Employees
CODE OF BUSINESS CONDUCTI

IIPurpose & Use

O V ER V I E W O F C H A P T ERSE MPL O Y E E S C O D E O F
BUSINESS CONDUCTINTRODUCTION

I.

Purpose Of A Code Of Business Conduct
within your Business Unit (either in Brand,
Region or a Central Function)

II.

Scope Of This Codea.
The purpose of this document is to delineate specific standards of ethical behaviour
in order to respect key business integrity issues. The standards, set forth in thefollowing chapters, provide the basis upon which you should make your decisions
when representing both your division or department, the Brands and the wider
Richemont Group structure, comprising associated regional, manufacturing andcentral business units. All such interdependent business units will henceforth becollectively and generically referred to as “the Company”.
The fundamental principle underlying the Company’s Code of Business Conduct ( ‘theCode’) is to; foster an environment of trust that is conducive to fair decision-making;act upon opportunities and initiatives in a responsible manner; and, ultimately,
enable employees and leadership alike to be accountable for their actions.
It is anticipated that employees share the vision of the Company, and the loyalty tothis vision will ensure the integrity of their business conduct.

Employees
CODE OF BUSINESS CONDUCT

2Whom It Shall Apply To
The Code shall apply to all Company employees throughout the business community
as detailed in I. For the purpose of clarity, an employee is defined as any memberof staff who is working under an agreement of employment, either written or tacit,
which is fixed, permanent, or temporary, and anyone working under a contract forservices. Consultants, contractors and agents will also be required to comply with
the Code in the same manner as direct employees.

b.

What It Shall Outline
What follows is a set of guiding principles upholding the Company’s ethical business
commitment.
The Code is not designed to supersede local laws and policies, but rather acts as aframework for guidance on applicable standards of business conduct.
The Code supports variations in internal culture and looks to promote common
values and encourage employees to abide by a collective duty to maintain andcontribute towards a healthy working environment.

Employees
CODE OF BUSINESS CONDUCT3E MPL O Y E E S C O D E O F
BUSINESS CONDUCTINTRODUCTION

c.

Compliance
The Company recognises the diversity of its workforce as a unique asset and one
which the Code looks to honour and preserve. Therefore, in all instances, individual
employee rights are governed by the laws of the country of employment and by
the rules inherent to the employment agreement. As such, and as alluded to in
II.b., no element of the Code is intended to supersede local laws, existing policies
or handbooks.

III.

Issues appearing to be in conflict with the principles set forth in the Code, as well as
any other suspected unethical issue, should be raised using a reporting mechanism,as set out below.
In reporting suspected non-compliance, employees may choose from a variety ofconfidential points of communication and may use the one most comfortable forthem: their immediate line manager; their local Human Resources Manager; theGroup Human Resources Director (secure email: GroupHR.Director@richemont.com),the Group Secretariat (secure email: secretariat@richemont.com); the Head ofInternal Audit (GroupAudit.Director@richemont.com).

It remains, however, in our collective common interest to promote the enduring
quality, integrity and excellence for which the Company is known. When representing
the Company, each employee is asked to make a personal commitment to upholdthe principle of lawful behaviour appropriate to your jurisdiction and to respect thegeneral spirit of this Code.
This Code reflects general rules of prudence to guide employees in their businessenvironment and is not intended to cover every eventuality.
This Code does not constitute a contract of employment between the Company andits employees and moreover, no element of this code alters the terms and conditionsof the employee’s contract of employment.

Employees
CODE OF BUSINESS CONDUCT

4Situations of conflict arising fromthe Code

Alternatively, a dedicated email has been set for use in such situations:whistle.blowing@richemont.com
In cases where a third party employee is in doubt as to whether colleagues are
acting inconsistently with the principles of the Code, they must notify their local line
manager, in the first instance, alternatively, Human Resources as soon as reasonably
practical.

Employees
CODE OF BUSINESS CONDUCT5E MPL O Y E E S C O D E O F
BUSINESS CONDUCTINTRODUCTION

Allegations of infringement will be investigated using secure internal channels. The
Company’s commitment to a confidential, prompt and fair investigation of allegations,should pave the way for an effective internal resolution.
Whilst ensuring that appropriate investigative recourse is actioned, the Company
will respect the employee’s privacy. There will be no retribution, retaliation or othernegative consequence to an employee when he/she reports an issue.
The above applies to all consultants, contractors and agents who, with reference toII.a., should comply with the Company’s internal and local codes of conduct.

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CODE OF BUSINESS CONDUCT

6Employees
CODE OF BUSINESS CONDUCT7OVERVI EW OF CHAP T ERS
1.

Our Committment To
Equal Employment Opportunity
1.1
1.2

2.

Discrimination: Gender, Race, Education, Disability, Nationality and Religion.
Retirees And / Or Former Employees
Our Commitment To
Health And Safety Standards

2.1
2.2
2.3

3.

6.

Office and Workplace Safety
Drugs & Alcohol Abuse
Smoking

6.1
6.2
6.3
6.4
6.4.a

7.

4.

Fair And Reasonable Acceptance and Donation Of Gifts & Gratuities
Accurate And Timely Exchange Of Information
Unlawful Competitive Behaviour
Compliance
Consequences of Non-Compliance
Monitoring & Investigation
Whistle-blowing
Unsuitable Sales Practices
Unsuitable Purchase Practices
Data Protection
Legal Compliance To Government / Institutional Standards
Our Commitment To
Acting as Responsible Employees

4.1
4.2

5.

Responsible Expenditure (client and staff entertainment, travel)
Fraud and Theft

8.

Employees
CODE OF BUSINESS CONDUCT

Private Use Of Supplies, Stock and Equipment
Computer Hardware and Software
Private Use Of Internet / email / telephone / mobile phones
Company Cars
Use of Company Credit Cards
Our Commitment To
Company Intelligence And Information

8.1
8.2
8.3
8.4

9.

Collection Of Information
Distribution & Disclosure Of Company Intelligence To Third Parties
Working Externally
Contact & Media Enquiries
Our Commitment To
Integrity Of Working Relationships

9.1
9.2
9.3
9.4
9.5

Our Commitment To
A Hostile Free Working Environment
5.1
5.2
5.3
5.4

Personal Vested Interests (eg. Declaration Of A Stock Options)
BribesEmployment of Closely Related Persons (nepotism)
Personal Relationships
Declaration of Personal Relationships
Our Commitment To
Protecting Company Assets

7.1
7.1.a
7.1.b
7.2
7.3

Our Commitment To
Ethical Business Practices
3.1
3.2
3.3
3.3.a
3.3.b
3.3.c
3.3.d
3.4
3.5
3.6
3.7

Our Commitment To
Avoiding Conflicts of Interest

Workplace Hostility
Abuse
Sexual Harassment
Bullying

Employees
CODE OF BUSINESS CONDUCTWith Customers
With External Suppliers
Legal Compliance
Financial Reporting
With Shareholders, Investors

2.

E MPL O Y E E S C O D E O F
BUSINESS CONDUCTOur Commitment To:
Health And Safety Standards

A PPL I C A B L E S TA N D A R D S

1.

2.1

Office and Workplace Safety

2.2

Drugs and Alcohol Abuse

Our Committment To:
Equal Employment Opportunity

1.1

1.2

It is not permitted to carry out work or represent the Company whilst under the
influence of drugs, alcohol and / or other substances (whether or not legallypossessed), which negatively affect character and judgment. On specific occasions,such as business or staff entertaining, alcohol consumption is warranted withinreason.
Any employee using, selling, or in possession of illegal drugs on Company property
and during working hours will be subject to Company disciplinary procedures.

Discrimination: Gender, Race, Education, Disability,
Nationality and Religion.
The Company is committed to an open, inclusive and diverse working environment
and to ensuring that all employees are respected equally, without any distinction
whatsoever. All employees are entitled to fair and equal treatment, regardless ofgender, race, disability, nationality, or any religious or cultural background.
Every endeavour will be made to extend this policy when recruiting, building,training, promoting or rewarding a team and / or individuals. The Company will act
solely based on merit, abilities and job-specific criteria when taking employment
related decisions.

		Company premises are managed with a view to minimizing the risk of personal
injury and to reducing sources of health hazards to those on site. Safety-related
issues are treated with the utmost seriousness and appropriate action is taken tomeet the Company’ s legal responsibilities.
As such, designated local management will take the responsibility of ensuring
compliance with local health and safety standards and will undergo specific training
and will be provided with continual support to that effect.

2.3

Smoking
The restriction of smoking within Company buildings is deemed as an integral partof the Company’s commitment to health and safety in the workplace. On thoseCompany premises where designated smoking areas do exist, smoking will betolerated only within that confined space (eg. ‘smoking rooms’, private offices).

Retirees and / or Former Employees
The Company shall honour requirements or requests (where deemed appropriate)
for references made by former employees or retirees by providing truthful accounts
and factually accurate testimonials.
On the re-hiring of individuals when there is mutual agreement to terminate
employment between the individual and employing company, only in very exceptional
circumstances will the Company re-appoint the said individual. If the individual doesrejoin at a later date, appropriate repayment of any compensation received underagreement will usually be expected, as projected losses are no longer appropriate.

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10Employees
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3.3

Given the wide scope of the Company’s activities and the serious consequences ofinfringement for all concerned, the Company and all employees will pay particularattention to national and international competition rules including, but not limited to,those rules relating to price fixing and collusion. Collusion is defined as a secretive
agreement between parties for a fraudulent purpose with a view to profitable gain.

A PPL I C A B L E S TA N D A R D S
3.3.a

3.

Fair and Reasonable Acceptance and Donation Of Gifts& Gratuities
Where gifts, gratuities or entertainment are received or offered, caution should be
exercised that these are proportionate to the business relationship at stake, do notbear the appearance of impropriety and are inline with the local legal environment.
With reference to 6.1, bribes cannot under any circumstance be veiled as gifts or
gratuities.
As a general rule, no gift or gratuity should begin to compromise the ability to makeobjective and fair business decisions by the party giving or receiving. For the benefitof transparency, employees are strongly urged to declare any gifts or gratuities
received to their immediate hierarchy.

3.2

3.3.b

3.3.c

Monitoring and Investigation
All employees will endeavour to prevent any non-compliance or breach ofcompetition rules resulting from the conduct or activities of any other employee,
consultant, contractor or agent of the Company, so far as it is reasonably within
their power to do so. They shall cooperate with their line management or local HR
division when necessary, including supplying such information and records as may
be requested in order to monitor compliance with such rules. Employees will also
cooperate fully with the requirements of the Company or any official regulator in
the conduct of investigations including, for example, making themselves available
for questioning and by truthfully replying to any such questions.

Accurate and Timely Exchange Of Information(Inter / Extra-Mural)

12

Consequences of Non-Compliance
The consequences for the Company of involvement in anti-competitive activities
are potentially severe, including heavy fines, costs in legal fees and management
time in dealing with investigations and significant adverse publicity. Depending
upon relevant national laws, individual employees may also incur fines or termsof imprisonment as a result of their anti-competitive actions.

An integral part of conducting ethical business is the practice of daily exchange
of information within a reasonable timeframe, to both internal parties and sources
external to the company. Information will also be unequivocally reliable, factual andaccurate. Employees will avoid providing misinformation or misstatements.

Employees
CODE OF BUSINESS CONDUCT

Compliance
All employees, consultants, contractors and agents will do their utmost to comply
with the spirit and letter of those competition laws which apply to their country ofwork and with any relevant rules or policies operated by local management or theCompany as a whole, both in relation to the business of the Company and theirpersonal dealings. Employees will neither do anything, nor omit to do anything,which would place the Company in breach of any competition rules.

Our Commitment To :Ethical Business Practices

3.1

Unlawful Competitive Behaviour

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3.6

Data relating to personal, customer, client or proprietary information must be
respected, retained and stored in a confidential manner and, where possible, be
purposefully protected.
Individual countries will abide by their respective laws regulating the safeguard ofconfidential data. Employees are to be professionally accountable for being awareof latest practices in their country.

A PPL I C A B L E S TA N D A R D S

3.3. dWhistle-blowing

Generally speaking, Company standards of data protection include inter alia requiring
employees to use encrypted email, password protected electronic documents thatare stored on the network or on personal computers, key locked filing, and storage
with limited and defined access.

If in doubt as to whether proposed or previous actions may infringe competition
rules, employees should seek the advice of their local line manager and / ortheir local HR division. Employees should refer to the reporting mechanism
as detailed in Introduction III, ‘Situations of conflict arising from the Code’.

Private / consumer data for commercial and marketing purposes will only be obtained
via lawful (published, public access or permitted) means.
Similarly, personal data will not be used or sold to third parties without prior consent
from the Company and those individuals concerned.

3.7

A dedicated email has been set for use in such situations:whistle.blowing@richemont.com

3.4

Legal Compliance With Government / Institutional
Standards
The Company will comply with national and international anti-trust laws, environmental
standards, and any other trade and commercial laws in place in the countries where
the Company carries out business. It is the individual duty of employees to assist theCompany in fulfilling this mandate.
Moreover, and as per Introduction III., employees highlighting concerns they may
have about Company activities or operating standards shall be entitled to voice theirclaims in confidence to their line manager or local Head of HR (where available) who
will be familiar with requirements of different jurisdictions and will refer the matterto central executive management where appropriate.

Unsuitable Sales Practices
Commercial relations will be sought out and conducted in an honest manner, andcommitments to customers will be honoured and realistic. Equally, commercial
transactions will be transparent, and all fraudulent sales unmistakably avoided.
Every employee is responsible for accurate and complete record keeping.

3.5

Data Protection

Unsuitable Purchase Practices
Purchases and procurements on behalf of the Company in all fields of activity will
be conducted only through lawfully permissible channels. All relevant authorizations
must be obtained prior to purchase.
Every employee is responsible for accurate and complete record keeping.

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CODE OF BUSINESS CONDUCT

14Employees
CODE OF BUSINESS CONDUCT15E MPL O Y E E S C O D E O F
BUSINESS CONDUCTA PPL I C A B L E S TA N D A R D S

4.

Our Commitment To:
Acting as Responsible Employees

4.1

Responsible Expenditure(client and staff entertainment, travel)
Caution will be exercised by all employees when incurring business expenses toavoid the mis-charging of costs unrelated to a clear business purpose. Overheads
will have to be proven as directly related and proportionate to a business need or
distinct business advantage. This is applicable to all external costs with special
attention to entertainment and travel expenditure. Please refer to the Travel Policy
appropriate to your area of activity.
Furthermore, employees will not embark on pursuits of personal leisure on Company
time or funds.
The onus will be on the individual employee’s good judgment and integrity to decideon the relevance of the aforementioned business need / advantage.

4.2

Fraud and Theft
The Company will not tolerate theft of personal effects or Company merchandiseand supplies in office buildings, commercial premises or other warehouse andmanufacturing facilities.
Similarly, employees will not instigate or partake in schemes of deception in theinterest of their financial or other gain.

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CODE OF BUSINESS CONDUCT

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CODE OF BUSINESS CONDUCT17E MPL O Y E E S C O D E O F
BUSINESS CONDUCT5.3

The Company will not tolerate any form of sexual harassment and this applies to
employees, consultants, contractors, agents and outside trade contacts alike.
Harassment may cause personal anguish as well as career damage and as an
assault upon an individual’s dignity it is clearly inconsistent with the nature of theCompany. The Company’s objective is to prevent sexual harassment and offer
any employee who experiences harassment a swift and secure means to end it.
Employees should refer to the reporting mechanism as detailed in Introduction III,
‘Situations of conflict arising from the Code’.

A PPL I C A B L E S TA N D A R D S

5.

For purposes of clarity, sexual harassment in the workplace is defined as unwelcome
sexual advances, requests for sexual favours, and other verbal or physical conductof a sexual nature. Such conduct constitutes sexual harassment when: submission
to such conduct is made (either explicitly or implicitly) a term or condition of anindividual’s employment; submission to or rejection of such conduct by an individual
is used as the basis for employment decisions affecting such individual; or suchconduct has the purpose or effect of unreasonably interfering with an individual’s work
performance or creating an intimidating, hostile or offensive working environment.

Our Commitment To:
A Hostile Free Working Environment
5.1

Workplace Hostility
The Company is committed to managing a healthy work environment conducive tocreative and productive results, and will admonish any employee inflicting awkward
and uncomfortable working relationships, which affect performance levels, results,
and the welfare of others.
In line with the Company’s commitment to equal employment opportunity (cf. 1.1)
the Company will not tolerate demeaning or insulting attitudes or actions, explicit
or implicit, towards another employee derived from race, nationality, cultural
background, gender, age, disability, or any other such characteristic.

5.2

Sexual harassment may take the form of lewd and suggestive looks or comments,
sexually explicit or offensive publicly displayed pictures or magazines, or unwanted
physical contact, sexual jokes, activities or preferences.
Sexual harassment is largely determined by the perception of the victim of how theconduct / behaviour is received regardless of whatever is intended by the perpetrator.
Sexual harassment need not be intentional to violate this policy.

5.4

Abuse

18

Bullying
Workplace bullying can be identified as the persistent and premeditated offensive
behaviour carried out with intent to undermine the dignity, confidence andperformance ability of a selected target.

The Company recognizes and aims to protect the dignity of each individual in its
employ. As such, every employee is entitled to work in an environment that is safe
from threat and intimidation to their person, be it physical or emotional.
Abusive conduct may be defined by an individual’s (or group of individuals)
unreasonable or arbitrary interference, which causes another individual’s work
performance to be detrimentally affected, and which constitutes a hostile or offensive
work environment.
Individual countries will abide by their respective laws dependent on the grounds ofcivil action.

Employees
CODE OF BUSINESS CONDUCT

Sexual Harassment

Manifestations of bullying include power harassment (bullying and abuse conductedby managers on the grounds of their hierarchical position), continual criticism,
arbitrary public humiliation, unrealistic assignments, extreme confrontational
management style (not to be mistaken with assertive management) all of whichlead to costly workforce downtime and destructive work patterns. Bullying will not
be tolerated in the Company’s workforce.

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BUSINESS CONDUCT

6.2

A bribe is considered to be an undue and unrelated ‘facilitating’ inducement, whichis expected to generate particular favours in return. Bribes will not be accepted,
offered or solicited by any Company employee or agent.
This is not pertinent to the donation or receipt of promotional or merchandisingproducts of strictly limited value.

A PPL I C A B L E S TA N D A R D S
6.3

6.

Personal Interests
A conflict of interest will occur when personal interests interfere, or appear tointerfere, with the interests of the Company as a whole. This may be financial (forexample, direct or indirect financial interests or investment in one of the Group
Companies or competitors) or other personal gain-based association.

6.4

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CODE OF BUSINESS CONDUCT

20

Personal Relationships
Employees are strongly advised not to enter into a personal relationship with another
Company member when they work within the same sphere of influence. For purposesof clarity, sphere of influence is defined as physical location e.g. same building orfunctional proximity (eg same team or brand unit). It is equally discouraged between
business-related associates (eg suppliers or contractors) or within a chain ofcommand, in particular where a direct / indirect reporting mechanism is in place.
Members of staff who are married should take steps to avoid working in the same
sphere of influence.
It is in the interest of the Company and the individual alike to avoid such potentiallyproblematic conflicts of interest.

In cases where employees have financial vested interests, please refer to theCompany’s Code of Conduct for Securities Dealings by Directors and Employees of
the Group in Richemont Units and Related Securities.
At times, employees may be required to disclose actual assets or potential conflictsof interest, albeit that such requests are accompanied by a statement that theCompany, or the relevant Group Company, would not unreasonably restrict orprevent such activities where they are permitted by the individual’s contract of
employment.
In cases where employees are engaged in other employment, it is the individual’s
responsibility to ensure that the requirements of the other job do not endanger or
jeopardize the Company’s interests.
Generally speaking, Company employees must not allow outside influences, activitiesor third parties to affect their performance or decisions made for and on behalf of theCompany. With reference to the terms in 8.2, employees are required to carry out
their duties in a manner that preserves the confidentiality of business informationand enhances confidence in the integrity of their position and the Company.

Employment of Closely-Related Persons
In line with the Company’s commitment to promote a transparent and diverse
workforce, Company policy is to avoid the employment of closely-related persons.
Closely-related persons can be defined as members of direct family, spouses,
descendents etc..
Appointments will be based solely upon evaluation of qualifications, ability and jobspecific related criterion.
In cases inadvertently occurring whereby closely-related persons work withinconnected parameters, the Company will prevent direct reporting lines andabolish direct supervision lines between those close family members or personal
relationships. It is expected that employees will voluntarily disclose in advancepossible sources of conflict of interest if the relationship / kinship is not immediately
obvious.

Our Commitment To:
Avoiding Conflicts of Interest

6.1

Bribes

6.4.a

Declaration of Personal Relationships
In any circumstance where a personal relationship exists or arises, that relationshipmust be declared to the line manager in the first instance and alternatively, the
Human Resources Director within the employing company. Depending on thecircumstances, the relevant Company may consider that one or both parties
should be reassigned to other duties, that there should be a change in reportinglines or that they should be relocated. Changes may be temporary or permanent,
and in some cases termination of employment may need to be considered.

Employees
CODE OF BUSINESS CONDUCT21

E MPL O Y E E S C O D E O F
BUSINESS CONDUCT

7.1.b

Personal use of Company owned and controlled communication tools such as
internet, internet email, work email, telephone and company mobile phones, will
be with restraint and moderation and only in so far as work performance levels
are not affected.
Levels of permissible usage are left to the individual’s judgment, but may besubject to management or supervisors’ curtailment.

A PPL I C A B L E S TA N D A R D S

7.

The Company reserves the right, but not the duty, for any reason and without prioremployee permission, to monitor any aspect of employee’s computer system. This
includes, but is not limited to, documents created and stored, monitoring sites
viewed, chat groups, news groups and material downloaded from the web, as well
as screening emails sent and received. Employees should not hold expectationsof privacy for any data transmitted via Company computer systems or accessed
for technical support reasons.

Our Commitment To:
Protecting Company Assets

7.1

For comprehensive guidance on what constitutes proper usage of the Company’s
information systems, employees should consult and abide by their local policy(where in existence).

Private Use of Supplies, Stock and Equipment, ProductsCompany employees will act under the same collective responsibility to protect
Company assets. Supplies and equipment purchased by the Company, or products
and stock owned by the Company are intended for use solely by Company staff andfor Company business purposes only. Computer hardware, software, books, audio
and videotapes, trade journals and magazines are a few examples of materials
which may be governed by intellectual property laws and licenses and, if improperly
used, could inflict liability on the Company.
Use of equipment is provided for authorized purposes only; any inappropriate use,such as accessing materials of a sexual nature or using equipment for meansof engendering harassment (including but not exclusively email abuse) will bepunishable.
Furthermore, the Company will not tolerate the theft of proprietary supplies andequipment by members of staff.

7.1.a

Private Use of Internet / email / telephone  / mobile phones

7.2

7.3

Computer Hardware and Software

Company Cars
Employees granted company cars will drive lawfully, responsibly and will abide by
the highway code of their respective countries.
Unlawful practices (drink driving etc) will result in termination of the benefit and maylead to disciplinary procedures up to and including termination, the latter dependent
on local labour laws.
Costs and other implications derived from other ‘minor’ breaches of the law (speed,
parking fine etc..) will not be endorsed by the Company.

Use of Company Credit Cards
Company Credit Cards will be used exclusively for business purposes and areapplicable solely for customary business expenses.

Any Company owned IT and communication material is on loan to a Company
employee and will therefore be treated with due care and consideration, particularly
mobile equipment, and will not be loaned or sold to third parties.
Company employees will not unlawfully acquire, transmit or sell Companylicensed software for individual gain or for third-party usage.

		

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22

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E MPL O Y E E S C O D E O F
BUSINESS CONDUCTFor the purposes of clarity, confidential information is considered to be informationthat has not been made public and / or information that is known to an employee
exclusively by virtue of their position. Examples include, but are not limited to,
unpublished price-sensitive information, material and information relating to theCompany’s products, pricing and strategy, prospective acquisition or divestiture,and private records or transcripts. Company information is subject to proprietary
intellectual property rights and should not be disclosed for reasons other thanbusiness needs or when lawfully requested.

A PPL I C A B L E S TA N D A R D S

8.

Our Commitment To:
Company Intelligence And Information
8.1

Collection of Information
Consumer and/or competitor information, market intelligence, and other technicalinformation may not be obtained by underhand or dishonest ways, thereby putting
the Company at risk of legal liability.
Additionally, only published or publicly available information will be drawn on as
reliable sources of reference.

8.2

8.3

8.4

Distribution & Disclosure of Company Intelligence To
Third Parties

24

Working Externally
When working remotely from their designated office base (eg. from home or fromcompany subsidiaries) employees must take care to carry no more information thanis needed at the time and that all information be restituted to the workplace soonest
thereafter. Original or duplicated documents and data should not be kept in private
homes, without the prior consent of a line manager.

Contact & Media Enquiries
Contact with the media will be handled with care - inadvertent release of businessor technical information to third parties may provide competitors with valuable
and costly research or otherwise unobtainable data, which may undermine theCompany’s competitive advantage. If in doubt, employees are advised to contact
their line manager.
When liaising with the media, staff are reminded of what constitutes confidential
Company information (c.f 8.2) and that they are speaking in the name of theCompany. Under no circumstances should they use this to further their personal
interests or air their grievances.

Employees with access to non-public Company information of a confidential naturesuch as business strategies, financial planning, financial results, contracts et al, areobliged to abide by strict principles of non-disclosure to third parties until explicitly
authorized by the Company or until that information is publicly disseminated by
the Company. Some cases may require formal agreements to be put in place.
Contractors and all parties working on a consulting basis occasionally have accessto sensitive company information and may be required to sign a non-disclosureagreement.

Employees
CODE OF BUSINESS CONDUCTEmployees are reminded that the implications of 8.1 and 8.2, and the responsibility
to protect Company information and / or confidential information do not, in general,cease upon separation from the Company. Furthermore, company information will
be handed over upon termination of employment.

Employees
CODE OF BUSINESS CONDUCT25

E MPL O Y E E S C O D E O F
BUSINESS CONDUCT9.3

The Company will abide by all applicable national and international laws that govern
the domain of international trade, commercial transactions, financial reporting,
employment relations, etc...
Moreover, the Group will supply truthful and accurate reports, certificates, statements
and classified information when lawfully requested.

A PPL I C A B L E S TA N D A R D S
9.4

9.

Legal Compliance

Financial Reporting
The Company will assume ultimate responsibility to issue accurate financial,accounting and other reports which reflect transactions in reasonable detail, in
accordance with national and international accounting standards and practices.

Our Commitment To:
Integrity Of Working Relationships

9.5

With Shareholders / Investors
The Company is accountable for maintaining high standards of accuracy and fluency
when recording, communicating and reporting financial information to shareholders
and investors.

9.1

With Customers
As a customer-orientated enterprise, the Company’s lifeline resides in superior
customer service and outstanding professionalism in all fields of activity: productquality; product knowledge; after-sales service for buyers; but also in solution
provision, technological advantages and professional services for internal (interCompany) customers.
Employees will do their utmost to understand their respective customers’ needs, toavoid mis-managing expectations and to supply the product / service with timely,
reliable and accurate information.

9.2

With External Suppliers
Mis-managed relationships with suppliers may have detrimental repercussions on
the rest of the business and may hinder customer relationship management in thelong-term. Therefore it is equally vital to respect the suppliers’ terms and conditions
and to conduct the relationship in a transparent and courteous manner in line withgood business practice.
Similarly, care must also be taken when evaluating a prospective supplier’s offeringand employees will always take into consideration that the reputation of the Company
and its associated companies is at stake when relying on outside suppliers.
Binding service agreements will always be in place and readily available for
auditing.

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CODE OF BUSINESS CONDUCT

26

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27