Code of Conduct■ SECTION IINTEGRITY, AT THE BASIS OF OUR ACTIONS

I.1 The reason for having the Code of Conduct
VALVIS HOLDING GROUP (the “Group”)’s Code of Conduct (the “Code”) reﬂects the ethical principles underpinning the Group’sbusiness in Romania and elsewhere and is intended to lead the way on issues related to integrity and ethics for all participants. The
companies CARPATHIAN SPRINGS S.A., VALVIS HOLDING DISTRIBUTION S.A., AQUA CARPATICA UK LTD and AQUA CARPATICA
USA, Inc. shall represent the members of VALVIS HOLDING GROUP for the purposes of this Code and of policies making reference
to VALVIS HOLDING GROUP.
On short, the Code outlines the Group’s commitment to ensuring correctness and transparency in conducting its business with aﬁnal aim to keep its good reputation and secure its stakeholders’ trust and conﬁdence.
The principles encompassed by the Code relate to and rule all aspects of our business:
A. at the workplace
B. in the market
C. in the daily business activity
D. in the interaction with the community

I.2 To whom the Code applies
The Code applies to all places in the Group, be it ofﬁces, plants, warehouses, meeting rooms and enrols everyone: the members of
all boards and committees, any control and supervisory bodies, the employees and the managers of any company within theGroup.
Non-compliance with this Code may result in disciplinary action up to and including termination of employment.
The Code is approved by the Board of Administration and brought to everyone’s knowledge, monitored and enforced by theCompliance & Ethics Ofﬁcer.
Any waiver of the Code requires the prior written approval of the Compliance & Ethics Ofﬁcer or, in certain circumstances, the Boardof Administration or a committee thereof.

I.3 What is my responsibility?
We all have to act with integrity. Every one of us has to keep integrity at the core of every business decision that is made at any
time. Browse through this Code on every occasion when you have a doubt about how to act. It should give a response to youruncertainty, so that you can perform your duty in an ethical manner.
So, acting with integrity means:
A.
B.
C.
D.
E.

Respect this CodeDo what is ethically right
Be an example that everyone can follow
Behave transparently and honestly
Take responsibility for your actions

1

Code of Conduct ■ SECTION I

Also, using the power of example is a great way to shape people around you. No matter who you are, you can be an example ofintegrity. This mission accompanies especially the managers and leaders, who are expected to serve as a model and to inspireothers to be ethical, and this can be achieved in many ways:
A.
B.
C.
D.
E.

Rewarding integrity
Encouraging direct and indirect reports to make ethical decisions
Encouraging people to speak up and discuss their concerns in a friendly and protective environment
Preventing retaliation against anyone who reports a genuine concern
Seeking help in resolving and escalating issues when they arise

Every day can bring a new challenge that you need to overcome, and maybe that can tempt you to try to shortcut the ethicalpath in unnoticeable ways, hoping that it will be a onetime action that no one sees. If and when this happens, remember that
this Code has not only letters and words, but also a spirit. Keep in mind the spirit of this Code, which is about acting withintegrity at all times, whether you are alone and no one can see, or in a group.

Possible Scenario:
If your manager asks you to act in a way that you think it is a violation of this Code or an applicable law, you can raise yourconcern fearlessly and openly with your manager. If the response you receive is not satisfactory or makes you feel uncomfortable oryou don’t feel comfortable raising the concern directly with your manager, seek assistance with any of the several channels
indicated at section I.4 below.

I.4 How to seek advice and to report violations
The Code cannot cover all daily situations and simply cannot contain all responses. In all cases where you feel that you do notunderstand an aspect in the Code, or the Code does not respond your punctual question, or you have a serious concern, you needto seek advice or, as the case may be, to freely speak up and raise your concern.
You can do any of the above in 2 ways:A.

by contacting any of the functions indicated below:■ Your immediate manager, next level manager or Human Resources manager. In most cases, your ﬁrst point ofcontact should be your direct manager. You have the duty to report the issues that require urgent attention.
Also, you can seek guidance on various company and job-related issues, such as: work responsibilities,
co-worker issues, discipline disputes, promotion opportunities, and issues related to the work environment■ Compliance & Ethics Ofﬁcer or the Legal Department. Any of the two departments should be contacted in caseof Code violations:
A.
B.
C.
D.
E.
F.
G.

Accounting or auditing irregularities or misrepresentations
Fraud, theft, bribery and other corrupt business practices
Antitrust or Insider Trading violations
Human Rights violations
Illegal discrimination or harassment
Actual or potential conﬂicts of interest
Guidance on any national, regional, local legal requirements that apply to your job.

Possible Scenario:
Situations where you should seek guidance are those moments when something does not feel right. If you ask yourself
one of the following questions:
A.
B.
C.
D.

Am I sure that this course of action is legal? Is it consistent with our Code and other policies?
If I do that, will it hurt Group’s or any of its members’ reputation or cause any of the Group companies
to lose credibility? OR May the action or result reﬂect poorly on me or the Group or any of its members?
How would I feel if it was reported on the front page of the newspaper?
Am I putting other people at risk?
Am I acting with integrity, being truthful and honest?

and the response is uncertain or you have not a response, then seek advice from the functions / departments mentioned
above to help you make the right decision.

B.

by using the additional Speak Up Point of Contact

All employees, consumers, suppliers and other third parties, in case they have a question, a concern or a report to make inconnection to a suspected Code violation, may contact us at the following Speak-Up points of contact available worldwide 24/7:▶ Email adress: compliance.ethics@valvis-holding.com▶ Web page: aquacarpatica.com/compliance-form

2

Code of Conduct ■ SECTION IAny information you provide to assist in investigating your report will be kept conﬁdential, except as needed to conduct a full, fair
investigation or as otherwise required by applicable law. You may remain anonymous if you so choose, except where restricted by
local law.

I.5 Reported Misconduct: Investigation and Disciplinary Action
INVESTIGATION
Once reported, the violation or case will be entrusted for solving with professionals designated by the Compliance & Ethics Ofﬁcer,
who will:
1.
2.
3.

Act objectively in determining facts through interviews or a review of documents;
Contact employees who may have knowledge about the alleged incident(s);Recommend corrective actions and/or disciplinary measures, where appropriate

If asked, you must cooperate fully with any inquiry or investigation.

NO RETALIATION
Before, during and after, there will be no repercussions against you in relation to your reporting initiative. The Group will not
retaliate or permit retaliation against a person acting in good faith.
DISCIPLINARY ACTION
You need to know that violation of Code, other policies or the applicable law may result in:i.
ii.

Disciplinary action, which may range from additional training and coaching to employment consequences,including termination of employment; AND
Civil and/or criminal penalties imposed by a governmental agency or a court

3

Code of Conduct ■ SECTION I

■ SECTION II
THE CODE IN THE WORKPLACE

II.1 Human Rights, Diversity, Inclusion and Non-discrimination
Valvis Holding Group recognizes the importance of respecting the human rights and therefore the Code supports the principles
underpinned by the International Bill of Human Rights and the International Labour Organization Declaration on Fundamental
Principles and Rights at Work1, such as:- freedom and equality in dignity and rights- no discrimination and harassment based on race, colour, sex, language, religion, political or other opinion, national orsocial origin, property, birth or other status- interdiction of slavery or servitude- fair wages, beneﬁts and other conditions of employment in accordance with local laws
- safe and healthy working conditions- prohibition of child labour, forced labour and human trafﬁcking- freedom of association, including the right to form and join trade unions
The Group companies promote principles of diversity, inclusion and equal opportunities and are committed to creating aworkplace in which people are treated fairly, guaranteeing the right to appropriate working conditions.
We oppose all forms of behaviour that result in discrimination in relation to gender, age, disability, nationality, sexual orientation,
ethnicity, religion, political opinions, and all other forms of individual diversity, or that is detrimental to the person and his or her
convictions or preferences.
The Group does not tolerate any type of harassment such that result in a workplace that is humiliating, hostile, intimidating,offensive, or unsafe. In particular, the Group does not tolerate any form of harassment concerning sexuality and behaviours that
could upset individual sensitivities (e.g. allusions, explicit remarks, or sexual advances). Discrepancy of treatment is not considereddiscriminatory if it is motivated by objective criteria.
If you genuinely suspect a human rights abuse or any kind of harassment in the workplace, in the interaction with various
partners, speak up and report it.

II.2 Environment, Health and Safety
Environment, health and safety of people, be it employees, collaborators, visitors, consumers and communities, are the mostprecious asset to be protected at all times. In order to make this possible we all need to observe the existing policies andprocedures, within the precincts of our plants, ofﬁce, warehouse, in the marketplace or on the public domain.
Performing your duties under the inﬂuence of drugs or alcohol or other substances that may pose safety risks to yourself andothers is prohibited in the workplace. It is also forbidden to possess, sell, use, transfer or distribute illegal drugs or substances
while being on any of the Group’s premises. It is also prohibited to work whilst being under treatment involving lawfully
administered drug or medication that may impact your ability to work – also in this case you may pose risks to yourself andothers.
You have to report your concern if:- You are assigned a task that you consider is unsafe or harmful to you, others or the environment- You are assigned a job you think you are not properly trained to perform and that may harm you or others or theenvironment- Someone is performing a task that you believe is unsafe or harmful to the environment or that the person is notproperly trained to perform- A vehicle or piece of equipment is not operating properly and may be unsafe- An unsafe condition or a potential danger to yourself, others or the environment comes to your attention.

1 - ILO Declaration on Fundamental Principles and Rights at Work (1998), as amended in 2022:
https://www.ilo.org/dyn/normlex/en/f?p=1000:62:0::NO:62:P62_LIST_ENTRIE_ID:2453911:NO
International Bill of Human Rights: https://www.ohchr.org/en/what-are-human-rights/international-bill-human-rights , which is made of Universal Declaration of Human
Rights (UDHR) adopted in 1948 and 2 international treaties commonly referred to as International Covenants: International Covenant on Economic Social and Cultural
Rights (ICESCR), and the International Covenant on Civil and Political Rights (ICCPR) and its two Optional Protocols - adopted in 1966.
UDHR in Romanian language: https://www.ohchr.org/en/human-rights/universal-declaration/translations/romanian-romana
List of International Labour Organization Conventions: https://en.wikipedia.org/wiki/List_of_International_Labour_Organization_Conventions

4

Code of Conduct ■ SECTION II

■ SECTION III
THE CODE IN THE MARKETPLACE

III.1 Our Consumers
We put the consumers at the heart of our actions. Our consumers and their trust in our products are the basis of our success story.
To earn and maintain consumers’ trust we act responsibly and honestly, provide top quality products and safety standards and we
abide by the applicable legislation and the best practices of the industry. Every day, every action we take is a step forward to building
a close relationship with our consumers, by supplying our products, responding their questions, informing them with regard to our
products and initiatives.
If you are part of the chain DEVELOPMENT – PRODUCTION – HANDLING – STORAGE of our products, then you must know andrespect the food safety and product quality standards and the internal policies, procedures and protocols that apply to your work.
If your job involves MARKETING our products, then make sure that you refrain from making any misrepresentation about our
products, you don’t use misleading or untruthful statements about them and you don’t make claims (including claims about our
products and their ingredients or health effects of our products) without adequate validation and appropriate legal clearance.

III.2 Our Customers
Our customers are essential partners in our route-to-market strategy. Through them our products get to our consumers. It is therefore
paramount that we build with our customers trustful and mutually advantageous business relationships and that we base thiscollaboration on ethics and equity, clear and respected terms of business.

III.3 Our Suppliers
Selection of our suppliers (e.g. goods and/or service providers) has to be fair and transparent, whilst the business relationship withevery one of them is based on fairness, ethics and clear terms of business. Our suppliers need to have the same standard of integrity
as ourselves and to comply with our Supplier Code of Conduct as a condition to do business with any company within our Group.
If your job involves selecting a supplier, you have to ground the selection decision on merit, quality and reputation, running therequired screening, irrespective of the size of the candidates.

III.4 Fair competition
We carry out our business fairly and legally. A market will only know a healthy growth if ﬁrms act based on unrestricted competition
and therefore we shall refrain from any anti-competitive behaviours or practices. We will not engage in anti-competitive activities
either with or against our business partners (customers, suppliers) or our competitors. We shall always use only lawful means(public or permitted sources) of obtaining competitive information, and always comply with antitrust and competition laws. We
shall never enter into any agreements or arrangements, irrespective if in writing or verbal, formal or informal, related to any of thefollowing topics:-

setting resale prices
coordination of bids, allocation of customers, sales territories or product lines
engagement in any other activity that violates applicable law

Activities that even appear to violate antitrust or competition laws must be avoided. For example, our written communication
related to our business or competitors should be appropriate in tone and refrain from language that could be interpreted as
encouraging anti-competitive behaviour or disparaging third parties.
Violations of antitrust or competition law may result in signiﬁcant legal penalties for the company and criminal charges for theindividuals involved. Given the complexity of the competition law, you should discuss with the Legal Department in case you havequestions or concerns regarding a potential competition issue.

5

Code of Conduct ■ SECTION III

III.5 Bribery and Corruption
The Group has a zero tolerance stance on bribery and corruption. It is not permitted for any employee or representative of ours to
give, offer or receive, from or to a private person, a private entity or a government ofﬁcial, a bribe or other improper advantage, forbusiness or ﬁnancial gain. Thus, you should never offer or receive, directly or indirectly through a third party, anything of value toimproperly obtain or retain business, inﬂuence business decisions or secure an unfair business advantage. Anything of value
includes not only cash, but also gifts, hospitality (travel, meals and entertainment), donations and sponsorships, or anything elsethat could be valuable to a recipient or to you. You also may not make facilitating payments to government ofﬁcials.
As gifts and entertainment given or received to unfairly inﬂuence business can result in ﬁnes and other penalties for the company
and the employee, such gifts and entertainment, including sponsorships and donations must be provided in accordance with therequirements of the Anti-Bribery Compliance Policy. Make sure that you read the said policy, in order to be able to identify andavoid the various forms of corruption.
Except for few carefully identiﬁed exemptions in the Anti-Bribery Compliance Policy, you must obtain written pre-approval before
giving anything of value to government ofﬁcials. All payments and other value made to government ofﬁcials, both directly andindirectly through a third party, must be accurately and transparently recorded in our books and records. If you have questions or
are unsure of the appropriate approach of a matter, you should contact the Compliance & Ethics Ofﬁcer or the Law Department.
You must promptly report any suspected bribery, demands for a bribe, or the actual payment of a bribe made under bullying
directly to the Law Department or the Compliance & Ethics ofﬁcer, or through the Speak Up Point of Contact. Terms such as„facilitating payment”, “government ofﬁcial”, “bribe” and “anything of value” are deﬁned in the Anti-Bribery Compliance Policy.

III.6 Business Gifts
The practice of exchanging business courtesies, such as gifts and entertainment, when used appropriately, helps strengthen
existing relationships and encourage new opportunities. However, if wrongly done, the business courtesies may trigger
anti-corruption laws, if they can be characterized as bribery. For this reason, before you exchange any gift, you must ensure it is notintended to inﬂuence a speciﬁc business decision, is without risk of reputational harm and permitted under our policies and thegiver’s/receiver’s policies.
Special attention should be paid to gifts or entertainment to government ofﬁcials. In this case prior written approval should beobtained from the functions indicated in our Business Gifts Policy before giving or offering any gift to such government ofﬁcial.
Please look for more details in our Business Gifts Policy.

III.7 Money Laundering and International Trade Controls
Any customer or supplier ﬁnancial transactions for the purposes of money laundering is illegal. The money laundering activity is
any process by which persons or groups try to conceal the proceeds of illegal activities or try to make the sources of their illegal
funds look legitimate. You should be careful and act prudently if you are requested to make payments in cash beyond the legal
limit or from a non-business account, or other unusual payment terms.
By virtue of PepsiCo being a shareholder in one of our companies, our Group may become the subject of various international tradelaws as well, which means that certain international trade restrictions might apply, such as embargoes or legal economic sanctions.
In case of any uncertainties, you can consult with the Law Department.

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Code of Conduct ■ SECTION III

■ SECTION IV
THE CODE IN THE BUSINESS

IV.1 Maintaining Accurate Business Record
A.

Records Retention

Each of us is responsible with ensuring that the records in his/her custody are maintained, stored and destroyed in accordance withthe applicable legal and regulatory record keeping rules. For this purpose, you must know what records, how and for how long theyneed to be maintained and stored and when to be destroyed. You should consult the Law Department if you have speciﬁcquestions about such procedures.
B.

Financial Accuracy

Doing business with integrity also means that you are accountable for the accuracy and honesty of the business records, contracts
and agreements that you handle in the normal course of business. The information should not be falsiﬁed, omitted, altered illicitly
or hidden in the company’s records.
C.

Financial Disclosures and Audits

If reporting on our business is part of your responsibility, then you must make full, fair, accurate, timely and clear disclosures in thereport subjected to communication to certain authorities. It is also your obligation to fully and openly cooperate with auditors
and/or investigators in connection with any corporate or external audit or review of the company’s books and records.
Practices such as those listed below are forbidden:-

misstating ﬁnancial information in our company’s books and records
altering manufacturing numbers to meet productivity goals
signing any side letter or any other document that modiﬁes or interprets an existing customer agreement
without the prior review and approval of the Law Department
presenting false medical information to obtain disability beneﬁts
falsely reporting time worked to earn more pay or to avoid discipline for being late or absent from work.

IV.2 Privacy
It is highly probable that due to your function in the company, you come across personal data of your co-workers or collaborators –individuals of the company or other individuals that are employees or representatives of our suppliers or customers or other type ofcollaborators of ours. Personal data* broadly means any information either by itself or in combination with other information thatcan directly or indirectly be used to identify a natural person. If you come across such data, you must act responsibly and inaccordance with the applicable laws and internal rules and policies regarding the processing of personal data.
You main obligations are:-to only process personal data that you need and are authorized to handle for legitimate business reasons
to disclose personal data only to authorized persons who have a legitimate business reason to know the
information and who are obligated to protect it
to securely store, transmit and destroy personal data in accordance with applicable policies and laws
to promptly report any actual or suspected violations of our policies, actual or potential data breaches, or otherrisks to personal data to your local Law Department or through Speak Up.

*Examples of personal data include, but are not limited to, names, identiﬁcation numbers, email addresses, individual phone
numbers, photos, IP addresses, device ID, or location data.

IV.3 Proper Use and Protection of Company Resources
The company resources, be it tangible (such as physical property, ﬁnancial resources and electronic assets) or intangible (such as
intellectual property and conﬁdential information) are dedicated to better serve our consumers and customers, operate
proﬁtably, and create value for our shareholders and other stakeholders.

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Code of Conduct ■ SECTION IV

A.

PHYSICAL PROPERTY AND FINANCIAL RESOURCES

You must use responsibly the Group’s resources and property that was entrusted to you to do your job. Company’s property suchas equipment, materials, cars, company cards, should not be used for personal use. Before expending company funds, you must
always:-ensure the funds are properly used for their established purpose
obtain required approval before incurring an expense
accurately record all expendituresverify that expenses submitted for reimbursement are business-related, properly documented and comply
with company’s policies

B.

ELECTRONIC ASSETSYour use of company’s information technology systems must comply with the company’s policies and internal rules. Incidental
personal use of company’s devices and systems, including phone, email and the internet, is permissible, so long as such usage does
not:-extend beyond what is reasonable and occasional.
interfere with your work performance or that of others.
involve illegal, sexually explicit, political, discriminatory or otherwise inappropriate material.
relate to outside business interests.
introduce malicious malware into company’s information resources through external devices or downloading
unauthorized material.
violate this Code or any company policy or internal rules.

You should not have an expectation of privacy regarding the use of company’s information resources. Any information you create,share or download onto company systems belongs to the company. The company, as your employer, reserves the right to monitor,
record, disclose, audit and delete without prior notice the nature and content of its employee’s activity using the company’s email,phone, voicemail, internet and other systems, to the extent permitted by local law.
Also, you must ensure that all third parties you engage or work with that provide for access to any company information, systems
or other information services also adhere to and uphold the company’s security policies, rules and requirements.
If you suspect a security-related incident or data breach, or become aware of any situation in which data has been compromised,
including the loss or theft of a laptop or handheld device or malware infection, immediately report the situation to your supervisor
or local technical support team.

C.

INTELLECTUAL PROPERTY

Much of the company’s reputation stays in the force of its brands, its intellectual property, which, it is rightfully to be said that, is aninvaluable asset built over years of hard work and must be protected at all times. Intellectual property includes our trademarks,
brands, domain names, social media accounts, package designs, logos, copyrights, inventions, patents and trade secrets.
You should never allow a third party to use, or allow others to use, our trademarks or other intellectual property without proper
authorization and a license agreement that has been approved by the Law Department. Our trademarks should never be used ina degrading, defamatory or otherwise offensive manner.
Our intellectual property also includes employees’ work product. As a company employee, any work you create, in whole or in part,in connection with your duties, and/or using company time, resources or information, belongs to your employer.
For example, inventions, ideas, discoveries, improvements, artwork, processes, designs, software, or any other materials you may
help to create or author in connection with your work for our company belong to the company to the extent permitted by law.
Domain names and social media accounts that include company’s trademarks or other intellectual property must always beregistered in the name of the appropriate Group company entity through authorized IT contacts and never in the name of anindividual employee or external consultant or agency. You should promptly disclose any invention or creative work related to ourbusiness, so that it may receive the same protection as other intellectual property of our company.

D.

Protecting Group Information

Much of the information used within any company in the Group is considered and must be treated as conﬁdential information.

8

Code of Conduct ■ SECTION IV

You must always take reasonable and necessary precautions to protect information relating to company, your coworkers,
company’s customers, suppliers, business partners, and other third parties that is conﬁdential, competitively sensitive and/or
proprietary. You must assume that company information should be protected unless you have clear indication that the company
has publicly released the information and/or that the information is classiﬁed as public.
The company’s conﬁdential information should never be disclosed to anyonei.
ii.

inside the company, if such disclosure is not necessary in alignment with the recipient’s job description (e.g. accesson a need-to-know basis) and right of access to such information; OR
outside the company.

Disclosure of conﬁdential information is solely permitted if it is:-properly authorizedin connection with a clearly deﬁned, legitimate business needsubject to a written conﬁdentiality agreement approved by the Law Department.

Remember that you have to safeguard electronic information in your possession, including when outside of the company’s system
when using non-company laptops, mobile devices and/or a remote network connection.

IV.4 Conﬂicts of Interest
Conﬂict or appearance of conﬂict between your personal interests and the company’s interests should be avoided at all times. A
conﬂict of interest might affect your ability to make objective business decisions, especially when personal relationships, outside
employment or investments are involved. Conﬂicts of interest may arise when you:-engage in activities that compete, or appear to compete, with our company’s interests.
let your business decisions be, or appear to be, inﬂuenced by personal or family interests or friendships.
use company business opportunity, property, information or resources for personal beneﬁt or the beneﬁt of others.
hire, supervise or have a direct or indirect line of reporting to a family member, romantic partner or close friend,or have the ability to inﬂuence that person’s employment opportunities or compensation.
have outside activities or employment that negatively affects your job performance or interferes with yourcompany responsibilities.
work for, provide services to, have a ﬁnancial interest in or receive any personal beneﬁt from a current or potential
supplier, customer, or competitor or have a family member who does. In general, it will not pose a conﬂict ofinterest if a nominal stock ownership interest (generally, less than a 1% equity interest) is owned by you or a family member.

The existence of a conﬂict of interests does not necessarily mean that there is an infringement of this Code, but failing to disclosesuch conﬂict is an infringement.
You must promptly disclose an actual or potential conﬂict of interest to our company when it arises by contacting Compliance &Ethics Ofﬁcer. This allows the company to advise you on how to best avoid the conﬂict and what action you need to take, if any.
If you ﬁnd yourself in a situation where you don’t know if you have a conﬂict of interests, you can ask yourself one of the following
questions, and if the answer is yes to either of them, then you have a potential conﬂict that should be disclosed:-

Do my outside interests inﬂuence, or appear to inﬂuence, my ability to make sound business decisions?
Do I stand to personally beneﬁt, or appear to beneﬁt, from my involvement in this situation? Does a friend or
relative of mine stand to beneﬁt or appear to beneﬁt?
Could my participation in this activity interfere, or appear to interfere, with my ability to do my job?
Is the situation causing me to put my own interests ahead of company’s interests? Does it appear to?
If the situation became public knowledge, would I be embarrassed? Would it embarrass the company?

IV.5 Communicating with the publicA.

Public speaking and press inquiries

Speaking on behalf of the company in public is solely allowed with prior authorization and according to the received instructions.
No company employee is permitted to agree to an interview or external speaking engagement, business or personal, in which ourcompany will be discussed or referenced, or publish any video or written content related to any company in the Group, without the
support and approval of the Communication & PR Department. You must also have authorization, based on a clear businessrationale, from your direct manager and/or the most senior person on your team. If you are contacted and asked to discuss company business with members of the press, investors or market analysts, do not provide any information. Instead, you should refer themto Communication & PR Department.

9

Code of Conduct ■ SECTION IV

B.

Social Media

Whilst being a member of the social media is encouraged, it is worth drawing attention on the fact that posting to social media
channels can trigger unintended consequences that could impact both you and the company, if you’ve identiﬁed yourself as aGroup employee and/or are using your company equipment or systems. For this reason, the rule of refraining to talk on behalf ofthe company is also applicable in this case.
Moreover, if you identify yourself on any of these channels as company employee, you must act diligently and comply with the
instructions from the Communication & PR Department, that is:-

Do not misrepresent yourself or the company or speak on behalf of the company
Never disclose any personal information about employees, consumers, visitors or online followers, or
proprietary or conﬁdential information about company or its business partners
Avoid harassing, defamatory or disparaging content, and be sensitive to global cultures. Remember thatinternet content can live forever

Examples of infringing actions:-

Posting photos from company facilities that may inadvertently reveal proprietary information or violate theprivacy of co-workers
Posting a picture of a private celebrity or business executive visit to company
Posting information about a company product or campaign before it is ofﬁcially released
Unauthorized speaking on behalf of company on social media channels■ CONTACTS

compliance.ethics@valvis-holding.com

aquacarpatica.com/compliance-form

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Code of Conduct ■ SECTION IV