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Our company is committed to conducting all affairs lawfully and always acting with integrity. This commitment extends throughout our global organization, no matter where in the world we do business. Our employees have a responsibility and are expected to hold themselves to the highest legal and ethical standards. This commitment to integrity and lawfulness requires sound judgment, critical thinking and the courage to do the right thing, even if that means the loss of a business opportunity. 

Our company measures itself not only by the results we achieve, but by how we achieve them. Following procedures, which are important and necessary, is not the end goal. Rather, we must always focus on improving our compliance results. Therefore, integrity must be a part of every decision we make, and the decisions we make must reflect a commitment to compliance with applicable laws and regulations.

All employees, directors and officers are expected to be familiar with this Code of Conduct (Code) and adhere to it. Except where applicable provisions of this Code are superseded by local laws or legal obligations, a violation of the Code may constitute just cause for disciplinary action, up to and including termination. Employees who violate this Code may also be subject to civil and/or criminal action, pursuant to any local, state or federal laws of any country in which the company conducts business.

This version of the Code supersedes all prior versions. It is an expectation of employment with the company that you are familiar with and adhere to this updated Code.

"By being principle based, empowering employees, becoming a preferred partner and continually transforming, we create virtuous cycles of mutual benefit. These not only maximize our contributions to others, and our results, they create opportunities for individual growth." 

—Charles Koch

How the Code Applies

This Code is intended to be consistent with all applicable laws and legal obligations, including those under collective bargaining (trade union) agreements. In the event of any inconsistency between this Code and any applicable law or collective bargaining agreement provision, we will comply first with the law or agreement.

For business locations outside the United States (U.S.), we will adhere to U.S. laws that have extraterritorial application and all laws of the host country. If you believe there are any inconsistencies between the Code and the laws of any host country, consult with Legal.

In addition to this Code, it is your responsibility to seek further information regarding the laws, standards, policies, procedures, practices, guidelines and work rules that may be applicable to your role.

This Code does not constitute a contract of employment or an assurance of continued employment for any individual.

Responsibilities as Employees

This Code is an important part of our company’s overall compliance and ethics program. It is a foundational tool for when you have questions or face dilemmas and where the right choice is not clear. However, the Code cannot cover every possible situation, nor can it specifically address all of the applicable laws at each of our locations. We expect and welcome questions about this Code, its interpretation or the law.  

You are never authorized to act illegally or unethically, even when doing so may seem to be in the best interest of the company or if a supervisor or any other employee has directed you to do so.

    • Always act in accordance with applicable laws, this Code, our Framework and other company standards, policies, procedures, practices, guidelines and work rules.
    • Avoid any activity that might have the appearance of being illegal or unethical.
    • Seek a full understanding of compliance requirements, risks and key controls that apply to your role. No one is expected to know every policy or standard word for word, but you should understand the policies and standards that apply to your role.
    • When you have questions, seek assistance from the many resources that are available to you. Promptly report potential or actual violations of a law, company policy or standard, or any request to violate a law, company policy or standard.
    • Promptly report any issue that you believe has not been appropriately resolved, even if it means raising it with another available resource.
    • Cooperate completely and honestly with company investigations.

    Retaliation, retribution or harassment against any employee who, in good faith, asks any question or raises any concern regarding ethical behavior or compliance responsibilities is against company policy and is prohibited.

    Responsibilities as Leaders

    Leaders have additional responsibilities to:

    • Lead by example and behave as a model for all employees.
    • Provide education and tools that promote employee understanding and compliance.
    • Create an ethical culture that promotes compliance, encourages employees to raise their questions and concerns, and prohibits retaliation.
    • Promptly address employee concerns of wrongdoing.
    • Evaluate and, as appropriate, recognize and reward employees who adhere to and promote legal compliance and ethical behavior.

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