“Acting with Integrity Around the Globe�

What Is Expected of Everyone

•  Comply with the Code of Conduct and the Law



•  Understand the Code of Conduct. Comply with the Code and the law wherever you are.



•  Use good judgment and avoid even the appearance of improper behavior.



•  Consider Your Actions, and Ask for Guidance. If ever in doubt about a course of conduct, ask yourself:
  
  
  •  Is it consistent with the Code of Conduct?
  
  
  •  Is it ethical?
  
  
  •  Is it legal?
  
  
  •  Will it reflect well on me and the Company?
  
  
  •  Would I want to read about it in the newspaper?
  
  
  
  If the answer is "No" to any of these questions, don't do it.



•  If you are still uncertain, ask for guidance. The Code of Conduct tries to capture many of the situations that employees will encounter, but cannot address every circumstance.



•  You can seek help from any of the following:


•  Your management



•  Company legal counsel



•  The Ethics & Compliance Officer

What Is Expected of Managers

•  Promote a Culture of Ethics and Compliance



•  Managers should at all times model appropriate conduct. As a manager, you should:



•  Ensure that the people you supervise understand their responsibilities under the Code of Conduct and other Company policies.


•  Take opportunities to discuss the Code and reinforce the importance of ethics and compliance with employees.


•  Create an environment where employees feel comfortable raising concerns.


•  Consider conduct in relation to the Code and other Company policies when evaluating employees.


•  Never encourage or direct employees to achieve business results at the expense of ethical conduct or compliance with the Code or the law.


•  Always act to stop violations of the Code or the law by those you supervise.




•  Respond to Questions and Concerns



•  If approached with a question or concern related to the Code of Conduct, listen carefully and give the employee your complete attention.


•  Ask for clarification and additional information.


•  Answer any questions if you can, but do not feel that you must give an immediate response.


•  Seek help if you need it. If an employee raises a concern that may require investigation under the Code of Conduct, contact Company legal counsel, senior executive personnel or the Ethics & Compliance Office.