Business Ethics
Guidelines
JULY 2013

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MESSAGE FROM THE OWNERS
We at Triumph International Spiesshofer & Braun KG and its subsidiaries(“Triumph”) are dedicated to conducting our business with the highest ethicalstandards. We have an obligation to our stakeholders, customers, suppliers,
community representatives and the general public to be honest, fair and candid
in everything we do.
We contribute to building a sustainable society and a natural environment in a
way that we can be proud of. Our vision is to be recognized internally andexternally as a company that is run in a responsible way, mindful of future
generations, and with consideration for what we leave behind.
Not only do we strictly comply with the applicable laws and regulations of thosecountries in which we conduct our business, Triumph additionally strives tomaintain the highest business ethics and corporate social responsibility whilst
aiming to achieve top performance. This focus has allowed us for more than 125
years to develop an enviable heritage.
These Business Ethics Guidelines provide the framework within which we wish tosustain our successful business. They contain the basic principles and rules ofcorporate conduct to guide behavior both within and outside our company. We
aim to foster a culture of integrity among ourselves for the benefit of thecompany, our employees and society at large. We also expect our business
partners to uphold a similar degree of responsibility when conducting theirbusiness with Triumph.
Triumph’s objective is to foster an ethical culture by enforcing these Business
Ethics Guidelines. Triumph never takes its reputation for granted. Every employeeof Triumph is required to live up to the ethical standards set out in these
Guidelines. All employees have the right and duty to disclose any deviation fromthese standards.
These Guidelines contribute to both the success of our company and to the wellbeing of the communities in which we operate. We trust that all involved will live
up to their principles and defend their spirit.
Bad Zurzach, Switzerland, July 2013
On behalf of the Spiesshofer and Braun families, the owners.

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CONTENTS
1.

Executive summary ........................................................................................................................... 4

2. Ensuring a proper tone at the top ....................................................................................................5
a.
b.
c.
d.

Mission statement................................................................................................................5
Company vision .....................................................................................................................5
Values, principles and core competencies ....................................................................... 6
Corporate responsibility commitment .............................................................................. 8

3. Avoiding conflicts of interests ........................................................................................................ 10
a.
b.
c.
d.

Outside appointments ....................................................................................................... 10
Third party interests .......................................................................................................... 10
Relatives and friends ......................................................................................................... 11
Gifts, meals and entertainment....................................................................................... 11

4. Safeguarding company assets ......................................................................................................... 13
a. Misappropriation of assets ............................................................................................... 13
b. Reliability and integrity of financial records ...............................................................14c. Privacy and confidentiality of information ...................................................................14
5.

Treating third parties fairly .............................................................................................................16
a.
b.
c.
d.

Dealing with third parties ................................................................................................. 16
Anti-bribery and anti-fraud .............................................................................................. 17
Political contributions, charitable donations and sponsorships ................................. 17
Anti-money laundering .......................................................................................................18

6. Putting people at the centre ......................................................................................................... 20
a.
b.
c.
d.
e.
7.

Diversity and inclusion ..................................................................................................... 20
Workplace and technical safety ..................................................................................... 20
Workplace harmony............................................................................................................ 21
Human Rights and international conventions ............................................................. 21
Environment ........................................................................................................................ 22

Administering the Guidelines ......................................................................................................... 24
a. Accountability .................................................................................................................... 24
b. Compliance, implementation and monitoring .............................................................. 24
c. Handling and reporting misconduct .............................................................................. 25

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1. EXECUTIVE SUMMARY
Triumph strives to foster the highest business ethics throughout its globalorganization. Starting at the top, a proper tone is established where ethicaland sustainable missions and visions are formulated then communicated to
employees. A set of globally shared values, principles and core competencies
provide direction of what we want to be known for and how we should interact
with our customers and consumers.
Based on more than 125 years of existence, we are committed to ensuring oursustainable legacy reflects our concern for future generations and the naturalenvironment.
Triumph’s Business Ethics Guidelines reinforce our view of the importance of
ethical behavior. The Guidelines give everyone a clear understanding of what is
expected of them in different situations to ensure an ethical conduct is upheld
and not compromised.
When avoiding conflict of interest, employees are expected to act in the bestinterest of the company by not taking outside appointments that compromise
Triumph, by disregarding the influences of personal friendships or financial
investments in competitors or business partners when making businessdecisions, and by complying with a code of conduct when giving and receiving
gifts and hospitality.
Employees are expected to safeguard the company’s assets, using them only
for Triumph’s business purposes. Financial information has to be reliable andcannot be misrepresented. Confidential information has to be protected.
While it is important to maximize the company’s profits, employees arereminded that they should always treat our business partners fairly in order tomaintain the company’s profitability in the long run. Triumph has no tolerance
for corruption, fraud or money laundering. Political contributions areprohibited. Charitable donations and sponsorships have to be conducted withcaution not to create the appearance of impropriety.
We endeavor to maintain safe workplaces that are free from bias anddiscrimination, where teamwork, communication, innovation and creativity areencouraged and everyone can develop a fruitful career. Triumph is committed to
Human Rights.
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Employees throughout all organizational levels assume a joint accountability
to enforce and monitor adherence to these Guidelines. We expect Triumph
employees and our business partners to live up to the ethical standards set out
in these Guidelines. Everyone has the right and duty to report incidences ofunethical behavior to an appropriate manager or via a dedicated email
hotline.

2. ENSURING A PROPER TONE
AT THE TOP
The establishment of a culture of integrity starts at the top. The mission and visionstatements of the company, as well as the fundamental values, principles and corecompetencies fostered by the owners and shared by everyone at Triumph, are thefoundation of our ethical business conduct throughout the global organization.

a. MISSION STATEMENT
Triumph strives to lead the global intimates market and to achieve profitable
growth. We collaborate to exceed consumer expectations with desirable, highestquality, and best-fit products supported by best-in-class services.
Passionate employees – valued as our greatest assets and ambassadors to themarket – make our brands strong and desired.
Inspired by family heritage, we ensure a responsible, ethical and compliant
corporate conduct and take great care of the global environment.

b. COMPANY VISIONOur consumers and employees trust and want to be part of Triumph, a company
empowering self-confidence.
Consumers who buy, wear and trust our brands and products will be empowered
through the feeling of attractiveness, through a positive self-perception as well as
an enhanced well-being and self-esteem.
Employees who work with us will shape our future success through the trust we
have in everyone’s own strength, value and ability. They will be proud to belong to
Triumph because we empower them to think, act and decide self-confidently asbrand ambassadors, entrepreneurs and pioneers every day.
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As a company, we encourage both consumers and employees around the world tobe more self-confident; thus we strive to become iconic and differentiated andgrow sales profitably.
We achieve our vision by combining our branded point of view with deep consumer
insight, becoming a top class multi channel retailer and a profitable, highperformance organization with a corporate focus on where to play.

c. VALUES, PRINCIPLES AND CORE

COMPETENCIES
Based on more than 125 years of Triumph’s existence, we have developed a set ofdeeply rooted values, principles and core competencies which guide our
employees’ day to day activities and are sharedby everyone at Triumph:

PASSION

OPENNESS

we are emotionally attached towhat we do and have fun;we share our thoughts and value
the opinion of others independentof their role and responsibility;

TRUST

CONSISTENCY

we believe in the capabilities ofeach of us;

we are here to stay, accountable ingood and bad times; andRESPECT
we value our people, individual
cultures and the environment.

THE
COMPANY’S
PRINCIPLESREAD AS
FOLLOWS:

We are in to win, … together;
We are consumer oriented
throughout the company;
We assume shared leadership andwork as a team;
We deliver what we commit toand assume responsibility;
We enable others by allowing
decisions at the lowest possiblelevel; andWe learn from our mistakes.
6While values and principles give us
perspectives, directions and a sense of
responsibilities, our seven corecompetencies provide a clear pictureof what kind of organization we want
to be and how we should interact withour customers and consumers. The
following core competencies describe
the behavior we expect from all
employees:

Our Core Competencies
At the heart of everything we do

RELATEINNOVATE

the competency to contribute to
Triumph’s success by behaving
in a brand-led and consumerfocused manner at all times;

the competency to find new
solutions to improve products,
processes and results;

DELIVEREMBRACEthe competency to proactively
drive and deliver high quality
results efficiently andeffectively;

the competency to understand,accept, adapt and support
required changes; andRESOLVE

LEARN

the competency to proactively
and constructively resolve
issues;the competency to proactively
develop self and others;

COLLABORATE
the competency to build andmaintain productive working
relationships.

With these values, principles and core competencies engrained in our hearts, weplace ourselves in the best position to create sustainable values for Triumph andsociety at large.
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d. CORPORATE RESPONSIBILITY COMMITMENT
Our corporate responsibility vision: “The future belongs to our children. We at
Triumph shall contribute to building a sustainable society and a naturalenvironment in a way that we can be proud of. It is our vision to be and to berecognized internally and externally as a company that is run in a responsible way,
mindful of future generations, and with consideration for what we leave behind.”
Our commitment: We at Triumph firmly believe that as a corporation we have a
responsibility towards what we affect with our actions that goes beyond delivering
our business goals.
In our endeavor for sustainable and profitable growth we commit to conduct our
global business legally and in a responsible and sustainable manner that is ethicallysound and concerned with the welfare of our people, our communities, ourstakeholders, and the natural environment.
In our pursuit of this commitment, our actions are led by:

Responsibility to include

Sustainability for future

stakeholder interests in ourdecision-making and to ensurethat good and ethical practices
are observed.

generations by creating economic
and social opportunities for our
employees and communities while
preserving the natural environment.

Through stringent governance and compliance standards we ensure that we apply
this commitment and manage any risks that would undermine our responsibility,
sustainability or the achievement of company objectives.
This commitment is consistent with our values and principles of honesty, integrity
and respect for others. Our culture of continuous learning and improvement, oureffective organizational structure and thorough communication will enable us tomonitor and control our behavior to ensure a sustainable legacy for future
generations.

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3. AVOIDING CONFLICTS OF
INTERESTS
Triumph relies on its dedicated, passionate and confident employees. Triumph
trusts its employees always to act in the company’s best interest, upholding thehighest ethical standards to protect the company’s reputation and to safeguard
the company’s assets. We should each apply our unprejudiced, intelligent judgment
to avoid conflicts of interest that are potentially harmful to the company.
If any activities or relationships occur that could lead us to gain a personal benefit
at the expense of Triumph, we are bound to disclose them. In such cases,
management personnel will then be able to take appropriate actions.

a. OUTSIDE APPOINTMENTS
A conflict of interest may arise from our business or personal relationship with acustomer, supplier, competitor, business partner, or other employee when these
relationships create the opportunity to advance personal interests at the expenseof Triumph’s interests.
We must not operate or assist a company that competes with Triumph in any way.
Furthermore, we must not be employed by, serve as a director of, or provide any
services to a company that is a supplier or a competitor of Triumph. Finally, wemust not be employed by or serve as a director of a customer or distributor orprovide services to a customer or distributor beyond the normal scope of theirbusiness relationship with Triumph.
We may engage in sideline work or outside employment only if engaging in those
activities does not interfere, or appear to interfere, with our ability to act in thebest interest of Triumph, and only if prior, written permission has been obtained
from the company. Examples of sideline work that may be allowed include
occasional writing, lectures and comparable sporadic activities, provided that the
aforementioned requirements are fulfilled and local policies regarding outside
employment are adhered to.

b. THIRD PARTY INTERESTS
We must take great care in making financial investment decisions. Investments insuppliers, customers, competitors and any other Triumph business partners could
lead to a conflict of interest.

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We must declare to the company any financial interests, direct or indirect, held byourselves or our immediate family member(s) in any business or anotherorganization which competes with Triumph or with which Triumph has businessdealings.
The issue is particularly sensitive if we have operational responsibilities in dealing
with a company in which we or our immediate family members hold investments.
We are therefore not allowed to have a financial interest in any such organizationthat could create a conflict of interest or otherwise impair our decision making.

c. RELATIVES AND FRIENDS
The actions of family members inside or outside the workplace may also give rise
to conflicts of interest because they may influence our objectivity in making
decisions on behalf of Triumph. We must remain alert to prevent our friendships
from affecting, or appearing to affect, our ability to act in the best interests of
Triumph. We must officially declare to the company any family relationships withother employees who also work for Triumph and disclose family or other close
relationships with people who are employed by Triumph’s business partners or who
have financial interests in Triumph’s business partners.
We must keep in mind that business-related decisions should be based on
qualification, performance, skill and experience and not on personal relationships

d. GIFTS, MEALS AND ENTERTAINMENT
Providing or receiving hospitality such as gifts, meals and entertainment is often
considered a form of courtesy and is common in everyday business in many
countries. However, we do not accept gifts, meals or entertainment, or any otherfavour from customers or suppliers if doing so might compromise, or appear tocompromise, our ability to make objective business decisions in the best interest of
Triumph.
Triumph is committed to fair dealings with third parties (including government
authorities). We must therefore avoid receiving and giving inappropriate benefits
which may impair sound judgment. The value of gifts or hospitality and thefrequency of such offers should not be excessive so that it does not create an
appearance of bad faith or impropriety and could not reasonably be
misunderstood by the recipient or others to be a bribe.

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4. SAFEGUARDING COMPANYASSETS
Triumph has extensive tangible and intangible assets with significant value. It is ourduty to safeguard and properly use these assets for business purposes only.
We must maintain true and fair financial information so that our management andexternal stakeholders can make proper decisions based on reliable information.
Triumph protects its employees’ private information so that everyone may feel
comfortable and secure working at Triumph. Triumph is also committed tosafeguarding the confidentiality of information concerning its business partners toensure that they have confidence in doing business with us.
Anyone who is aware of any form of misappropriation of Triumph’s assets or
misrepresentation of Triumph’s information must report such incidences to theappropriate level of management.

a. MISAPPROPRIATION OF ASSETS
We must safeguard Triumph’s tangible assets (such as computers) as well as
intangible assets (such as intellectual property). Misappropriation of assets refers
to theft or use of assets outside of our employees’ regular organizational
responsibilities. For example, conducting private, commercial activities during
working hours is strictly prohibited. In addition, senior management personnel who,
as a result of their positions within Triumph, acquire critical business knowledge,
product designs and/ or any other commercial intelligence, may not treat suchknowledge as their own property and use it for their own benefit during and/or
after their employment with Triumph. We consider misappropriations of bothtangible and intangible assets as equally unacceptable.
Given the nature of Triumph’s business and its global reach, Triumph’s products
are highly susceptible to counterfeiting. To safeguard the company’s interests,
everyone must stay alert to counterfeits and report any such incidents to theappropriate management level. Counterfeiting Triumph’s own products byemployees or by third parties is considered theft and will result in legal
consequences.
In the same spirit, Triumph does not infringe other company’s assets, including
intellectual property.

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b. RELIABILITY AND INTEGRITY OF FINANCIAL

RECORDS
Triumph is committed to open and effective communication with its employees,
customers, suppliers, and business partners. To accomplish this objective, all of us
have the responsibility to maintain accurate and truthful business and financial
records which both Triumph and third parties may rely upon to make informed
business decisions.
We also provide true and fair financial information to government authorities, suchas tax authorities.
We are committed to fulfill our legal and regulatory obligations of relevant
jurisdictions of those countries in which we operate.
Triumph’s employees are obliged to follow established internal controls and global
policies intended to ensure that business transactions are legitimate as well as
properly authorized, documented and accurately recorded. We must keep in mind
that Triumph’s reputation and credibility are also built upon accurate
recordkeeping and financial information. Intentional efforts to misrepresent or
improperly record transactions are therefore strictly forbidden.

c. PRIVACY AND CONFIDENTIALITY OF

INFORMATIONBusiness information and IT infrastructure are essential to our business success andlong-term existence. It is one of our top priorities to make sure that private
information concerning employees, customers, suppliers and other business
partners is protected and secured.
Triumph has a well-established global IT security policy to safeguard the privacy
and confidentiality of information assets following three key principles:.

Integrity

Confidentiality

Availability

The safeguarding of theaccuracy andcompleteness of
information.

Information will not bemade available ordisclosed tounauthorized individuals,
entities or processes.

Information will beaccessible and usable
upon demand by anauthorized party.

We must never disclose sensitive, confidential information to anyone outside
Triumph, including family and friends, except when disclosure is required forregulatory purposes and disclosure is in compliance with confidentiality
agreements entered into with the parties concerned.

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5.

TREATING THIRD PARTIESFAIRLYThe success of Triumph and society in general is built on honest and fair dealing
with one another.
Triumph strives to foster an environment that is free from bias, illegal activities,
discrimination and any other malicious conduct that can create negative
consequences for third parties.

a. DEALING WITH THIRD PARTIES
Triumph recognizes the importance of treating third parties fairly, which isessential to establishing mutually trustworthy, fruitful and lasting relationships. We
make our purchasing decisions based on objective criteria such as price andproduct / service quality as well as the suppliers’ delivery reliability and integrity.
We do not accept kickbacks, bribes or similar payments which may unlawfully
impact decision making and lead to bias and preferential treatment vis-à-vis ourvendors. We give every supplier the same fair consideration.
We believe in fair competition permitting markets to develop freely and profitably.
We never knowingly communicate false information about a competitor or theirproducts or services.
Triumph always aims at maximizing customer value by providing high quality
products and services that satisfy customer demands to the greatest extent
possible. We never mislead customers through deceptive acts or practices, false
advertising claims or misrepresentations regarding Triumph’s or our competitors’
products and services.
Triumph also expects its business partners to uphold the same standards ofbusiness ethics as Triumph does. We never do business with a third party in any
circumstance that would reflect poorly on Triumph’s reputation. We also never use
a third party to perform any acts that are inconsistent with or prohibited underthese Guidelines.

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b. ANTI-BRIBERY AND ANTI-FRAUD
Corruption has for long been a regrettable aspect of human behaviour. For thatreason, it may be easy to forget the damage that corruption causes. By wrongly
benefiting a few individuals who abuse their power or position, it creates unfair
competition, damages innovation and undermines integrity.
Fraud is also an ever-present threat and often arises because of lack of properinternal controls. It may also be the result of failure to follow proper procedures,
carelessness in carrying out checks, inadequate segregation of duties ormanagement overriding internal controls.
Triumph’s values are integrity and transparency in business. In support of theseprinciples Triumph is committed to the prevention and detection of fraud, bribery
and all other corrupt business practices, with a zero tolerance policy. The
company’s reputation for lawful and responsible business behaviour is of great
importance and is to be protected under all circumstances and at all times.

c. POLITICAL CONTRIBUTIONS, CHARITABLE

DONATIONS AND SPONSORSHIPS
Political contributions refer to contributions of anything of value to support a
political goal. Political contributions made on behalf of the company are vulnerable
to abuse and are illegal in many countries. Therefore, we do not make politicalcontributions in any form as a company.
However, we may pursue our private/ personal political activity as long as our job
duties are not affected. Any activity for a legal political cause should be executed
as a private person, never appearing publicly as a Triumph employee or
representative. We must also not use Triumph’s reputation or assets to further ourown or any other political activities or interests.
Even legitimate charitable donations can carry the risk of creating the appearanceof corruption. Therefore, we must follow this guidance in making charitable
donations:17

DONATIONS
may not be offered, promised or given if they are intended to influence official
action or secure an improper advantage.
may not be made to individuals, to for-profit organizations, to organizations that
do not have tax-exempt status or whose business principles are not compatible
with the Triumph Business Ethics Guidelines.
must be transparent.
should be tax-deductible.

PAYMENTS
to private accounts or in cash are not permitted.

d. ANTI-MONEY LAUNDERING
Money laundering is the process of disguising the nature and source of money
connected with illegal or criminal activities, such as drug trafficking, terrorism orbribery, by channeling illegal money into the commercial stream so that it appears
legitimate while its true source or owner cannot be identified.
It is Triumph’s objective to conduct business only with reputable customers,
suppliers and business partners who are engaged in lawful and legitimate businessactivities with funds derived from legal sources.
We do not facilitate money laundering and we must not accept or make any
payments with funds known to be derived from illegal activities.
To avoid being abused as a channel for money laundering, we must comply withapplicable anti-money laundering laws and Triumph’s procedures designed todetect and deter suspicious forms of payments or other transactions that could
involve money laundering. To mitigate money laundering risk, we mustbe attentive to and report suspicious behaviour by customers, suppliers andbusiness partners and must comply with company policies and internal controls
which govern payments and receipts of cash, banking transactions and treasury
activities.

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6. PUTTING PEOPLE AT THE
CENTRE
Triumph embraces diversity throughout our global organization. Workplace safety
and harmony are top priorities, and we also adhere to Human Rights conventions.
Triumph is environmentally conscious, and we strive to avoid harming theenvironment as a result of our business activities.

a . DIVERSITY AND INCLUSION
Triumph makes every effort to maintain a healthy, safe and productive
work environment which is free from discrimination or harassment andgives equal employment opportunity to everyone. Every Triumph
employee should treat others with respect and dignity and help
maintain an inclusive and harmonious workplace where all of us candemonstrate our full potential, and prosperously develop personally. This, in turn,will immensely support our profitable, sustainable growth.
Triumph does not tolerate discrimination or harassment of any kind. Discrimination
includes employment decisions based on personal characteristics or beliefs thatare unrelated to the ability to do one’s job, including race, colour, religion, gender,
gender identity, nationality, ethnicity, age, maternity, marital status, disability,
sexual orientation, membership of workers’ organizations including unions, andpolitical affiliation.
We strive to provide equal opportunities for every employee in all aspects of
employment, such as training, education and promotions. Any factor unrelated toour employees’ job responsibilities and performance will be disregarded.

b. WORKPLACE AND TECHNICAL SAFETY
Triumph is committed to providing a safe and healthy
working environment for our employees. Their safety andsecurity are vitally important, especially for those working in
our worldwide production and warehouse facilities. We consistently
apply the highest safety standards to our facilities in all locations andassume accountability for the well-being of everyone working at
Triumph.

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We do not tolerate violence or threats of violence in, or related to, our workplace.
If we experience, witness or become aware of a violent or potentially violent
situation that occurs on Triumph’s property or affects Triumph’s business, we must
immediately report the situation to our supervisor.
Triumph does not permit anyone to carry weapons of any kind whilst on-site or offsite travelling on company business.

c. WORKPLACE HARMONY
Triumph’s success depends on the collective contributions from its
dedicated employees. We strive to ensure harmony for everyone at
Triumph by creating a friendly and caring working environment which
fosters team work, innovation, creativity, respect, trust, happiness and asense of family. We believe that through the creation of a safe andharmonious working environment, employees will deliver top performance anddevelop fruitful careers.
Triumph is an organization that supports team work and shares information andideas openly and honestly. We promote open communication between allorganizational levels and encourage interactions across geographical anddepartmental boundaries.
Triumph strives to attract, retain and develop high quality people. We care forthem and invest in their training and development, provide a supportive
environment where they can perform to their potential.
We recognize performance and strive to provide fair, competitive and transparent
reward and recognition. We respect the individual, listening to and acting on theirconcerns.
At the same time, all employees of Triumph must fulfill their responsibilities,
support each other and work collaboratively for the benefit of the entire
organization.

d. HUMAN RIGHTS AND INTERNATIONALCONVENTIONSTriumph is committed to respecting and supporting, within
its sphere of influence, the principles contained within the
United Nations Universal Declaration of Human Rights(UNHR). Triumph equally supports the fundamental labour
principles and rights as defined in the International Labor Organization’sCore Conventions. These include the prohibition of child labour andforced labour in all its forms, freedom of association and the right tocollective bargaining, and protection from discrimination.

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Triumph is a member of the amfori Business Social Compliance Initiative (amfori
BSCI) and, in its supply chain, is committed to ensuring compliance with theamfori BSCI Code of Conduct (www.amfori.org/content/amfori-bsci).
Triumph expects their business partners to live up to these same standards.

e. ENVIRONMENT
As stated in our mission, protecting the environment and preserving
natural resources are high priorities for us.
We commit ourselves to environmentally sustainable business practices.
We seek to avoid any adverse impact and damage to the environment
and the communities in which we do business. At the same time, we also comply
with all applicable environmental, health and safety laws and regulations ofindividual country jurisdictions. It is Triumph management’s responsibility tounderstand, communicate and obey relevant laws, regulations and policies.
Triumph strives to conserve resources and reduce waste and emissions throughrecycling and other energy conservation measures. Triumph employees have a
responsibility to promptly report to the appropriate level of management any
known or suspected violations of environmental laws or any events that may resultin a discharge or emission of hazardous materials. Manufacturing employees havea special responsibility to safeguard the environment by staying alert to the proper
storage, disposal and transportation of waste and toxic materials over land, wateror air.

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7. ADMINISTERING THE
GUIDELINE
We seriously attempt fostering an ethical culture and are committed to enforcing
these Guidelines.
Our reputation should never be taken for granted. Every employee of Triumph is
accountable to live up to the ethical standards represented by these Guidelines.
Everyone has the right and duty to report any unethical incidence to theappropriate management level.

a. ACCOUNTABILITY
We have the responsibility to read and understand the Guidelines and proactively
seek clarification from our supervisors when in doubt. Triumph employees across theglobe throughout all organizational levels must uphold and defend the spirit of these
Guidelines under all circumstances and at all times.

Triumph’s Global Management Board is obliged to review and update periodicallythe contents of these Guidelines in response to changes in the global businessenvironment to ensure the Guidelines remain comprehensive and relevant.
b. COMPLIANCE, IMPLEMENTATION AND

MONITORING
During daily business routines, we may face various ethical dilemmas which
potentially put our company’s reputation at risk. While these Guidelines may notprovide all answers for all situations, they serve as a framework which, coupled witheach individual’s sound judgment and experience, should allow us to make the rightdecisions and act in the best interest of our company.
Triumph’s global management bodies are responsible for distributing, implementing
and monitoring these Guidelines throughout our group. Every one of us is expected
to have the discipline to follow these Guidelines even in the absence of monitoringfrom our supervisors.

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c. HANDLING AND REPORTING MISCONDUCTThe management relies on each employee to report any breach of these Guidelines
to help implement corrective actions. All of us have the right and duty to report withgood faith any suspicion of unethical behaviour or any violation of these Guidelines.
We strictly prohibit retaliation against anyone who reports such incidents.
Triumph has set up an integrity hotline (integrity@triumph.com) which is anindependent and confidential communication channel for receiving information
relating to improper business conduct. It is open to Triumph employees as well as tothird parties, such as suppliers, local authorities and customers and can be used toreport corporate misconduct such as fraud, corruption, bribery and theft. No
qualified report will be disregarded.
Employees may also ask questions through the integrity hotline should they be indoubt about these Guidelines and have been unable to obtain satisfactory replies
from their supervisors, or if they do not feel comfortable seeking advice from theirsupervisors.
The integrity hotline should only need to be used if regular communication channels
are not appropriate or have failed.

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