A commitment to our global team...

CODE OF CONDUCT

www.thor.com

OUR WORLDWIDE CODE OF CONDUCT

UK
Spain

USA

FranceGermany

Italy

Japan
China

MexicoMalaysiaBrazilSouth Africa

Australia

TABLE OF CONTENTS
A message from Giuseppe De Lucia

04
04

It’s Our Code

05
05
06
06

Our workplace

08
08
09
10
11

• Our values• Our Code of Conduct• Asking for advice• SpeakUP• Health, safety and the environment• Dignity and respect• Drugs and alcohol• Quality

Honesty and integrity

11
11
12
13
14
14
15
15
16

Safeguarding our assets

17
17
18
20
21
22

• Bribery and corruption• Gifts and hospitality• Conflicts of interest• Respecting human rights• Modern slavery• Fair competition• Trade controls• Accurate records• Use of information technology• Social media• External communications• Confidential information• Data privacy

www.thor.com

A message from Giuseppe De Lucia

Being part of Thor is being part of an incredible global team that has made this organisation the success that it is. I’m proud
to be part of the team at this important point in our journey.
We make a difference to the world at large. We provide products thatare used to keep people safe, looking good and feeling great.
We’re trusted to deliver and that trust is integral to everything we do.
We must stay focussed on maintaining that trust and acting at all times
with integrity.
Our Code of Conduct is our guide to how we conduct business, bothinternally and customer facing. It guides us and ensures we act withintegrity and hold ourselves to the highest standards of responsible andethical behaviour. Our Board of Directors will review the Code of
Conduct annually to ensure that it remains fit for the purpose ofmaintaining our philosophies and values.
I ask you to make sure you read, understand and adhere to the Codeof Conduct. As part of the Thor team we all have a part to play inmaking sure we always look after our fellow team members, provide
our customers with quality products and do the right thing.

“I’m proud to say that I’mpart of the Thor family and
I understand and uphold
the Code.”
GIUSEPPE DE LUCIA
Main Board Director
04

Our values

TRUST

We work as a team
We earn trust from our employee family, customers and business
partners with our competency, integrity and ability to succeed.
HONESTY

We deliver on our promises
We always operate honestly and ethically in everything we doand with everyone with whom we connect.
OPTIMISM

We believe in our future
We see opportunity where others see problems and we use
these opportunities in our quest for success.
RESPECTWe treat everyone with dignity and respect
We believe that everyone should enjoy an environment freefrom discrimination and harassment.

It’s Our Code

Our Code of Conduct

What is the Code of Conduct?

The Thor Code of Conduct (our Code) outlines ourcommitment to and gives guidance on how we dobusiness regarding standards of integrity and ethics. It
describes the basic rules of conduct that we are expected
to follow. The Code also assists us in applying these rules
and policies in practice by giving us guidance on actions
and behaviours that match our company values.

Who has to follow the Code of Conduct?

The Code applies to everyone doing Thor business.
This is wide ranging and includes all of Thor’s businesses, divisions and offices. It also
applies across all jurisdictions where the organisation operates. It applies to all
employees (whether temporary, fixed-term, permanent, paid or unpaid) and all Officers,
Trustees, Board and/or Committee members at any level.
If the code says we, us, our, you or I; you should interpret this as meaning that it
applies to everyone at Thor.
Thor has also made a commitment to do business only with others who share ourvalues and undertake their business with the highest standards of integrity and ethics.

What are our obligations?

Acting with integrity and undertaking business ethically is a requirement of working
at Thor. We are all expected to read, understand and follow the Code. All existing
employees are asked to sign-up to the Code, demonstrating that they understand it
and will follow it acting with integrity at all times. New employees will be asked tosign-up at the very start of their journey with Thor when accepting their contractof employment.
The Code acts as our guide for business conduct. It is written to give us guidanceand support to assist us in making the correct decisions to act ethically and incompliance with the laws that affect us. We are a global organisation and subject to avast number of laws, regulations and situations in our daily business lives. This means
the Code cannot cover everything - it is your responsibility to learn about any
additional requirements that may apply to you.

If you are in any doubt you shouldseek guidance from your local
Human Resources Manager or
Global Compliance.

What happens if the Code of
Conduct is breached?

Not following the Code can haveserious consequences for us asindividuals and for Thor as anorganisation.
Breaching the Code may lead to
disciplinary action, up to andincluding termination, in line with local
guidelines and regulations.

ask yourself...
SO, before you act,...does it feelright?

...is it legal?

...does it meetthe requirementsof the Code of
Conduct?

...is it fair to allconcerned?

...would I feel OK
if someone elseknew about it?

If you can’t answer yes to all of these then you need to stop and think again.
It’s always OK to ask for help.
05

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SAFET

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WAST
Asking for advice

You may face difficult
situations in yourwork.
Our Code and yourgood judgement may
be enough to guideyou in the correct
actions to be taken.
However sometimes
you may need help
to make the correct
decisions.
You should speak in
the first instancewith your manager
and if you needfurther help you canspeak with your
HR Team or Global
Compliance.

V
EN

NT
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NM
O
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ICT

SpeakUFL
CON

When should I...

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06

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If you see something that you suspect is unethical, illegal or contrary
to our values and the Code you should speak up. It may seem theeasy option to look the other way - but not living up to goodbusiness and personal practices affects all of us.

UP

Remember no concern is too minor to report.

How do I speak up?

If you feel you are in a position to challenge the behaviour you should do soappropriately.
If you feel you are not in a position to challenge the behaviour yourself,
your manager will usually be the best person to listen to your concerns
and take the necessary action. If you feel unable to speak with yourmanager you can approach your HR Team or another member ofsenior management.
It’s not always going to be easy to raise your concern with someone
within the organisation. In these circumstances we should reportconcerns to SpeakUP, the ethics and compliance hotline. This is a service run by anindependent third party which is available 24/7 in all countries where we haveoperations.
SpeakUP allows anonymous reporting. We would ask though that you give yourdetails if you feel you are able to allow us to complete a full investigation.

Anti-retaliation

It takes courage to raise your concern, but you should feel safe to do so. Retaliation for
asking questions, making a good faith report or participating in an investigation will not
be tolerated regardless of whether the concern turns out to be unfounded or not.

What does Good Faith mean?

A good faith report is a concern that you genuinely believed to be correct. It does notmatter if the report is subsequently found to be unfounded as long as all truthful
information was given at the time to aid in the investigation.

What happens when I make a report to the SpeakUP Hotline?

You may leave a phone or web report with your concern; both of these can beanonymous if you prefer. You will be given a case number for your concern and thisis the reference number for you to check back on the status of your report.
Once received, details of your report are passed to the company Global ComplianceDepartment who will then ensure that the report is investigated in the mostappropriate way.
All reports are taken very seriously and you can be assured that processes are inplace to ensure they are handled correctly.
The SpeakUP programme is reviewed regularly by the Board of Directors, thisincludes reports, investigations and results of these investigations.

SpeakUPHotline
www.thorspeakup.com

Or use the free phone number for your location.
This can be found in the Thor Whistleblowing Policy07

Our workplace

Health, Safety and the Environment
What do we mean?

Good management of our health, safety and environmental performanceis integral to our success, it’s how we operate each and every day.

What do we believe?

We believe in and are committed to looking after the health and safetyof all employees, visitors and others who may be impacted by ouroperations. We are also committed to conducting our business in anenvironmentally responsible manner.
Our aim is to meet or exceed compliance with all health, safety andenvironmental laws and regulations.

Staying safe and a good environmental ambassador

We always follow our health, safety and environmental policies andprocedures. We also ensure that operations are carried out in compliancewith local health, safety and environmental laws and regulations.
We look out for our fellow workers and others who may be impacted
by unsafe conditions or acts. We take care of the environment and makesure that our environmental impact is controlled.

What if I see something wrong?

If we see something that could put us, others or the environment at
risk we don’t walk past or ignore it - we take action. At all times, we takean active part keeping ourselves, others and the environment safe.
We all need to take an active part in managing the health, safety andenvironmental risks of the company.
We make sure:• If PPE is required, we wear it and treat it as if it’s our own.
• If a procedure needs to be followed to keep us safe, we follow it.
• If training is required, we complete it.
• If it doesn’t look right, we take action or we report it.
08

Scenario:
Q: Maria has a small quantity of hazardous waste to dispose of. The
disposal area is a long walk and it’s raining. She knows it’s unlikely tocause a problem if she puts it down the rain water drain because rainwater will dilute it. Is it ok for Maria to dispose of the wastethat way?
A: No it’s not OK. Maria needs to follow the onsite hazardous waste
disposal procedures every time. As well as taking her personal
obligations seriously, she should be aware that the site is likely tohave strict permit requirements that disposing of waste in this way
will breach.
Q: Trevor works in an area that has a mandatory safety glasses

requirement. His prescription safety glasses got broken yesterday,
he reported it and HSE have ordered him a new pair. He knows he
can’t work without eye protection. What should Trevor do today?
A: Trevor should ask his Health and Safety Manager what alternatives
he can use. These might include over glasses (so he can wear his
normal specs underneath), goggles or a visor.

Dignity and Respect

Respect and responsibility

What do we believe?

We believe in an inclusive and diverse workplace where everyone connectedwith us is treated with dignity and respect.

Diversity and inclusion

We always treat everyone we connect with fairly regardless of their personal
beliefs or differences. Selection should be based solely on merit with everyone
having the same opportunities regardless of their personal beliefs ordifferences.

Harassment

We never bully or harass anyone. This means we will never violate anindividual’s dignity or create an intimidating, hostile, degrading, humiliating or
offensive environment for that individual.
We should remember that bullying and harassment can be physical, verbal
or written. It can include words, pictures or statements. It can be transmitted
by post, phone, fax, video, text message, email, a screen saver or via social
media etc.

personal care ingredients

In all communications whether face to face, virtual or written we must always
be respectful. In line with our company values we should always be open andhonest.
Scenario:
Q: Jon has an open position in his department. He asks HR to send him only
CVs for people under 40 as he thinks older workers are too slow to pick up theskills he needs them to have. Is it OK for Jon to do that?
A: No. It’s never OK to discriminate and Jon is violating company policy and theCode of Conduct. Age is also a legally protected characteristic, HR needs to give
Jon some further guidance.
We celebrate Thor as a place of diversity and inclusion and we don’t discriminate
or harass anyone based on their personal beliefs or difference.
This could include:• Age.
• Disability.
• Gender reassignment and gender identity.
• National origin.
• Sex or sexual orientation.
• Marital or civil partnership status.
• Family status including pregnancy, maternity, paternity or other carer status.
• Race including ethnic origin.
• Genetic information.
• Religious, political or other beliefs.
• Full-time or part-time status.
Related Group policies:• Thor Anti-Discrimination and Anti-Harassment Policy

09

Drugs and alcohol
What do we believe?

Alcohol and substance abuse limit our ability to do our jobs safely andefficiently which puts us all at risk.
We should report fit for duty at all times.

What are my responsibilities?

We must never be under the influence of alcohol, illegal drugs
or a lawfully prescribed prescription drug which affects our
performance or creates a risk to safety whilst at work or
undertaking work for the company.
We must never undertake the unlawful use, purchase, sale,possession, distribution, transfer, or manufacture of alcohol(this includes legal manufacture except when associated withcompany business), illegal drugs or controlled substances,while on company property, while operating company
machinery or vehicles, or while conducting company
business.
Scenario:

Q: David’s co-worker Trev drives the FLT in the area where theywork. Often after lunch David can smell alcohol on Trev’s breathand he has seen him driving erratically. What should David do?
A: David should report the matter to his line manager or the HR
Department. If David doesn’t feel he can speak to someone
directly, he could use the SpeakUP Hotline. If someone is under
the influence of alcohol at work they put all of us in danger.
Related Group policies:• Thor Drug and Alcohol Policy

10Quality

What do we believe?

We’ve built our reputation and our business on excellent customer service andproviding quality products that meet or even exceed what our customers require.
We believe that everything we produce should be to the best possible quality
and meet all the requirements of applicable laws and regulations.

Honesty and Integrity
Bribery and Corruption
What does it mean?

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving,
accepting, or soliciting something of value or of advantage so to induce or influencean action or decision.

What do we believe?

We believe that our business should be conducted at all times with the highest
standards of integrity and honesty. We do not allow others who act for us to breachany of the requirements that we ourselves must comply with.

Bribery and corruption

We never engage in bribery or corruption in any form. We do not give, offer or
receive anything that could be considered a bribe.

Facilitation and grease payments

Working to ensure that we produce quality products

We always comply with quality control standards, procedures and customer
agreed specifications. In addition to making sure we ourselves produce quality
products and services we make sure our suppliers and others who supply us
products and services meet the same high standards.
We always report any non-conformance with quality standards to line
management and ensure that correct action is taken.
Scenario:o
Q: Mo knows that if he heats a product mix 5 C degrees higher than the internal
quality procedure requires, he can make the final mix quicker and produce
more batches in his shift. Is it OK for him to do that?
A: No. Mo must follow the quality procedure to ensure that the product is
produced to the expected standard. The company is always looking to improve
so Mo should then feel free to speak with his line manager to make thesuggestion, which may then be investigated fully.

We do not make facilitation or grease payments to grant an advantage or facilitatean action to which we are otherwise legally entitled.

Political and charitable donations

We do not make donations, in cash, kind, or by any other means, to support any
political parties or candidates. It is recognised this may be perceived as an attempt togain an improper business advantage. We only make charitable donations where we arecertain that the donation is fit and proper and cannot be viewed as an influencing
behaviour. We must seek approval of Global Compliance before any donation is made.
Scenario:
Q: Susan is at a customer negotiating the price of goods we are going to supply.
At the start of the meeting the customer gives Susan a pen to use during themeeting and to keep as a personal memento. Is it OK for Susan to keep the pen
as a gift?
A: If the pen was of nominal value and not intended to influence Susan, then yes.
Related Group policies:• Thor Anti-Bribery and Corruption Policy
11Gifts and hospitality
What does it mean?

The exchange of legitimate gifts and hospitality that build goodwill inbusiness relationships.

What do we believe?

We believe that gifts and hospitality providing they are not excessive
and are appropriate to the circumstances can be an acceptable partof business relationships.

Gift and Hospitality

We never give, offer or receive a gift or hospitality if the act of
doing so may be seen to influence.

Gifts and hospitality can be an acceptable part of business.
However, we know if giving or receiving we should ensure:• It is not done with the intention of influencing the party to whom
it is being given.
• It is not made with the suggestion that a return favour is expected.
• It is in compliance with international and local law.
• It is given in the name of the company, not in an individual’s name.
• It does not include cash or a cash equivalent eg: a voucher or gift
certificate.
• It is of an appropriate type and value and given at an appropriate
time, taking into account the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with
the intention of directly influencing them.

ACTICIDE¤ Biocides...
Related Group policies:• Thor Anti-Bribery and Corruption Policy

12Conflicts of Interest
What does it mean?

When employees’ personal interests either influence, have the potential toinfluence, or are perceived to influence their decision making, a conflict of interest
situation results.

What do we believe?

We always try to avoid conflicts of interest or any situation that may beperceived as a conflict of interest.
Where we feel it cannot be avoided we report the situation promptly to ourline manager and Global Compliance.

Working to avoid Conflicts of Interest

We discuss any potential conflicts of interest openly and honestly with our line
manager. We agree and abide by a workable plan to manage the situation.

Scenario:

Q: Peter works in the Purchasing Department and would like to place an orderfor chemicals to use in his Thor site. Peter thinks that a company his brotherworks for as a sales manager is the best place to purchase these chemicals.
Is it ok for Peter to place the order with Rob his brother?
A: Peter should let his line manager know and then remove himself from any
negotiations in relation to the order. The order should then follow the normalpurchasing procedure with no input from Peter.

Being able to recognise a potential conflict can help you avoid one.
A conflict of interest can occur in the following situations:• Personal workplace relationships eg: hiring or supervising a closely related
person.
• Outside employment eg: having a second job which has the potential toprevent you from fulfilling your duties to the organisation.
• Ownership or financial interest of an external organisation eg: owning a shareof a supplier while in a position to steer Thor business towards it.
• Using company equipment or means to support an external businesseg: using the company van to deliver your personal goods.
• Relationship with a supplier or customer eg: you have a family member who
is at a level in the organisation that may give the appearance that it could
affect your judgment, decisions, or actions in your dealings.
• External mandates eg: serving on the board of directors of another company.
Related Group policies:• Thor Conflict of Interest Policy
13Modern Slavery

What does it mean?

Modern slavery encompasses human trafficking and slavery, servitudeand forced or compulsory labour.

What do we believe?

We believe that nobody should be subject to modern slavery andwe will not tolerate it in any business connection with thecompany. We will not knowingly do business with any
party that is involved in modern slavery.

Respecting Human Rights
What does it mean?

Treating everyone with dignity and respect and allowing freedoms thatare expected in a modern society.

What do we believe?

We respect fundamental human rights and are committed to theprinciples set out in the United Nations Universal Declaration of
Human Rights.

We abide by local employment law wherever we operate. All suppliers
and business partners associated with the company are required tocomply with these same standards.

What are my responsibilities?

We abide by all local laws relating to employment terms and treat
everyone with respect and dignity.
When dealing with suppliers and other business partners we expect
them to uphold these same principles.

What are my responsibilities?

We abide by international conventions and laws relating to modern
slavery. We keep aware of our own work environment and that of ourbusiness partners to ensure that the company remains in compliancewith its commitment to not knowingly engage in modern slavery.
Modern Slavery - Key Points:• Modern slavery encompasses human trafficking and slavery,
servitude and forced or compulsory labour.
• Human trafficking consists of three basic components: action,means and purpose of exploitation. All three components must bepresent in an adult trafficking case; for child trafficking the ‘means’component is not required.
• In human trafficking cases, exploitation can take many forms,
including: sexual exploitation, forced labour, slavery, servitude,
forced criminality and removal of organs.
• Some people may not be victims of human trafficking but still
victims of modern slavery if they have been subject to slavery,
servitude and forced or compulsory labour.
• Human trafficking is not the same as human smuggling. There arecommon myths about modern slavery, such as misconceptions
that UK nationals cannot be victims and that a person cannot bea victim if they reject offers of help.

UK Home Office, Statutory Guidance

14

FAIR Competition
What do we believe?

We believe that our business should compete in a lawful, fair, and ethical manner.

We always compete for and do business solely on the basis of merit and open
competition.

Dealing with customers• We must comply with Thor anti-trust and competition policy and international
and local laws relating to antitrust and competition.
• We must always deal fairly with everyone we come in to contact with or havea connection with as part of our business dealings; this includes our customers,
suppliers and competitors.

We deal fairly with our customers. We deal only in facts and are truthful when
we discuss our product quality, purpose and availability.
We do not engage in tying of products by making acustomer purchase one product to be allowed to purchaseanother.

Related Group policies:• Thor Anti-Trust and Competition Policy

We do not engage with competitors to fix prices, undertake bid
rigging, market allocation, control production or any other competition
restricting action.
Likewise, we do not discuss our business and how we undertake that businesswith our competitors.

When exporting or importing
goods or services we are subject
to local and international laws.
These laws dictate if and when
we can export or import,
and what permissions etc.
we require.

Trade
Controls

Dealing with competitors

Market information

We gain market intelligence in accordance with the law, through legal means.
We never use deception or confidential information for competitive
advantage.
Scenario:
Q: Callum, the Sales Director in one of our divisions, goes to lunch with his
friend who is the Sales Director of a competitor selling the same products
as Callum. Callum’s friend suggests that if he lets him deal exclusively withcompany A, he will let him deal exclusively with company B. This is a great
opportunity to concentrate his limited resources. What should Callum do?
A: Callum should stop his friend from discussing it immediately and let him
know that Thor doesn’t do business this way. In addition, he should inform
his local management and Global Compliance of the discussion. In short,he should not take up the offer in any way.

What do we mean?

What do we believe?

We believe that all of our business operations should comply with applicable
local and international trade law.

What are my responsibilities?

We understand that there are specific requirements for the export and import ofgoods and services between countries and that these may restrict the way we dobusiness.
We make sure that if involved in the import or export of goods or services thatthese are done in compliance with international trade law.
We make sure that when exporting we know of our product’s final destinationand its intended use. We do not participate in shipping our products throughone country to allow shipment to another if the shipment to either is againstinternational trade laws.
15

Accurate Records
What do we mean?

Business records are used to make public disclosures and provide
information for production processes, customers, regulators andothers. The company also makes important business decisions basedon these records.

What do we believe?

We are trusted to keep accurate records of everything we do.
We have a duty to ensure that information we gather and record isaccurate, correctly recorded and retained.

What are my responsibilities?

We ensure that any records we are required to make are accurate
and contain all necessary information. We are honest in what werecord and do not hide or omit information to alter the recording
process.
We do not dispose of records that are required to be retained or
dispose of records that are or may be called for in any regulatory
process.
16

Scenario:
Q: Lise works in sales and wants to show progress in her weekly
order volumes. It’s the last day of her reporting week and she
has just received a commitment of an order that will be placed
the next day. Can she record it in the report she is about tosubmit?
A: No. She can’t record this as a sale as there is no order as yet.
All information must accurately reflect what is to be recordedin the report.

We ensure that any records we are required to make are accurate
and contain all necessary information.
These can include (but are not limited to):• Financial records• Permit records• Environmental monitoring records• Health and safety records• Expense reports• Production/quality records• Shipping records• Stock records• Export and import records• Customer records• Supplier records• Facility records

Safeguarding Our Assets

Use of Company Information Technology
What does it mean?

Information technology - includes all computer devices including mobile
devices, computer networks, computer information management services
including cloud computing, system software, application software, mobile phones,
removable storage media and emerging technologies.

What do we believe?

We aim to provide up to date information technology that promotes
collaboration and innovation and enhances our customer’s experience.
We believe that everyone should use these assets responsibly.

Business use

We always follow all security measures for our information technology assets,
this includes using only IT approved software, locking devices when not in use,password protecting removable media devices and never disclosing our passwords
to unauthorised persons.
We never use our information technology assets in circumstances that are against
the law or good business ethics.

Personal use

We will not allow personal use of computer information technology to interferewith our work (or anyone elses), or use it in circumstances that are against thelaw or good business ethics.

We shouldn’t be using company information technology assets in the following ways:• For personal gain or that of another person or organisation.
• Accessing, downloading or sending inappropriate, sexually explicit, illegal or
offensive material.
• Undertaking any activity that may be contrary to the Thor Anti-Discrimination
and Anti-Harassment Policy.
• Downloading or using unlicensed software.
• Downloading of any licensed software without local IT Team supervision.
• Using information technology and/or associated products in non-compliancewith applicable licensing, copyright, notices, contracts, agreements, regulations,sanctions or trade control laws.
• Duplicating, publishing or distributing copyrighted materials to which you haveno right. This may include (but is not limited to), downloading songs, photographs
and videos.
• Disclosing confidential information to those not authorised to receive it.
• Using an organisation email address to register on websites that are not connectedwith the organisation eg: social media, online auction, gambling or similar websites.
• Gambling.
Related Group policies:• Thor Information Technology Use Policy

Scenario:
Q: Kris finds a joke online that he thinks is funny, but he knows it’s racist. Kris
knows Bill in accounts will find it funny. Is it OK for Kris to forward it on?
A: No it’s not OK. Kris should not hold this on his computer or forward it
on to anyone. In addition, Kris should be sure that he is not breaking
company policy by accessing inappropriate material from company
information technology.

17

Social Media

What does it mean?

Social media - consists of web-based communication tools such as
websites and applications that enable users to create and share
information or to participate in social networking.

What do we believe?

We believe in the right of every individual to use social media forprivate purposes. At the same time it is important that employees andothers associated with the organisation understand the implications of
online communication that references the company or something
associated with it.

Business use

We are only allowed to post to social media using a Thor account if
we are authorised to do so. When posting we follow the guidancecontained in the Thor Social Media policy.

Personal use

We never give the impression that our views or opinions are thoseof Thor or that we are a company spokesperson speaking on Thor’s
behalf. We never disclose Thor confidential information and always
remember that what we post can have lasting effects on both
ourselves and others.
Scenario:
Q: Val has been involved in setting up a major new supply
contract with a customer that will bring a lot of additional
revenue and profit to Thor. She’s excited and posts thenews to her personal Facebook account. Should she havedone that?
A: No. Val is right to be excited and can post her feelings to her
personal account. However, she is not authorised to releaseconfidential business information concerning the company.

18

Even posts that we intended to be restricted
to family and friends may end up forwarded- sometimes globally. These posts can then beread by anyone including fellow employees,
management, customers, suppliers,
regulators etc.
When using social media for private purposes,
we should:• Adhere to the Code of Conduct andall other company policies.
• Make it clear that any comment we makeis ours alone, using ‘these are my personalviews’ could be helpful.
• Never post non-public company
information or non-public information
relating to other employees, customers,
suppliers, or anyone or anything connectedwith the organisation.
A good rule is - If in any doubt do not post.
Related Group policies:• Thor Social Media Policy• Thor Information Technology
Use Policy

AFLAMMIT¤
Flame Retardants...

19

External Communications
What does it mean?

We are often contacted for information or comment from external
parties such as regulatory agencies, media organisations or evenindividuals.

What do we believe?

We believe in giving consistent, accurate information when it
is in our business interest or legally required. Incorrect
information or confidential information shared at the wrong
time or to the wrong outlet can have serious implications
for the company.

What are my responsibilities?

We do not disclose confidential business information, givecomments to the media about any aspect of the company
or provide information to any other external parties unless
we are authorised to do so. Authorisation can only begiven by respective Managing Directors or other seniorboard members.
Scenario:

Q: Jay works in the gatehouse and was involved in dealing withan incident on site yesterday where some emergency responders
attended. Today a reporter has turned up at the gatehouse and isasking him questions about what happened. Jay was on the spotyesterday and thinks he is the best person to give the reporterthe information. Is Jay right?
A: No. Unless you are authorised to speak on behalf of the company,
you should not. Jay should take the reporter’s details and informthem that he will pass them on to the correct person; in this casethe Site Manager.

20

Confidential Information
What does it mean?

We have large amounts of confidential information which can come in manydifferent modes. Confidential information can include; patents, copyrights, trade
secrets, engineering plans, business ideas, business plans, customer/supplier lists.
All of these include information we own and information that may be supplied
to us by customers and other business partners.

What do we believe?

We believe that confidential information should remain confidential. When you
protect our confidential information, you protect our assets and our competitive
advantage.

What are my responsibilities?

We do not disclose confidential information unless authorised. We take careof confidential information and are careful where we discuss it, disclose it oraccess it.

Scenario:
Q: Jackie is the sales manager for one of our large accounts. She is at the airport
and receives a telephone call on her mobile from Group Finance who want
immediate information for the CEO on sales forecasts. She is sitting in a busy
airport boarding area and can’t get to a quiet area. What should she do?
A: Regardless of where Jackie is she must first ensure that the person she isspeaking to is someone who is authorised to receive this confidential
information. She should then let them know that she is not in aposition to discuss it at the moment due to the potential of being
overheard. She should not discuss this confidential information
if she is not sure that it is safe to do so without it being
compromised.

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Data Privacy

What does it mean?

We often have access to personal information that could identify anindividual. This may include their name, address, telephone number,email address or other personal data. There are data privacy laws andregulations that govern how this information may be collected, used,shared, stored and disposed of.

What do we believe?

We believe that we should always aim to collect and process
personal data in accordance with applicable laws, regulations and bestpractice. Managing personal data responsibly is fundamental inmaintaining trust.

What are my responsibilities?

We only collect, access, use or disclose personal data for appropriate
business purposes if we are authorised to do so. When we collectpersonal data we only collect what is necessary.
We do not share personal data with anyone who is not authorised
to receive it. In addition, we do not access personal data unless weare authorised to and have a business reason to do so.
At all times we safeguard personal data.
Scenario:
Q: Helen works in HR and has been asked by a supplier for the
personal address of one of the buyers so they can send them abirthday card. Helen has said she can’t do that. Is Helen right?
A: Yes. Helen is correct. Providing this information would be a
violation of data privacy rules and our policy of keeping personal
data private.

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When we deal with personal data we must always:• Inform individuals that we want to collect and use their data.
Always be transparent as to what we will collect and what we willuse it for and never collect what we do not require.
• Ensure that all data held is correct and up to date.
• Access personal data only if we are authorised to do so.
• Never share data with others unless we are authorised to do so
and they are authorised to receive it.
• Keep personal data safe and secure. Any data we release to third
parties must be covered by the same standards contained within
our Code of Conduct.
• Ensure that the transfer of data meets the legal requirements ofthe country where it is being handled. Inter country transfer mustmeet the legal requirements of both the country it is leaving andthe country where it is being sent.
• Meet the legal requirements for retention of data and only keep
data for the purpose for which it was intended and for as long as itis required. Data should always be disposed of correctly.
• Meet the requirements of personal requests for access to data thatis held on an individual in the timescales as set by local legal
requirements.
• Report breaches of data privacy rules contained within the
Code of Conduct or other requirements to our local
HR Management immediately.
Related Group policies:• Thor Information Technology Use Policy

Use this section for any notes or questions you may have...

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06/2020

OUR VALUES
TRUST

We work as a team

HONESTY

We deliver on our promises

OPTIMISM

We believe in our future

RESPECTWe treat everyone with dignity and respect

www.thor.com