SPS-Europe Code of Conduct

- CODE OF CONDUCT-

SPS-EUROPE B.V.

This Code of Conduct applies to SPS-Europe B.V. and its subsidiaries (hereafter: “SPS”). The Code of Conduct describes ethical rules and values that should guide employees at all levels and in all actions.

SPS, its management and its personnel agrees to adhere to the following principles:

• We strive to act with honesty, fairness and integrity and to obey the laws and regulations of the countries where we do business;
• We treat our employees with respect: we emphasize personal integrity, respect human rights, are committed to equal opportunity and to maintain a safe, secure and healthy workplace. It is against our policy to use forced or child labour;
• We are committed to the continuation of free enterprise: we recognize the importance of laws preventing trade restraints and unfair or unethical business practices. In our business dealings we will avoid unfair or deceptive practice and treat all customers and suppliers honestly, fairly and objectively;
• Our business decisions are based on merit. We will not engage in corruption or bribery. Gifts given to or received from customers or suppliers may never influence business decisions. Any gift must be nominal in value and frequency and approved by the management of SPS.
• It is our policy to provide employees with a drug-free and safe workplace. We will not tolerate violence, intimidation or threats of any nature. It is the responsibility of each employee to follow company policies and procedures related to workplace health and safety;
• We are committed to being environmentally responsible. We encourage conservation, recycling and energy reduction programs. We will follow applicable environmental laws and regulations in the countries where we operate;
• SPS employees will not risk conflicts of interest. They will not compete with SPS or let their business decisions be influenced by personal or other interests;
• Employees of SPS will protect confidential information of SPS and its business partners;
• Employees of SPS will use SPS property or company assets for the intended business purposes. SPS reserves the right to monitor the use of company assets (incl. Internet use, e-mails, etc) in order to avoid abuse;
• SPS encourages its employees to report on any conduct or situation that he/she believes conflicts with this Code or violates a local law. SPS is committed to reviewing any report made in good faith in a prompt and effective manner. Every employee is required to fully cooperate with any inquiry resulting from any reported conduct or situation. SPS will protect the rights of the individuals who report these issues;
• All employees are expected to display responsible and ethical behaviour, to follow this Code consistently and to act with integrity.