets and intangible assets, such as confidential information of the Company or personal information held by the Company.

No officer or employee should use or disclose at any time during or after employment or other service with the Company, without proper authority or mandate, personal or confidential information obtained from any source in the course of the Company’s business.  Examples of confidential information include non-public information about the Company’s plans, earnings, financial forecasts, business forecasts, discoveries, competitive bids, technologies, and personnel.

9. Whistleblowing and Open-Door Communication Policy
The Company encourages employees to ask questions, voice concerns, and make appropriate suggestions regarding business practices of the Company.  Employees are expected to report promptly to management suspected violations of law, the Company’s policies, and the Company’s internal controls, so that management can take appropriate corrective action.  The Company will promptly investigate any reports of such suspected violations.

No action may be taken or threatened against any employee for asking questions, voicing concerns, or making complaints or suggestions, unless the employee acts with wilful disregard of the truth.

Failure to behave honestly, failure to comply with law and the Company’s policies, and the Company’s internal controls may result in disciplinary action, up to and including separation.  No one in the Company has the authority to make exceptions or grant waivers to the Company’s standards of business conduct.

10. Health and Safety Policy
It is the Company’s policy to conduct its business in a manner that protects the health and safety of its officers, employees, customers, others involved in its operations, and the public.  The Company will strive to prevent all accidents, injuries, and occupational illnesses through the active participation of every employee.  The Company is committed to continuous efforts to identify and eliminate or manage health and safety risks associated with its activities.