Bordo Group has published Ethical Principles and Code of Business Conduct to instill ethical principles – having applied them in business processes since its inception – in its employees, suppliers, subcontractors, and all social stakeholders. This code of conduct serves as a guide for ensuring that all stakeholders apply the very same ethical values in business processes by embracing them, and for taking the necessary precautions when this is not followed.

Group’s Ethical Principles and Code of Business Conduct mainly involve:
• Pursuing public good,
• Compliance with laws and other regulations,
• Looking out for employee rights and work conditions,
• Interaction with business partners and social stakeholders,
• Striving for company rights and transparency.

Bordo Group is committed to responsible corporate behaviour, which includes high standards of business conduct with respect to all stakeholders in its relationships with employees, contractors, customers, consumers, shareholders, suppliers, governments, competitors and the local communities in which it operate.

1. Introduction
The purpose of this Code of Good Business Conduct (‘the Code’) is to ensure that employees and contractors across the Concern have a clear understanding of the principles and ethical values that the Company wants to run the busines now and in the future. It applies to all employees and contractors in all Bordo Group internationally including affiliates.

The target is due Corporate Governance, with transparency, consistency and same understanding across borders.

As it is not possible to anticipate every possible situation, the Code is broad and is not intended to replace more detailed policies and procedures. However, these basic principles and ethical values should serve as a guide to each person in his/her dealings with consumers, customers, suppliers, governments & regulators, shareholders, competitors, colleagues and others with whom the company has relationships.

The Code forms the core element of Bordo Group’s Corporate Responsibility Framework which comprises of a set of policies and control arrangements that govern how we want to act as a Concern and how the company interact with its stakeholders in conducting business.

Compliance with the Code is vital in maintaining and building the reputation of Bordo Group as a responsible and trustworthy business partner, employer, client, supplier and corporate citizen within the contexts that it operates.

2. Corporate Management Principles

A.Observence of Community Benefits

a. Sustainability and The Environment
Bordo Group is committed to moving its business towards greater sustainability across the economic, social and environmental dimensions of its activities. The Company believes that a more sustainable business will not only better fulfill its responsibilities to society and the planet, but also contribute to delivering consistently better consumer solutions and greater long term shareholder value.
Bordo Group actively avoids processes which may be against animal health and wellbeing.

b. Human Rights
Bordo Group believes that human rights are an absolute and universal standard. The Company subscribes to the United Nations Universal Declaration of Human Rights and the Convention on the Rights of the Child.

B. Compliance with Laws and Other Regulations
a. Compliance with Laws, Regulations and Company Policies
Bordo Group respects, observes and strictly abides by the laws®ulations of countries that it operates in.
Bordo Group vehemently condemns any illegal activity of any kind or nature, disapproves any kind of non-legal structure/business and/or act, and will gladly proactively cooperate with authorities to prevent any such acts. All must be aware of and observe all laws and regulations governing the activities.
Some specific areas of legal and regulatory attention include: health & safety; anti - bribery laws, employment and work place practices; protection of the environment; competition; and, the payment of taxes and social security. Compliance with the Company’s internal operating policies and procedures is of equal importance.

b. Regulatory Compliance
All are required to support the Company’s regulatory compliance obligations, which include the appropriate reporting of adverse events.

c. Competition Law
It is a Company policy that all Bordo Group companies and their employees and contractors comply with the competition, anti - trust and anti - monopoly laws of all countries in which they conduct business. Directors, managers and others with supervisory responsibility have a duty to ensure that all are aware of, and comply with this policy.
Bordo Group promotes free competition, and competes actively in the marketplace, but will not use its market position to illegally obstruc the legitimate activity of a competitor.

d. Anti – Bribery
It is a Company policy that Bordo Group companies and their employees and contractors comply with the anti- bribery/anti- corruption laws of the countries in which they conduct business. Directors, managers and others with supervisory responsibility have a duty to ensure that employees and contractors under their supervision are aware of and comply with this policy.

C. Employee Rights and Observance of the Working Environment a. Working Conditions
The company believes the human rights at work of its employees and contractors are an absolute and universal requirement. Bordo Group subscribes to the International Labour Organisation’s (ILO) Fundamental Conventions; and OECD’s applicable guidelines.

b. Equal opportunity / No Discrimination
In employment related matters (access to training and promotion, transfers, employment termination, discipline, compensation and benefits,recruitment, etc.), decisions are made on the basis of merit, performance record and abilities needed for the work to be undertaken.
The Company is committed to equal opportunity at work; colleagues should not engage in or support discrimination based on race, colour, language, national origin, religion, disability, gender, marital status, affiliation, age, etc.

c. Working Environment and Occupational Health & Safety & Security
The company is committed to providing a safe and healthy working environment and to assuring, so far as is reasonably practicable, the health, safety and welfare at work (whether on the road or within premises) of its colleagues.

d. Colleague Communication
The company is committed to providing timely and effective communication with its colleagues/employees to show the importance and value it gives to them.

e. Privacy
Bordo Group respects the privacy of its employees, contractors and it will exercise appropriate and due care to legally ensure that sensitive personal is not publicly disclosed.

D. Communication with Partners and Share Holders
a. Conflicts of Interest
Employees and contractors must avoid situations where their personal interests might, or might appear to be, in conflict with the interests of the Company. In particular, employees may not exploit knowledge or information gained from employment within the company or take advantage of a corporate opportunity in order to obtain a personal gain or benefit for themselves, family members or any other connected person.
Any situation which gives rise, or might give rise to a conflict of interest should be disclosed as soon as it arises and, where required, written authority to proceed should be sought from the company.
Examples of situations where conflicts of interest may arise and the principles that should be applied include, but are not limited to, the following:

Outside engagements
Employees of the company should not undertake any other business or profession, be an employee or agent of any other company, or have any financial interest in any other business or profession, other than: non - executive positions approved by the Company; community voluntary activities; and, bona fide investment holdings in entities that are not direct competitors of the company. Any exceptions to this must be approved by the company prior.

Dealings with related parties
Employees and contractors should not enter into any business dealings on behalf of the company with a family member or any other connected person with whom business dealings may result in a potential conflict of interest without first disclosing this to the company and obtaining approval.

Gifts, dinners and entertainment
Employees and contractors of the Company must ensure that they deal with customers, suppliers and other business relationships in a way that avoids their independent judgement on behalf of the Company being influenced by personal advantage, or any appearance or even implication that this may be the case.
As a rule of thumb for guidance, a ballpark amount of 50Euro is a limit for assesment for what may be a gift (incl. travel to visit locations and alike) and/or entertainment – both for receiving and giving. Anti-bribery terms also apply.
In any case, it is expected that at least Deputy GM level is informed for receiving any such gift prior. Preferably the partner companies should be made aware of the policy proactively and prevent reception at the root. Likewise, for gifts to be given also, at least the same level of information/approval is required to assure that the gift is meant to be of symbolic nature, and not to offend.

b. Suppliers and their Contractors
The Company is committed to proactively encouraging its suppliers (service as well as goods) and contractors to demonstrate responsible business behaviour and likewise reciprocal high standards of business conduct.

c. Quality and Service
Bordo Group is genetically committed to delivering only the highest standards of service (with technology and spirit), with the corresponding quality.

d. Ethical Business Conduct and Fair Dealing
All must accept responsibility for maintaining and enhancing the Company reputation for integrity and fairness in its business dealings. In its everyday business transactions the Company must be seen to be dealing even-handedly and honestly with all its stakeholders.

E. Observence of Corporate Rights and Tranparency
a. Protecting Company Assets
Employees and contractors are responsible for the proper use, the protection and the maintaining of company assets whether on the road or still. Moreover, Company assets may only be used in relation to the Company’s business.

b. Authority Matrix
The existence of an agreed authority matrix is a requirement for an effective financial and operational control environment. All business units are required to establish and maintain appropriate levels of authority to cover all items of asset value / expenditure and all transactions which need to be subject to management approval.

c. Integrity of company financial records
The books and records of the Company must accurately reflect the true nature of the business, and the underlying transactions and no undisclosed or unrecorded liabilities or assets shall be established or maintained. Books and records must be maintained in all respects according to law and the accounting principles, policies and procedures that the Company has adopted.

d. Protecting confidential information
Employees and contractors must ensure that confidential information is preserved and protected. Confidential information is that which is not generally known outside the organisation and either gives or could give the Company a competitive advantage or disadvantage, or could lead to the loss of existing competitive advantage, if became known to others. This kind of information may not be revealed to anyone outside of the organisation unless an appropriate confidentiality agreement is in place and is necessary for business purposes.
Employees and contractors are required to respect these confidentiality provisions even after their employment with the Company comes to an end.

3. Compliance with this Code
All employees and contractors are required to comply with this Code of Good Business Conduct and are personally responsible for doing so. Thus, the Company will make every effort to make sure this is read and understood.

Employees and contractors must comply with any rules set out in this Code of Conduct. Breach of any of the principles within the Code may result in disciplinary action, and a serious breach such as if an employee or contractor is found to be in wanton abuse of the code and their actions cause reputational risk or damage and/or financial loss to the business may amount to gross misconduct, which may result in summary dismissal and contract cessation.

Bordo Group reserves the right to seek redress and damages from the individual(s) who has been found to have breached the code of conduct, irrespective of the position and location the individual(s) might hold, in or out of the company, at the time the breach of th is Code comes to light.

In fact, Employees and Contractors at all levels will be required to certify, annually, that they understand the code and that they (and those they supervise who do not have a Company email address) are in full compliance with this Code for the operations for which they have responsibility.

On an annual basis, by Internal Audit, the findings of this certification will be monitored by Internal Audit Department. Those who do not have a Company email address will have the Code communicated to them.

Those that supervise these colleague groups will be required to sign that these groups are in full compliance with the code.

Bordo Group has in place a confidential “whistle blower” policy and process to encourage the reporting of any non - compliance with this Code of Good Business Conduct. If in any doubt, employees and contractors can obtain full information on this process from the local Human Resources and Legal departments.

4. Violation
Violation of this policy may subject the individual to disciplinary action, including dismissal and cessation of contract. Therefore, employees and contractors MUST read and understand
the Company’s Code of Good Business Conduct and associated documents and policies.

5. This Code of Good Business Conduct comprises of seven (incl. this one) pages.
6. This Code of Good Business Conduct (which is a compilation of already existing policies, values and codes) is valid immediately on circulation.