Compliance with Laws and Regulations
Our reputation is based on integrity and the respect of laws and regulations – both in our domestic countries and in export countries where we operate. It is our personal responsibility to know the laws, regulations and requirements relating to our job. Any breach of these laws may lead to civil and criminal prosecution. Activities which could involve the company in unlawful practices are prohibited.

 Commitment to Integrity
The Code of Ethics is the foundation stone of the company Business Ethics management. Its purpose is to define principles helping each of us to uphold our commitment to integrity in our daily work. Many of our activities are not governed by laws or regulations, in which case the principle of integrity must govern our conduct. It is our personal responsibility to apply this principle at all times. No performance objectives should be imposed or accepted if they can only be achieved by compromising our ethical standards.

Seeking guidance and reporting concerns
The Code of Ethics cannot cover every situation that we may face within our everyday role. We may find ourselves faced with a dilemma that we are not sure how to resolve. There are a number of ways that we can seek advice and support. We can contact our immediate manager, someone else in our management structure.

In addition, if after having received the necessary advice and/or clarifications mentioned above you have any reason to believe that a violation of the Code or other improper conduct has occurred, you are encouraged to report your concerns. Your concern will be treated seriously and fairly and your identity will remain confidential. We must not let any concerns go unresolved. No reprisal will be tolerated against employees making such a report in good faith.

Business Relationships

Customers
We are committed to treating all our customers honestly and fairly, whatever the size of their business and honouring our contractual commitments all the time. We must provide our customers with high-quality and safe products and services that meet their expectations. Quality and safety are core values for the company and we must comply with all control standards, including applicable laws and regulations as well as internal control procedures ensuring safe and high-quality products and services are delivered to our customers.

Suppliers
Suppliers deliver an important part of the value of our products and services and play an important role in customer satisfaction. We must promote ethical relationships with our suppliers and make sure that they are treated fairly and equally. In the selection of goods and services account must be taken of price, quality, performance, delivery and suitability.

Fair competition
We must always behave ethically when competing for customers’ business and when placing business with suppliers. Honesty and integrity clearly apply to our dealings with both customers and suppliers. This is especially true in the development phase of new business and in the negotiation phase of contracts. We must always comply with competition, antitrust and anti-corruption laws. We strictly adhere to the principles of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions as well as the United Nations Convention Against Corruption. It is our collective and individual responsibility to never engage the company in any form of corruption, whether public or private. 

Business advisors
We must never hire someone else to do anything that we cannot ethically or legally do ourselves. Engaging a third-party to indirectly make an improper payment violates anti-corruption laws. The selection of business advisors is guided by strict internal procedures.

Gifts and hospitality
The company aims to ensure that any business decision made by us, our customers, suppliers or other business partners is solely based on relevant criteria, such as competitiveness, performance and quality of products and services offered. Business courtesies, such as gifts and hospitality, given to or received from customers, suppliers or other business partners must reflect a normal courtesy of business and may not influence, or give the appearance of influencing, any business decision. Gifts and hospitality must not be given or received with a corrupt purpose anywhere in the world. Reasonable behaviour, common sense and prudence should always guide us in these situations and it is our duty to always comply with the laws and regulations of our domestic countries and those of other countries where we do business. Gifts in cash or any lavish hospitality are never permitted.

Money laundering
Money laundering is the faking of the origin of money coming from criminal activities. In compliance with all laws related to this matter, the company is committed to conducting business with reputable partners. All of us must be cautious with the way payments are made to detect any irregularities with partners who demonstrate suspicious behavior in their operations.

Facilitation payments
Facilitation payments are small unofficial payments to low-level public officials to speed up or obtain routine administrative processes. The company prohibits such facilitation payments in any country where we operate.

Conflicts of interest
All people involved in the company are required to avoid conflicts of interest between our obligations to the company and our personal affairs. Any relationship or activity which could or would influence, or appear to influence, performance of our duties to the company must be disclosed to our manager.

Sponsorship
Sponsorship is part of the marketing and communication strategy. It is authorised in compliance with applicable laws and regulations. Decisions to engage the company in any sponsorship is subject to prior approval and must be properly recorded.

Export Control
We must comply with all applicable laws and regulations when importing and exporting products, services and information. If we fail to observe export control laws, the company (and individuals) may face fines, criminal prosecution and loss of authorisation to export. We must be familiar with policies and procedures for handling goods, technology and data or providing services which may come into or go outside our country.

A Socially Responsible Company

Environment
The company has a responsibility to our global community to protect the environment. We must promote eco-efficiency in all of our business activities by striving to reduce the overall company carbon and global environmental footprint. Environmental protection and eco-efficiency will be conducted within the framework of Sustainable Development and supported by Sustainable Procurement practices. In addition, we must comply with all applicable laws and regulations wherever we do business. Lastly, all of us as employees are encouraged to contribute to this collective effort and more generally to adopt individual environment-friendly behaviours.

Donations
Donations to public-interest or privates organisations on behalf of the company may be permitted in compliance with all applicable laws and regulations. Decisions to engage the company in any donations to our communities or charities is subject to prior approval and must be properly recorded. 

Political contributions and activity
Political contributions are often subject to national laws and vary from country to country. the company policy is not to make contributions, financial or in kind, to political parties or organisations, or to individual politicians. The company respects the rights of its employees to participate as individuals in their community and civic affairs. This must be done at a personal level in their own time and at their own expense, consistent with applicable laws. Employees need to carefully separate their own political activities from the company activities and avoid any conflict of interest.