BUSINESSCONDUCTGu i deFebruary 2023

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Table of Contents• Introduction

1• Conflicts of Interest

2• Use of Assets

4• Fair Dealing

7• Antitrust

11• Government Relations

11• Anti-Corruption

12• Rights of Others

14• Miscellaneous

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o Examples
o Disclosure and WaiversooooProper Use of Company Property
Confidential Information/Insider Trading
Accounting and Reporting Integrity
Signing Authority

o Receiving Gifts
o Giving Gifts
 Government Officials and Employees Corporate Sponsorships

o Government Procurement of Products
o Political Activities
o Additional Informationo Payments and Expenditureso Engaging Agents and Channel
Partnerso Anti-Corruption Laws
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o
o
o
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Fair Treatment of Employees
Health, Safety & Environmental Laws
Copyrights and Software
Third-Party Confidential Information
Privacyo Corporate Responsibility Principles
o Company Disclosure
o Announcements, Press Releases, Media Advisories & Media
Inquirieso Social Mediao Third-Party Inquirieso Volunteerism, Community Service, and Solicitationo Approval of Publications and Presentationsi• Compliance
o

o
o
o
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Waivers
Violations
ReportingConfidentiality and Non-retaliation
Training and Certification• References

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INTRODUCTION
Eastman Kodak Company’s Business Conduct Guide covers key company policies thatreflect our commitment to ethical business conduct. Our commitment to ethical behavior
builds trust with our customers and improves the experience of all employees at Kodak.
The Business Conduct Guide applies throughout the worldwide Kodak consolidated
group of entities, from the newest employee of Eastman Kodak Company or a Kodak
subsidiary to the company’s or subsidiary’s senior officers. As an employee, you are
expected to be familiar with the Business Conduct Guide and the underlying policies.
Each employee is responsible for conducting the company’s business with honesty andintegrity, and for complying with all applicable laws, regulations, and company policies.
These responsibilities include:
1. Avoiding situations where personal interests are, or appear to be, in conflictwith company interests, and promptly disclosing any apparent or actual
conflict.
2. Safeguarding and properly using company assets, including maintaining
confidentiality of nonpublic information and not acting on such information
for personal gain.
3. Being truthful and accurate in all communications, records, and reporting
both inside and outside the company.
4. Treating customers, suppliers, and fellow employees, lawfully, honestly
and fairly.
5. Maintaining the highest ethical standards in dealings with public officials
and government employees.
6. Respecting the rights of others.
7. Being familiar with company policies that govern relationships with third
parties.
8. Reporting promptly all suspected violations of law and company policy.
This Guide does not cover all ethical or compliance issues that may arise, and is
supplemented by other company policies, which can be found at
http://policies.kodak.com.
If you have questions about appropriate business conduct, discuss them with yoursupervisor, Human Resources or a member of the Compliance or Legal teams. If it is notpossible to seek guidance in a timely fashion, you are expected to act with integrity andgood sense. Business decisions and activities must meet our ethical as well as legal andindustry standards. When carrying out your responsibilities, consider (a) whether thecompany’s reputation would be damaged by public scrutiny of the matter, and (b)whether you would be comfortable publicly disclosing the matter.
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We encourage you to report potential violations to your supervisor, Human Resources,
the Kodak Business Conduct Hotline, the Chief Compliance Officer, or the Legal
Department. Kodak does not tolerate acts of retaliation toward employees who reportsuspected violations in good faith. Any employee engaging in retaliation is subject todisciplinary action, up to and including termination.

CONFLICTS OF INTEREST
Employees should avoid any situation that may involve a conflict between their personal
interests and the interests of the company. When representing the company intransactions with others, when making recommendations or decisions relating to thosetransactions, and when carrying on the company’s business in any manner, Kodak
employees should not obtain any improper personal benefit or gain related to their
responsibilities at the company. Employees must also avoid any situation that could leadto divided loyalties or present the appearance of a conflict of interest.
This policy applies to each employee and, depending on the circumstances, may apply
to the employee indirectly as the result of actions by members of the employee’s
immediate family, including the employee’s spouse, parents, stepparents, children,
stepchildren, siblings, mothers and fathers-in-law, sons and daughters-in-law, andbrothers and sisters- in-law and anyone residing in the employee’s home (other than atenant).
When uncertain, you should discuss your situation with your supervisor, Human
Resources, the Chief Compliance Officer, or the Legal Department.
Company officers must also follow the company’s Related Party Transactions Policy
and Procedures.
ExamplesExamples of actual and potential conflicts of interest include:•

Conducting business with an entity that employs or is owned by an
immediate family member.

•

Hiring an external vendor to perform services for the company when you or
your immediate family member is a director, employee or a greater than
10% owner of the vendor.

•

You or your immediate family members having significant indebtedness toan outside organization or individual with which Kodak conducts business(“significant indebtedness” does not include indebtedness to a bank or otherqualified lending institution at interest rates and on terms generally
prevailing at the time the indebtedness is incurred).

2•Serving as an employee or director, performing work or services for, or
receiving compensation from a competitor or other third party whose
interests are adverse to Kodak’s interests.

•

Influencing business for your own personal gain or not in the best interestof the company with respect to a party with whom you have a close
personal relationship or friendship.

•

Having a greater than 10% ownership interest in a business where you hireor utilize employees, vendors, or customers of Kodak.

•

Using for a personal business any company property, including
opportunities that are discovered through the use of company property,
information, or position.

•

Acting as a broker, finder, or intermediary for the benefit of a third party intransactions involving the company or its interests.

•

Acting on an advisory/technical board where technology may conflict with
Kodak’s short-term or long-term interests.

Where an employee, by virtue of his or her position, is able to affect the business of athird-party on behalf of Kodak in the examples above, it is more likely that there is anactual conflict of interest. An employee serving as a director or similar fiduciary of anentity in which Kodak owns an investment will not create a conflict of interest even if
Kodak engages in transactions with such entity; provided, such employee has no otherrelationship with such entity and any compensation for such service is paid to Kodak.
Disclosure and Waivers
Before any actual or potential conflict of interest arises, or as soon as the employee
becomes aware of an actual or potential conflict of interest, the employee must makeprompt and full disclosure in writing to supervision by completing and submitting a
Conflict of Interest Declaration and Waiver Request available on the Compliance pageof the Kodak Workforce Portal. This form must be reviewed and signed by theemployee’s supervisor and Human Resources. Supervisors, working in coordination
with Human Resources, the Chief Compliance Officer and Legal, as appropriate, should
promptly apply the criteria described above to determine whether a conflict of interest
does exist, and, if so, whether to waive the conflict consistent with the company’s bestinterest. All completed forms should be sent to the Chief Compliance Officer for
approval.
Relationships with competitors or potential competitors are of special concern due toantitrust laws and may not be appropriate to waive. These relationships must be
reviewed by the General Counsel in addition to the procedures described above.
Only the Board of Directors or a committee of the Board of Directors may waive
conflicts of interest for Section 16 officers, which must be disclosed when and as
required by the rules of the New York Stock Exchange and Securities and Exchange
Commission.
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If circumstances change, or are anticipated to change, significantly from those initiallydisclosed, employees should submit a new Conflict of Interest Declaration and Waiver
Request.

USE OF ASSETS
Each employee is responsible for the protection and proper use of company assets,
including confidential information. Employees must comply with security programs tosafeguard assets against unauthorized use or removal, as well as against loss by criminal
act or breach of trust.
Proper Use of Company Property
Unauthorized removal from the company’s facilities of company property is prohibited.
This applies to furnishings, equipment (including computer equipment), and supplies. It
also applies to property created or obtained by the company for its exclusive use,
including originals and copies of customer lists, files, personnel information, referencematerials and reports, computer software, and data processing systems and databases.
Employees must obtain prior written authorization from supervision before removing
company property from the company’s facilities or using company property for
purposes other than the company’s business.
The company’s products and services are its property. Contributions made by any
employee to their development are also the company’s property and remain thecompany’s property even after the employee’s employment terminates. Further, allemployees are required to maintain the security of information resources and IT
systems, including computers, laptops, wireless devices, removable media (e.g., USB
flash drives, external hard drives, etc.), and all other sources of electronic information,
to guard against loss or theft of the information. Details on this obligation can be foundin Sections 9 and 10 of the Internal Control Standards. http://ics.kodak.com/.
Employees must contact WWIS immediately if any IT equipment (e.g. laptop, cell
phone, hard drive, etc.) is misplaced, lost or stolen. This includes company-issued
equipment and personal devices used for work. Employees must notify their supervisor
and immediately report the incident to WWIS by emailing WW-CISO-Mail@kodak.com
or submitting a Data Security Incident using HelpIT. Each employee has an obligation touse productively the time for which he or she receives compensation from the company.
Work hours should be devoted to activities directly related to the company’s business,
except for non-business activities authorized by the employee’s supervision.
Company assets, including equipment, facilities, information resources, and “corporate
opportunities” (business opportunities that an employee discovers in the course of his or
her employment, but that rightfully belong to the company) must be used for businesspurposes only. This includes company-provided e-mail and Internet access, although
infrequent, brief, constructive, and professional one-to-one e-mail and Internet personal
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communications during non-work time (e.g., breaks or family emergencies) may bepermitted.
Confidential Information/Insider Trading
Employees who are entrusted with information through the company, its customers,
suppliers, contractors and other parties that transact business with the company must
hold such information in confidence and must not communicate it to anyone, including
family members, not authorized to see it, unless otherwise required by law.
The type of information that employees must safeguard includes business strategies,
pending contracts, research results, unannounced products, product formulae, software
source code, manufacturing processes, sales data, customer information, nonpublicfinancial information, and significant projects, including proposed acquisitions anddivestitures. Confidential information also includes all non-public information thatmight be of use to competitors, or harmful to the company or its customers, if disclosed.
Federal and state securities laws (commonly referred to as insider trading laws)
generally prohibit any person who is aware of material non-public information about acompany from transacting directly or indirectly in, including purchasing or selling, thesecurities of that company. These laws also prohibit such person from disclosing
material non-public information to other persons who may directly or indirectly transact,
including making a purchase or sale on the basis of that information.
Kodak maintains an insider trading policy to both ensure compliance with the insider
trading laws and to avoid circumstances where company insiders could be perceived tohave violated those laws. Violations of the insider trading laws can result in serious
liabilities and both civil and criminal penalties.
Employees are responsible for complying with the securities laws and Kodak’s insider
trading policy. The policy also applies to an employee’s family members who residewith the employee, anyone else who lives with the employee, any family members who
do not live with the employee but whose transactions in company securities (as definedin the policy) are subject to the employee’s influence or control (such as parents orchildren who consult with the employee before they trade in company securities) andany entity whose transactions in company securities are controlled by the employee. The
employee is responsible for making sure that these other persons and entities comply
with the policy.
As further described in the policy, certain employees may only transact in company
securities during specified trading windows and/or must obtain pre clearance prior totransacting in company securities. Any employee who possesses material non-public
information at the time such employee’s employment or other services with thecompany terminates, will remain subject to the policy until the information has been
publicly announced by the company or is no longer material.

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Accounting and Reporting Integrity
The company is required by law to report its results, including its financial results,
accurately and completely.
To ensure that the company’s reports to third parties, including shareholders, creditors,
and government entities, are accurate and complete, employees must ensure that internalreports are equally accurate and complete.
All company financial reports, accounting records, research reports, sales reports,
expense accounts, time sheets, and other documents must accurately and clearly
represent the relevant facts or the true nature of a transaction. Improper or inaccurate
accounting, documentation, or financial reporting are contrary to company policy andmay also be in violation of applicable laws. Intentional accounting misclassifications(e.g., expense versus capital), sham transactions (e.g., sales where the company isobligated to repurchase products, or sales in excess of customer’s reasonablerequirements), and improper acceleration, deferral, or recognition of expenses orrevenues are examples of prohibited reporting practices. Also prohibited are payments
made with the understanding that they will be used for something other than the statedbusiness purpose. Finally, it is a violation of company policy, and possibly a violation oflaw, to assist third parties, including customers and suppliers, with their improperaccounting and reporting. The company maintains a system of internal controls,
disclosure controls and procedures to ensure that:a. transactions are executed in accordance with management’s authorization, andare properly recorded and posted;b. company assets are safeguarded from loss, unauthorized access, waste, fraud, andabuse;
c. company resources are used in an efficient and effective manner;d. the company accurately and timely discloses required financial and non-financial
information; ande. all legal requirements are satisfied.
The company’s internal controls are those policies, procedures and activities taken toprovide reasonable assurance that the company is moving toward meeting its businessobjectives in a manner consistent with company values and applicable legal obligations.
A system of good internal controls takes into account specific risks which can affect theaccomplishment of business objectives and minimizes those risks in a cost-effective
manner. The company’s system of internal controls helps businesses succeed bypromoting efficient and effective use of company resources, safeguarding assets fromwaste and fraud, assuring reliability of financial and operational information, andassuring compliance with relevant policies, procedures, laws, and regulations, bothinternal and external to the company.
Responsibility for compliance with these policies rests with all employees, not solely
with the company’s finance and accounting personnel. Each employee is required to be
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familiar and in compliance with the internal controls, disclosure controls and procedures
related to his or her job.
All employees must be truthful and open in dealing with the company’s internal andindependent auditors and Corporate Security investigators. Employees may not directly
or indirectly take any action to improperly influence, coerce, mislead, or manipulate thecompany’s internal or independent auditors or investigators. Doing so may result in
disciplinary action up to and including termination.
Signing Authority
Only authorized employees can sign contracts and other binding documents on behalf ofKodak and its subsidiaries. This authority is granted to employees, by name or by title,by authorizing resolutions (adopted by Kodak’s board of directors and the boards of
directors of Kodak subsidiaries). Signing authority does not derive from internal
administrative designations or titles.
Individuals who have been authorized to sign a legally binding documents on behalf ofthe company have been notified. An employee who is uncertain about his or her signingauthority should check with supervision or the General Counsel’s office.

FAIR DEALING
Kodak employees must treat customers, competitors, suppliers, and other employees
fairly and without manipulation, concealment, abuse of privileged information, or
misrepresentation of material facts.
The company does not seek to gain advantage through the improper use of favors orother inducements. Offering, giving, soliciting, or receiving any form of bribe isprohibited.
Our policies restricting the giving or receiving of gifts and entertainment are based on
the principle that business decisions should not be influenced by inducements with apersonal benefit. Even the appearance that a business decision was influenced by apersonal benefit can harm the reputation of the company and our employees.
Gifts of a “token value” are not subject to the restrictions described below. “Tokenvalue” means a value of US$100 or less except in the EAMER region where “token
value” means €100 or less. The value of multiple gifts given or received by Kodak
employees over a limited period of time, i.e. twelve months or less should be aggregatedfor purposes of determining whether they exceed token value. In general, the term “gift”
refers to items of a personal nature and does not apply to commercial products andservices, such as company product provided at no charge as part of a trade trial.

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Receiving Gifts
Without the written approval of an Executive Leadership Team member, neither an
employee nor a member of the employee’s household may accept gifts, favors,
entertainment, or other inducements, of more than token value (as defined above), or
offered at less than market value from any person or organization that does or seeks to
do business with, or is a competitor of, the company.
The approving member of the Executive Leadership Team will determine whether theemployee may accept a gift or entertainment or must return it or dispose of it in someway. The rationale for a decision to allow an employee to accept a gift or entertainmentof more than token value must be documented by the relevant Executive Leadership
Team member and approved by the Chief Compliance Officer. Any questions aroundhow to determine whether to allow an exception to this policy should be directed to
the Chief Compliance Officer.
Some company units (e.g., Procurement) have adopted a stricter standard, and havecommunicated that standard to their personnel.
An employee must not accept a gift or entertainment if it unduly influences him/her ormakes the employee feel obligated to pay back the other party with company business orassets. An employee may choose to reimburse the offering party for the cost of a gift orentertainment. In such cases, the employee must discuss with his/her supervisor whether
the reimbursement is sufficient to eliminate even the appearance that the employee may
be influenced by the offering party. If the supervisor concludes that the potential
appearance of influence is mitigated by the employee reimbursing the offering party, thesupervisor should document the rationale for this conclusion in the employee’s personnel
file.
It is never acceptable to receive a gift in cash, stock, or a cash or stock equivalent. It isalso unacceptable, except as noted in the section in this Guide on Conflicts of Interest, toreceive the benefits of a loan or loan guarantee from any entity doing business or
seeking to do business with the company.
Reasonable meals and refreshments served during business meetings are not considereda gift. Before accepting any meals or entertainment offered in conjunction with abusiness meeting or function by a person or entity doing business or seeking to dobusiness with Kodak, employees should consider the primary purpose of the meeting orfunction. If the primary purpose of the meeting/function is personal entertainment, theoffer will be treated as a gift and the restrictions set forth in the first paragraph of thissection on Receiving Gifts will apply. If, on the other hand, the primary purpose of themeeting/function is to discuss business, the offer is not a gift and falls outside the scopeof this policy.
To differentiate between a personal and a business meeting/function, consider thefollowing examples:8•An employee is invited by a supplier to a three-day event at a resort location withtravel expenses and lodging to be paid for by the supplier. The agenda for the
event includes two days of golf, spa treatments and sailing. The final day of theevent includes a business meeting.
Conclusion: The primary purpose of the event is personal in nature because themajority of the agenda is dedicated to entertainment, not business. The employee
should either seek his/her supervisor’s approval for Kodak to pay their travel andlodging expenses necessary to participate in the business portion of the meeting or
decline the invitation.

•

An employee is invited by a prospective vendor to a customer focus groupmeeting in another city. The prospective vendor offers to pay the employee’s
hotel and meal expenses. In order to participate in the focus group meeting, theemployee must review two binders of background material. The agenda for thesession consists of seven hours of discussion on business topics and a one hour
lunch break.
Conclusion: The primary purpose of the meeting is business because the agenda
consists primarily of business topics. Also, the employee would be providing avaluable service to the prospective vendor by preparing for and participating inseven hours of business discussions. The employee may accept the prospective
vendor’s offer with the approval of his/her supervisor.

•

A prospective Kodak distributor offers a company employee two tickets to aprofessional soccer match. The tickets have a value of $200 each. The employee
is invited to bring a guest to the match. The prospective distributor will not attend.
Conclusion: There is no business purpose for the employee to attend the soccer
match because the prospective distributor will not be represented. The company
policy on Receiving Gifts applies because the tickets are worth more than token
value. The employee should either decline the offer or discuss with his/hersupervisor whether it is appropriate for the employee to reimburse the prospective
distributor for the cost of the tickets. The conclusion of this discussion should be
documented if the supervisor determines that it is appropriate for the employee toreimburse the prospective distributor.

For their protection, employees dealing with customers or suppliers should advise thecustomers or suppliers of this company policy at the outset of the relationship,preferably in writing.
Giving Gifts
Gifts, favors, and entertainment may be given to customers and suppliers if what isgiven:••••

is consistent with customary business practice;is of no more than token value and cannot be construed as a bribe or pay-off;is not in violation of applicable law or ethical standards; andwould not embarrass the company or the employee if publicly disclosed.
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When a proposed gift consists of Kodak products, “token value” means up to US$250.
For other types of gifts or entertainment, token value means $100 or less except in the
EAMER region where token value means €100 or less. Although this list is not allinclusive, examples of gifts that are not acceptable include alcohol, or hosting acustomer, channel partner or supplier at an entertainment club or night club.
Exceptions to these limitations require the written approval of an Executive Leadership
Team member. The rationale for an officer’s decision to allow a gift or entertainmentthat does not meet all of the standards listed above must be documented by the [relevant
member of the Executive Leadership Team] and approved by the Chief Compliance
Officer. Any questions a company officer may have in determining whether to allow
an exception to this policy should be directed to the Chief Compliance Officer.
The procedure for reimbursement of permitted gifts and entertainment is described in thecompany’s Global Travel, Entertainment and Expense Policy.
Government Officials and Employees: Although gifts to government employees are
generally prohibited by law (see Section on Anti-Corruption), there may occasionally besituations where law and custom permit the giving of gifts to government employees.
Where such gifts are contemplated, the prior written approval of Kodak legal counsel
and an Executive Leadership Team member is required. Similarly, receipt of gifts fromgovernment employees or entities requires the prior written approval of Kodak legal
counsel and an Executive Leadership Team member. Any such gift received should beof “token value” as that term is described herein. Any questions around determining
whether to allow an exception to this policy should be directed to the Chief
Compliance Officer.
Certain countries may have specific legislation prohibiting gifts and entertainment toparticular governmental organizations. Kodak employees should seek legal advice tounderstand the boundaries of such legislation. In the United States, for example, Kodak
employees are prohibited from providing, requesting or directing a gift, including meals
and travel, to a Member of the U.S. Congress, family member of a Member, or an officer
or employee of either House of Congress. Also, in the United States, all gifts involving
Executive Branch officials and employees, including family members, must be approvedby the Vice President of Public Affairs in addition to the above-mentioned approvals.
Furthermore, in order to comply with U.S. state and local ethics laws, all gifts directed toa state or local official or employee, or family member thereof, must be approved inadvance by the Vice President of Public Affairs.
Reasonable meals and entertainment provided to a current or prospective nongovernment customer or business partner in connection with a business meeting orfunction are not considered gifts. However, employees should be mindful of this gift
policy when the primary purpose of a meeting or function is personal entertainment
rather than business. Providing event tickets to a customer or business partner will beconsidered personal entertainment unless the customer or business sponsor isaccompanied by a company representative and business will be discussed during the10event. Examples illustrating the difference between meetings/functions that areprimarily for business and those that are primarily personal in nature appear above under
Receiving Gifts.
Corporate Sponsorships: As a sponsor of sporting and other entertainmentorganizations and events, Kodak has access to certain benefits from the sponsoredorganizations such as free tickets or passes to events. Such tickets and other benefits
may be given to non-government customers and other business partners, provided that(1) the benefits are contributed to the company by a sponsored organization and; (2) a
Kodak representative will host the customer or business partner during the event.

ANTITRUST
Employees must comply with the antitrust laws of the United States and corresponding
competition laws of other nations. The antitrust laws apply to the following kinds ofactivities: conduct constituting monopolization or abuse of a dominant position;
discussions among competitors involving price, territories and customers to be served,
terms and conditions of sale, and other competitively significant information;
determinations by suppliers of the prices to be charged by their customers;
discrimination in price and other allowances by suppliers in dealings with theircustomers, channel partners, or distributors; tie-in sales; and the anti-competitive effectsof mergers, acquisitions, joint ventures and other similar arrangements.
An area of particular concern involves agreements and discussions with competitors.
Employees must not participate in any discussion, understanding, agreement, plan, or
scheme, whether formal or informal, with any competitor or potential competitor thatinvolves prices, price levels, territories, or customers to be served.
All employees who regularly deal with customers or competitors must be generallyfamiliar with relevant antitrust law and related company policy, as summarized in thecompany’s Antitrust Compliance Manual located on the Kodak Workforce Portal.
The criminal penalties imposed by courts related to such understandings are severe interms both of imprisonment and fines, and they are imposed on both employees andemployers.
For questions regarding potential antitrust issues, contact the Legal Department.

GOVERNMENT RELATIONS
Employees must adhere to the highest standards of ethical conduct in all relationships
with government officials, employees, and candidates for public office.

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Government Procurement of Products
Many governments around the world have comprehensive laws governing the purchasesof products from private suppliers like Kodak. These laws are intended to ensure thatgovernmental entities obtain goods and services at competitive prices, often prices atleast as good as the supplier’s best price to a commercial customer. When sellingcompany products to government procurement agencies, employees must comply withall applicable laws.
Political Activities
The company will not make political contributions (including in-kind contributions suchas the use of corporate facilities or personnel) unless permitted by applicable law, andapproved in advance, and in writing, by the company’s Vice President of Public Affairs.
Since an employee’s political activities could be attributed to the company, employees
must, before engaging in any political activity, including fundraising activity, that occurs
during working hours or that involves the use of company facilities or personnel
services in connection with such political activity, obtain the prior written approval of
the company’s Vice President of Public Affairs.
Additional Information
For additional information regarding gifts to government employees, see Giving Gifts inthe section headed FAIR DEALING.

ANTI-CORRUPTION
Payments and Expenditures
Kodak employees are prohibited from making, offering or accepting payments or any
form of value, relating to an existing or potential business relationship with a customer,
where the payment or value is intended to influence an individual to make a businessdecision or determine the way in which business is conducted. If a payment is intended
as a means to obtain or retain the business of a customer, or where it is intended tosecure an improper advantage with respect to that customer, it may be a form of briberythat is prohibited under anti-corruption laws, such as the U.S. Foreign Corrupt Practices
Act (FCPA) or the UK Bribery Act.
Kodak may also be liable for the acts of third parties in this area. If a person or entitythat performs services for or on behalf of Kodak makes or offers an improper payment
for the purpose of obtaining or retaining business or an advantage for Kodak, thecompany may be liable. Third parties can include agents, distributors, channel partners,
contractors, suppliers and other parties, where their activities are directly in aid of thecompany’s business efforts, rather than simply as an independent provider of goods orservices.
12In some cases, payments to facilitate routine transactions, that are regular practice andrequired according to a law or regulation, may be acceptable. These payments are known
as “facilitation payments.” However, before any such payments are made or agreed
upon, Kodak employees must consult with regional Kodak attorneys or the Chief
Compliance Officer to ensure that the payments are permissible.
In addition, where local law, regulation, and government policies allow, legitimate andreasonable, less than US$100, expenditures that are intended to build upon or establish abusiness relationship with a customer, or to demonstrate products and services, may be
acceptable, where the expenses are in fact reasonable and consistent with industry
practices and are not lavish or excessive. For example, the provision of first class or air
travel, luxury accommodations, or meals or events that are not clearly connected tolegitimate business activity would not be considered “reasonable” expenses.
Reimbursement of customer expense exceeding US$100, where the customer is agovernment agency, must be pre-approved in writing by Kodak legal counsel and an
Executive Leadership Team member with a copy of the approval sent to the Chief
Compliance Officer. Additional guidance in this area is in the Fair Dealing section.
Engaging Agents and Channel Partners
Kodak has corporate policies governing the selection and use of Agents and Channel
Partners, which includes a vetting process and appropriate authorization.
Prior to engaging with an agent or Channel Partner, you must follow the company’s
policies and processes.
Kodak’s Mandatory Principles for all Kodak agents/channel partners, as applicable,
include:1. Kodak strictly prohibits agents and channel partners from making, offering or
accepting improper payments or any form of value, on behalf of Kodak.
2. No Kodak employee may engage an agent or channel partner on Kodak’s
behalf unless the engagement has been approved in accordance applicable
Kodak policies.
3. Kodak may not use agents or channel partners to do something that thecompany would not be permitted to do itself.
4. Kodak will provide reasonable compensation to agents consistent with thescope of work, geographic location, and level of expertise.
5. Kodak will accurately record in its books and records any payments madeand expenses reimbursed to agents and channel partners.
Anti-Corruption Laws
The anti-corruption laws that prohibit this conduct apply to both commercial (private)
and government (public) customers. Both the FCPA and UK Bribery Act laws are global
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in scope and are not limited in geography. In addition, Kodak employees must be awareof and comply with all local laws and restrictions that relate to doing business withpublic entities in the countries in which the employees work or in which they are sellinga Kodak product or service. Questions about laws and restrictions in this area should
be directed to regional Kodak attorneys or Kodak’s Chief Compliance Officer.

RIGHTS OF OTHERS
Fair Treatment of Employees
Each employee is entitled to be treated with dignity and respect by supervisors and byother employees. The company maintains a zero-tolerance policy for harassment or
intimidation because of race, color, religion (including religious dress and grooming
practices), sex, sexual orientation, gender, gender identity, gender expression, marital
status, pregnancy (including childbirth, breastfeeding and related medical conditions),
genetic characteristics or information, citizenship status, national origin, ancestry, age,physical or mental disability, medical condition, military or veteran status, or othercharacteristics protected by federal, state and/or local law, and for retaliation.
Health, Safety & Environmental Laws
All company facilities worldwide operate under the basic principle that health, safety,
and environmental responsibilities are fundamental to Kodak values. Employees are
responsible for ensuring that the company complies with the health, safety, andenvironmental laws of the countries where it does business.
Copyrights and Software
Employees must respect the valid copyrights of others, in works as diverse as printed
materials, films, sound and video recordings, art items, and computer software in any
media, as well as translations and adaptations of such works.
Employees are prohibited from duplicating, distributing, or incorporating in Kodak
works the copyrighted works of others, unless permissions are obtained. This includes
work in electronic as well as conventional format.
Software used by employees for company business must be covered by a license fromthe owner of the software.
Third-Party Confidential Information
The company frequently enters into written confidentiality agreements under which thecompany undertakes an obligation to protect confidential information obtained fromthird parties. If the third parties follow the contractual procedures for disclosing theirconfidential information, employees who become aware of such information must
maintain it in confidence, in accordance with the terms of the confidentiality agreement.
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No employee of Eastman Kodak Company will seek to obtain business informationfrom others through false pretense or illegal means.
Privacy
The company respects the privacy rights of its employees, customers, and suppliers.
Employees are responsible for complying with all relevant data privacy laws whenaccessing the personal data of others. Employees must also comply with the Corporate
Policy on Privacy of Personal Data. Section 9 of the Internal Control Standards
describes the requirements relating to Data Privacy Management.
Employees with any questions about privacy or the security of their personal
information should contact their local Human Resources office. Employees can also
contact a member of the Privacy Team at any time by sending an email toprivacy@kodak.com.
Due to various legal requirements that obligate Kodak to notify authorities about
security breaches, Kodak requires all employees and contractors to immediately reportprivacy incidents to their supervisors and WW-CISO-Mail@kodak.com.

MISCELLANEOUS
Corporate Responsibility Principles
The company maintains a set of Corporate Responsibility Principles that state its corebusiness-conduct philosophy and govern its relationship with third parties. Employees
should be generally familiar with the Corporate Responsibility Principles.
Company Disclosure
The company will provide full, fair, accurate, timely and understandable disclosure in
reports and documents the company files with or furnishes to the Securities andExchange Commission. The company’s other communications to the public will bemade in compliance with the rules and regulations of the Securities and Exchange
Commission.
Announcements, Press Releases, Media Advisories and Media Inquiries
All external communications including press releases, media advisories and social
media posts must be preapproved by the Chief Marketing Officer. If announcements
may involve material non-public information or financial information, the documents
and the timing of the related communications must be reviewed and approved by
Kodak’s General Counsel. The content and timing for all internal employee
communications involving material, non-public information must also be approved by
Kodak’s General Counsel. The Chief Marketing Officer must provide all team members
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with guidelines around issuing external and internal communications on an annual basis
and when there are changes to these procedures.
Employees contacted by the media to give a statement on the company’s behalf should
not discuss or disclose company business unless authorized to do so. If contacted by the
media for a company statement, employees should direct the media representative to theChief Marketing Officer.
Approval of Publications and Presentations
Employees must obtain advance approval from supervision of all copy, presentations
and proposed interview topics involving company-related information for delivery
outside the company. Any topics that may include material, nonpublic information must
be reviewed and approved by Kodak’s General Counsel.
Social Media
Kodak utilizes social media to promote and protect the company’s brand and to connect
with customers, key influencers, employees and potential talent. Kodak manages its
presence and message on social media through individual employees as authorized by
the Chief Marketing Officer to speak on its behalf. No other employees are authorized to
speak for the company. Employees may choose to engage in social media in theirpersonal capacities as discussed in the company’s Social Media Guidelines.
Third-Party Inquiries
Employees should immediately refer all inquiries from government officials and lawyers
representing third parties to a member of the Legal Department. Inquiries from lawenforcement agencies may also be referred to Corporate Security.
Volunteerism, Community Service, and Solicitation
The company encourages community volunteerism among its employees consistent withthe guidelines that support the Kodak Cares initiative. Employees are encouraged toconsult with the company’s Public Affairs office if there are any concerns about therelevance and appropriateness of specific volunteer activities.
Employees volunteering personal time should review the Kodak Cares Guidelines
applicable for their region. Employees must not commit company funds, products, inkind services, or other assets to outside organizations with which they are associatedwithout the approval of Public Affairs. Generally speaking, distribution by employees of
non-work-related literature, for any reason, is prohibited during work time in work
areas. However, local supervision may permit limited solicitation for non-profit
charitable organizations, or for fundraising in connection with school-age children’s
activities, in non-work areas.

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COMPLIANCE
Employees must comply with applicable law and company policy. When in doubt,
employees must seek clarification from their supervision or, if necessary, from Human
Resources, the Chief Compliance Officer, or the Legal Department.
Waivers
Situations will occasionally arise where the company deems it appropriate to waive
compliance by an employee of a policy in this Business Conduct Guide. For example, as
noted above under Conflicts of Interest, it may sometimes be appropriate to waive a
conflict of interest. All such waivers must be in writing. In addition, where thecompany’s Chief Executive Officer, Chief Financial Officer, Controller, or another
Section 16 officer seeks a waiver under the Business Conduct Guide, only the Kodak
Board of Directors or a Board Committee may grant the waiver, which must be promptly
disclosed as required by the rules and regulations of the New York Stock Exchange andthe Securities and Exchange Commission.
Violations
Violations of the company’s business conduct standards are grounds for disciplinary
action, up to and including discharge. Frequently, such violations also constituteviolations of law, which can subject the company to monetary damages and fines, andcan subject employees to fines and imprisonment.
ReportingAll employees benefit from an atmosphere of ethical and legal conduct. Employees who
suspect violations of law or company policy are expected to report such matters to theirsupervision or the following:
•
•
•
•

•

Human Resources;
Chief Compliance Officer / Director of Corporate Audit –585/726-3506;
Legal Department; orKodak Business Conduct Help Line -- (toll free) 866/480-6134 (international
employees can call collect at 704/943-1130). Employees in France should
call 0800 90 6923 to connect to the professional alert telephone line. Thisline was established to meet the CNIL Guidelines. The Business Conduct
Help Line is also accessible on-line athttps://www.kodakbusinessconducthelpline.com
Employees in Belgium and the Netherlands can call to connect to theprofessional alert Kodak Business Conduct Help Line in Belgium (0800-80768) and the Netherlands (0800-020-0394).
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Employees who wish to anonymously report concerns regarding questionableaccounting or auditing matters should report to the Kodak Business Conduct Help Line.
The Kodak Business Conduct Help Line will direct any reported issues to various
resources within the company, including those identified above. In addition, the Kodak
Business Conduct Help Line will report issues that involve certain members of senior
management directly to the Audit Committee of the Board of Directors.
For the avoidance of doubt, nothing in this Business Conduct Guide prevents Company
employees from reporting possible violations of federal law or regulation to any
governmental agency or entity, including but not limited to the Department of Justice,
the Securities and Exchange Commission, the Congress and any agency Inspector
General, or from making other disclosures that are protected under the whistleblower
provisions of federal law or regulation. Company employees do not need priorauthorization to make any such reports or disclosures and are not required to notify theCompany that they have made such reports or disclosures.
Confidentiality and Non-retaliation
Generally speaking, employees may report suspected violations confidentially. Where
confidentiality cannot be maintained (e.g., in situations involving the imminent threat ofserious harm or if required by local laws), every effort will be made to obtain theemployee’s consent to disclose his or her identity.
It is illegal for the company, and company personnel, to retaliate against an employee
acting in good faith that reports information or raises questions about possible violationsof law or company policy. Kodak does not tolerate acts of retaliation toward employees
who report suspected violations in good faith. Any employee engaging in retaliation is
subject to disciplinary action, up to and including termination.
Training and Certification
The company periodically requires employees to complete Business Conduct Guide
training and certify compliance with policies and procedures. Failure to complete thistraining may result in disciplinary action up to and including termination.

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REFERENCES
Link to the Business Conduct Guide:
http://policies.kodak.com/policies/BusinessConductGuide.htm
Link to Insider Trading Policy (select language):
Eastman Kodak Company Policies & Procedures Website
Link to Corporate Policies:
http://policies.kodak.com/

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