Integrity We care about conducting our business in a fair and honest way. Code of Conduct | Safety | Integrity | Sustainability Business Partners | Downloads Integrity Key messages We compete in a fair and honest way We follow trade restrictions carefully We protect personal and confidential information We keep a clear line between business and personal interests We look after company property and use it appropriately We keep records in accordance with company policies We are alert to fraud and report suspicious activity We communicate in a professional way Integrity Our individual and collective behavior shapes the opinions of everyone we deal with. Because of this we act in a fair and honest way, complying with all laws and regulations wherever we operate. We all contribute to safeguarding the company's integrity and reputation. Fair competition We support free and fair competition. We aim to meet our customers’ needs faster, better and more distinctively than our competitors. So, we compete hard, but fairly, within the framework of competition laws. We maintain a policy of strict compliance with competition laws and our own rules. We do not enter into agreements and practices that would have a detrimental effect on competition, such as price-fixing, market allocation or abuse of dominant position. We promote our products in a fair and balanced way, with information that has been approved through our internal marketing review procedures. For further guidance, please refer to:Directives PortalCompetition Law Compliance Confidential information It is vital that we safeguard the company’s intellectual property and confidential information. This includes business strategies, technical know-how, financial information, customer lists and passwords. We protect confidential information against unauthorized disclosure to avoid destruction of the value of our assets and damage to our business operations and reputation. We also respect the intellectual property of others. We protect confidential information provided to us and only use it if we have obtained permission to do so. For further guidance, please refer to:Directives PortalIntellectual Property Honest business conduct We are committed to applying the highest ethical and legal standards. We conduct business fairly and with integrity. We don’t make, offer or authorize bribes or conduct any other form of unethical business practice. We do not make facilitation payments. We believe in competing on the merits of our products. We each have a responsibility to ensure that we base our dealings with business partners on objective decisions and are not influenced by gifts or entertainment. All gifts and entertainment given or received must be of modest value and appropriate to the business relationship. We seek approval for our actions. For further guidance, please refer to:Directives PortalAnti-Bribery, Gifts & Entertainment Trade controls We conduct international business in a world that has trade restrictions. Some countries have trade controls that restrict certain business transactions and movement of goods across borders. We comply with all trade controls applicable to our business, and provide accurate and truthful information about our business to Customs and other relevant authorities. For further guidance, please refer to:Directives PortalExport Control Personal data We are committed to protecting the personal data of employees, customers and business partners. We follow applicable laws and our own set of privacy rules which ensure that we treat personal data with a high level of care. We abide by these rules to ensure that we keep personal data for legitimate business purposes, and that we are clear about when and how we collect, use or share personal data. For further guidance, please refer to:Directives PortalProtection of Personal Data Avoiding conflicts of interest We each have a responsibility to make decisions in the company’s best interests, and we understand that our decisions at work must not be influenced by personal or private considerations. If a potential conflict may exist or may appear to exist, we discuss it with our line manager. We know we can take part in political and democratic processes in our personal capacity, as long as it does not conflict with our responsibilities at work. As a company, we do not provide financial or other support to political parties or political campaign efforts. For further guidance, please refer to:Directives PortalAvoiding Conflicts of Interest Company resources It is important to protect the company’s property, resources and information systems and ensure that they are kept secure at all times. We use these assets appropriately and responsibly, and protect them against loss, damage or misuse. We take care to use assets and resources for their intended business purpose. For further guidance, please refer to:Directives PortalCompany Resources Preventing fraud We have a set of comprehensive business controls in place to prevent fraud. We follow all internal approval processes and accounting and financial reporting principles to ensure that we properly record all transactions and to ensure that they are subject to review where appropriate. We abide by anti-money laundering laws to prevent any use of the company’s resources to conceal crimes. We are alert to threats of fraud, and we report any suspicious transactions or activity immediately. For further guidance, please refer to:Directives PortalFraud Trading in shares If we are aware of inside information, we do not deal in shares or securities in the company, either by ourselves or through someone else. Inside information is information which could have a significant impact on the price or value of our shares or securities if it was known outside the company. We also do not use such information to trade in the shares or securities of other companies or provide such information to anyone else unless allowed to by law and in accordance with our Share Dealing Code. Even if we do not have inside information, we may be prevented from dealing in shares or securities of the company by virtue of our position or through our relationship with the company. For further guidance, please refer to:Directives PortalInsider Information Record keeping We each have a duty to ensure that the records we keep related to our business activities are accurate, complete and up to date. Efficient and accurate records management is essential for the protection of the company’s business interests. We follow internal rules and guidelines when creating documents and ensure that we keep records safely or destroy them in accordance with relevant document retention policies. For further guidance, please refer to:Directives PortalRecords Keeping Proper communication We are committed to communicating in an open, factual and timely way, while following all legal and business obligations. To be sure that we comply with the law and protect the company’s interests, we refer media enquiries to people who are authorized to speak on behalf of the company. We each carefully consider our business communications, regardless of the method we use to communicate, and ensure that they meet high standards. We each use discretion and common sense when we use social media and follow the company’s guidelines at all times. For further guidance, please refer to:Directives PortalGlobal Communications Question A consultant I regularly work with has tickets to a sports event and invites me to come along. Can I accept? Answer Only if the arrangement is of modest value, is not intended to influence a business decision, and is approved by your manager. Question A friend is offering his company's services. Can I procure the services? Answer Only if there has been a fair and transparent procurement process and the decision is approved by management and not influenced by personal interests. Question I am at the border. A customs official offers me a fast-track entry in return for some cash. Is this okay? Answer No. This sounds like a facilitation payment, unless this is an official fast-track service for which you get an official receipt.