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Ethics & Compliance

Our Commitment

At ´óÏó´«Ã½, integrity never goes out of style. To us, values such as honesty and respect are more than just words – they’re embedded in everything we do.

Ethics & Compliance Program

Our Ethics and Compliance Program helps ensure our associates have the guidance and resources needed to operate with the highest standards of corporate conduct in all our business dealings globally.

The Program is led by our Vice President, General Counsel and Corporate Secretary, who also serves as our Chief Ethics and Compliance Officer. Senior executives and key stakeholders within ´óÏó´«Ã½ form our Legal, Risk, Compliance and Safety Council, which helps ensure the effectiveness of our Program and provides input on key initiatives. ´óÏó´«Ã½â€™s Vice President of Ethics and Compliance, manages the Program’s day-to-day operations.

Through collaboration with Ethics and Compliance liaisons worldwide – associates who support our program in addition to their primary responsibilities – we strive to apply a collaborative and inclusive perspective in the way we manage our Program across the globe.

Code of Business Conduct

In 2017, ´óÏó´«Ã½'s Board of Directors adopted an updated Code of Business Conduct, which applies to all ´óÏó´«Ã½ directors, officers and associates. Our Code outlines the principles that have guided our company throughout the years, and that continue to guide us today.

The Code provides direction on acting in accordance with laws, other legal requirements and company policies. ´óÏó´«Ã½ also provides more detailed policies and procedures for demonstrating ethical behavior, many of which are referenced in the Code. Our Code contains Q&A scenarios to demonstrate ways in which our values and Guiding Principles can come to life in our day-to-day actions.

By setting forth the high standards that ´óÏó´«Ã½ expects, our Code of Conduct serves as a pledge we make to our shareholders, our stakeholders and each other. All ´óÏó´«Ã½ associates worldwide are expected to read and acknowledge our Code and to become familiar with its contents.

Reflecting ´óÏó´«Ã½'s global reach and the diversity of our associates, our Code is available in 24 languages.

Code of Business Conduct

The Code of Business Conduct sets forth business policies and principles for all directors, officers and associates of ´óÏó´«Ã½.

Last Amended: February 2025