Signify Classified - Internal

Procurement Code of Ethics
2021
Procurement employees play an important role in ensuring that Signify and all employees conductbusiness with integrity. Adherence to the Integrity code in the procurement process strengthens
stakeholders’ confidence in Signify. The impact of integrity issues can have a very severe anddisruptive impact on the company, its employees and its businesses.
The Procurement function has implemented a specific Procurement Code of Ethics. The purpose of thiscode is two-fold: it underlines the importance of business integrity to the Procurement function and setsout specific business integrity principles that apply specifically to Procurement employees.
The Procurement Code of Ethics applies to all Procurement employees and is an integral part of theIntegrity code and its supporting policies. It is a function-specific policy that applies in addition to global
Signify policies, such as the Anti-Corruption & Anti-Money Laundering Policy and the Antitrust manual.
This code does not replace any of these policies.
Procurement employees must always comply with the below business integrity principles:

1. Confidential information••

Procurement employees may have access to confidential information that may affect a contract bid
or the business award process, such as selection plans, ranking of bids, proposals, competitors
involved and competitive range determinations.
Confidential information related to quotes and bids from suppliers is not to be shared with anyother supplier or third party at any time. Procurement employees must keep confidential
information from a supplier strictly confidential.

2. Conducting business with honesty and integrity•••

Procurement employees must ensure that contracts are awarded and administered free from any
improper influence.
Circumstances might arise that could call the employee’s impartiality into question, e.g. when hisprocurement duties require him to work with his former employer, spouse’s employer, close
relatives, or others with whom he has an indirect or direct business relationship. When an actual or
potential conflict of interest arises, Procurement employees are obliged to disclose promptly suchactual or potential conflict in accordance with the procedure as laid down in the Conflict of Interest
Policy.
Partners or family members may not receive personal benefits as a result of an employee's positionat Signify.

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3. PROCUREMENT POLICY FOR GIFTS & HOSPITALITY
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The Anti-Corruption & Anti-Money Laundering Policy includes a standard for gifts and hospitality.
Under this global policy, gifts and hospitality can be defined as follows:o A gift concerns anything of value, given willingly as a present to someone.
o Hospitality includes all forms of travel or lodging, meals, invitations to social gatherings,
sports or cultural events and other forms of entertainment and any other cost incurred in
hosting and entertaining a third party
Under the Anti-Corruption & Anti-Money Laundering Policy, Signify functions can implement
additional rules. Procurement has implemented a specific Procurement policy for gifts andhospitality in the form of the following stricter mandatory rules for Procurement employees:o Procurement employees are in principle not allowed to take, accept or promise to accept,
directly or indirectly, any gift from a supplier (representative) or any other third party,
irrespective of the value of the gift or the specific circumstances.
▪ If any gift is being offered in person, a Procurement employee must politely refuse
and instantly return it to the supplier (representative) with a reference to thisProcurement Code of Ethics.
▪ If a gift is being offered in any other way (e.g., by regular mail or e-mail), theProcurement employee must return the gift to the supplier with a copy of theProcurement Code of Ethics letter (see further Paragraph 4 below) attached.
▪ If it is reasonably not possible or impolite to refuse a gift, it should be handed overpromptly after receiving it to the Procurement Compliance Officer, who will
determine an appropriate destination.
o As a main principle, Procurement employees are not allowed to participate in any form of
hospitality offered directly (or indirectly) by suppliers. If they receive any invitation for anoccasion that includes hospitality elements, they must politely refuse and refer to thisProcurement Code of Ethics.
o As a main principle, Procurement employees must pay for their own meals/drinks expenses
and not let suppliers (or other third parties) cover these.
Procurement employees must always comply with all other standards in the Anti-Corruption & AntiMoney Laundering Policy (meaning those standards where this Procurement Code of Ethics does notdeviate from with stricter rules).
If any local laws or regulations apply that are stricter than our internal Signify policies, these laws orregulations must always be followed.

4. Follow a fair process to select suppliers and award business•Procurement employees shall treat suppliers fairly and select suppliers and award business on thebasis of fair competition.

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In all cases, Signify must follow the predefined rules of the procurement processes and share therules upfront with suppliers when applicable.
Arrangements with or among suppliers that could limit or distort competition must be avoided.
Long-term agreements with suppliers must periodically be subject to fair and open competition, toobtain the best current market offering and to provide alternative suppliers with an opportunity to
win the business.
Procurement employees shall not request any payment from suppliers. Suppliers must be selectedon the basis of meeting appropriate selection criteria.
Procurement employees shall not require or encourage suppliers to undertake activities or incur
costs when there is little chance for them obtaining business within a reasonable period - unless thesupplier is made aware of all the circumstances.

5. Select suppliers that comply with ethical standards
Procurement employees must select and award business to suppliers that are committed to acting fairly
and with integrity towards their stakeholders. Suppliers must act with integrity towards stakeholders
and observe both the laws of the countries in which they operate, and the guidelines provided in theSupplier Sustainability Declaration.

6. Report concerns regarding compliance with the Procurement Code of Ethics•Procurement employees must always promptly report to the Procurement Compliance Officer, theEthics Line, or directly to their line manager, any concern about compliance with the Integrity code,
this Procurement Code of Ethics and/or any applicable laws or regulations.

7. Accountability and adherence to the Procurement Code of Ethics•Procurement employees are expected to hold each other accountable for adherence to the Integrity
code and the Procurement Code of Ethics.