CODE OF ETHICS - HARTWELL PLC

 

Preamble

The prosperity and development of a company depend to a great extent on the confidence it places in its social environment and inspires in its employees, customers, shareholders, partners and suppliers.

There asserts the Group's collective commitment to instil and develop this confidence. Its goal is to allow each individual, in his or her daily activities, to embrace the fundamental values upheld by its managers and employees: promoting the protection of its employees safeguarding its assets, promoting responsible citizenship, protecting its customers and promoting its products and services.

Respecting these values will thus help enhance the Group's positive reputation and its performance.

Code Of Ethics

The Code is a set of values and provisions which, though they cannot cover every possible circumstance, should help each person, according to his or her judgement and sense of responsibility, seek and take the correct decision in any given situation, in accordance with the laws and regulations applicable in the countries in which the Group operates and the social, societal and environmental commitments under taken.

1.Protection Of Employees

Respect for People is a fundamental value at Hartwell: each individual has a duty to contribute to the cohesion of the company by continuing professional relationships with both managers and colleagues that are open, loyal and respectful to all.

As such, the Group undertakes. not to discriminate for any reason whatsoever in working relationships and in particular.

• not to discriminate against persons on the grounds of gender or age, racial, social, cultural or national origin, union activity, sexual preference, disability, political opinion or religion;
• to recruit and promote its staff members according to their specific qualities and treat them with dignity without favouritism and with due respect to their private life.
• to take the necessary measures to ensure that working conditions protect the health and safety of employees;
• to take the necessary measures to ensure the safety and protection of individual
• to comply with laws and regulations governing the protection of employee's personal data

2. Protection From Tangible And Intangible Assets(2)

The safeguarding of the Group's assets is key to its prosperity, which is of benefit to all employees.

The Group's employees are duty-bound to help protect and preserve its assets against all forms of deterioration and damage, theft or misappropriation and, in particular, not to use them for personal reasons.

Respect For Confidentiality

One of the means by which intangible assets are protected is by implementing and respecting confidentiality. The Group's employees may hold information belonging to the Group that must remain confidential insofar as its disclosure maybe harmful to the Group's interests.

The information may relate to products, studies, technical projects, industrial data, commercial and financial plans, HR data, and elements that may involve intellectual property rights and know-how.

Each individual must ensure that this information is not circulated outside the company or even communicated to persons employed within the company who are not authorised to obtain it. The same applies to temporary workers, trainees and employees of service companies called upon to implement a service contract on one of the Group’s sites.

Protection And Enhancement Of The Group's Image

The quality of the Group's corporate image and the reputation of its products and services are necessary conditions for its longer term sustainability. The Group's employees, aware of their importance, must help maintain its positive reputation and to inform any disparaging act and from initiating or supporting any boycott action, negative communication, institutional campaign or any action unfavourable to the Group, of any kind, including when using public social media.

No external communication may be circulated by unauthorised persons. All communication must first be approved by the management, who must inform the competent authorities.

(2)'Assets ' in this instance refers not only to tangible property such as buildings, facilities, machines, vehicles, equipment, computers, IT systems & supplies, but intangible assets such as intellectual property, know-how and the sensitive data we handle.

3. Protection Of Customers

The confidence placed by the Group’s customers in its business and products is one of the company’s primary concerns.

The confidence of customers is acquired and maintained, in particular, through stringent respect for their rights, preservation of their interests and a constant concern to undertake only those commitments that can be upheld and respected

To this end, the Group and its employees undertake to:

• comply with all rules, processes and technical and environmental requirements that govern the safety and quality of the Group's products;
• only deliver to customers and consumers verified and honest information about the products and services delivered and their characteristics;
• comply with laws and regulations governing the protection of customers' and/or prospective customers' personal data

4. Protection Of Shareholders

Information Sharing

As with all forms of communication, whether pertaining to accounts, finance or management, within and outside the company, the integrity and sincerity of the information published are key to building the trust of its partners and the investors upon whom the Group calls to finance its growth

Each employee concerned must take responsibility for the integrity and sincerity of the information. Similarly, on an annual basis, the Senior Management, assisted by Compliance & Audit, ensures compliance with the principles and rules laid down by the Group in this area.

5. Promotion Of Responsible Citizenship

Political And Religious Activities

Employees who undertake political and/or religious activities shall do so outside the group, in a strictly private capacity, outside working hours and abstaining from any attempts at proselytizing. They shall under no circumstances invoke their employment by the Group. Moreover, the Group does not finance political parties or religious institutions.

Relationships With Third Parties

Economic Partners

The Group wishes to foster loyal and equitable relationships with its economic partners (members of the sales network, financial partners, suppliers, etc.)

Suppliers

All services must be subject to competitive tendering and an order or contract, as well as a regular inspection of their appropriateness and compliance with changes in competition according to the rules of the company’s purchasing policy. Suppliers must only be selected according to their performance, assessed on the basis of agreed criteria. This selection should also take into account ethical criteria applied internally by suppliers; in particular, the company shall ensure that its suppliers adhere to the fundamental rights of employees and the occupational hazard prevention policy in accordance with the principles laid down by Hartwell, and that they undertake to ensure that they are adhered to by their own suppliers.

Non-Commercial Partners

Public relations, sponsorship and all other forms of non-commercial relationships must not be subject to favouritism.

Recourse To Intermediaries

Having recourse to agents, representative negotiators, advisers and consultants, forms part of those acts which are necessary for the proper management of the Group.

The intervention of these intermediaries is only justified in this context after a rigorous selection procedure and provided that it gives rise to real services; it must be incorporated naturally into the legal framework.

Their remuneration must be transparent and proportional to the services stipulated in the contract.

Conflicts Of Interest

The Group's employees may be confronted with situations in which their personal interest, or the interests of natural persons or legal entities that they are associated with or in the management of which they are involved, may enter into conflict with the interests of the Group. It shall be their responsibility in such cases to declare the conflict of interest to their line manager.

Corruption And Disguised Rebates

No employee of the Group may, directly or indirectly, accept or require any bribe or advantage of any kind (gift invitation, etc.).

The Group must not offer or give any bribes or other advantages, nor agree to any requests for the same.

The Group must not grant any rebate concerning part of the payment for performance of a contract to the employees of their contracting party, nor have recourse to any other practices (subcontracting, orders, etc.) in order to make payments to officials, employees or relatives or associates of their contracting parties.

Paid Work

No paid work for an entity outside the Group can be accepted if it is in conflict with the interests of the Group. To avoid any difficulties, any full-time employee who wishes to conduct a professional activity outside the company must seek the prior approval of his or her manager

6. Corporate Social And Environmental Responsibility

Corporate Social Responsibility

Corporate Social Responsibility is the framework based upon which the company implements the concepts of sustainable development. The Group's employees undertake to incorporate social, environmental and economic concerns into their actions, taking the interests of all stakeholders into account (employees, customers, shareholders, suppliers, etc.).

Hartwell places five priority focus areas at the forefront of this voluntary undertaking:

• Diversity
• Customer Care
• Road safety
• Traditional Values
• Sustainable Mobility

Corporate Environmental Responsibility

The commitment of all of the Group's employees to take into consideration and seek to reduce the negative impact of their activities on the environment as a whole is key to ensuring the company's sustainable development.

The protection of the environment is thus a fundamental principle for the company; it is one that applies at all stages of its activities and is implemented by each employee.

7. Application Procedures

Employees should address any questions regarding the application of the principles defined in this Code to line managers; if they deem the information received to be incomplete and unsatisfactory, they may contact Compliance & Audit.

In addition to the standard routes (line manager, human resources department statutory auditors etc.) and for the financial, accounting, anti-corruption and anti-competition fields, if an employee has good grounds for doubt or suspicion concerning practices that may have a seriously adverse effect on the company's business or incur its liability in these fields, a whistleblowing procedure is available on the Intranet.

The Code is aimed at all employees of Hartwell PLC and its subsidiaries.