A. OUR BUSINESS CONDUCT AND ETHICS CODE

The Code helps us understand how ALDE’s values are put into practice every day.

ALDE’s Business Conduct and Ethics Code is built on our core values and highlights the principles that guide our business conduct. It provides questions and answers for situations that employee might encounter on the job and lists resources for help or further information.

However, the Code cannot address every possible workplace situation or list all of ALDE’s corporate policies and procedures. One needs to use it for guidance about our ethical standards and where to take employee questions or concerns.

When each of us follows the Code, we communicate our commitment to the values that have made ALDE admired both as a business partner and as a valued citizen of the global community. It is important to note, however, that violations of the Code, or the policies referred to in the Code, could result in disciplinary action, including termination of employment, or criminal prosecution or both.

Using the Code

• Read through the entire Code.
• Think about how the Code applies to employee’s job, and consider how employee might handle situations to avoid improper, illegal or unethical actions.
• If employee has questions, ask Supervisor or Immediate Manager or contact Human Resource representative.

Our Role and Responsibility

Each of us has a responsibility to speak up. All of us must obey the letter and the spirit of the law at all times, wherever we live or work. Each of the countries where our Company does business or will have business, has its own laws, regulations and customs. Sometimes there can be significant differences from one place to another and between regions within a single country. However, no matter where we work, we are all responsible for respecting all applicable laws and following the policies in our Code.

Code of Conduct

• We conduct our operations with honesty, integrity and openness, and with respect for the human rights and interests of our employees.
• We shall similarly respect the legitimate interests of those with whom we have relationships.

Obeying the Law

• ALDE as a Company and employees are required to comply with the laws and regulations of the countries in which we operate as of now and in future.

Employees

• ALDE is committed to a working environment that promotes diversity and equal opportunity and where there is mutual trust, respect for human rights and no discrimination.
• We will recruit, employ and promote employees on the sole basis of the qualifications and abilities needed for the work to be performed.
• We are committed to safe and healthy working conditions for all employees.
• We will provide employees with a total remuneration package that meets or exceeds the legal minimum standards or appropriate prevailing industry standards.
• We will not use any form of forced, compulsory, trafficked or child labour.
• We are committed to working with employees to develop and enhance each individual’s skills and capabilities.
• We respect the dignity of the individual and the right of employees to freedom of association and collective bargaining.
• We will maintain good communications with employees through company-based information and consultation procedures.
• We will ensure transparent, fair and confidential procedures for employees to raise concerns.

Consumers

• ALDE is committed to providing branded products and services which consistently offer value in terms of price and quality, and which are safe for their intended use. Products and services will be accurately and properly labelled, advertised and communicated.

Stakeholders

• ALDE will conduct its operations in accordance with internationally accepted principles of good corporate governance. We will provide timely, regular and reliable information on our activities, structure, financial situation and performance to all stakeholders.

Business Partners

• ALDE is committed to establishing mutually beneficial relations with our suppliers, customers and business partners. In our business dealings, we expect our partners to adhere to business principles consistent with our own.

Community Involvement

• ALDE strives to be a trusted corporate citizen and, as an integral part of society, to fulfil our responsibilities to the societies and communities in which we operate.

Public Activities

• ALDE will co-operate with governments and other organizations, both directly and through bodies such as trade associations, in the development of proposed legislation and other regulations which may affect legitimate business interests.
• ALDE neither supports political parties nor contributes to the funds of groups whose activities are calculated to promote party interests.

The Environment

• ALDE is committed to making continuous improvements in the management of our environmental impact and to the longer-term goal of developing a sustainable business.
• ALDE will work in partnership with others to promote environmental care, increase understanding of environmental issues and disseminate good practice.

Innovation

• In our scientific innovation to meet consumer needs we will respect the concerns of our consumers and of society.
• We will work on the basis of sound science, applying rigorous standards of product safety.

Competition

• ALDE believes in vigorous yet fair competition and supports the development of appropriate competition laws. ALDE as a Company and employees will conduct their operations in accordance with the principles of fair competition and all applicable regulations.

Business Integrity

• ALDE does not give or receive, whether directly or indirectly, bribes or other improper advantages for business or financial gain. No employee may offer, give or receive any gift or payment which is, or may be construed as being, a bribe. Any demand for, or offer of, a bribe must be rejected immediately and reported to management.
• ALDE accounting records and supporting documents must accurately describe and reflect the nature of the underlying transactions. No undisclosed or unrecorded account, fund or asset will be established or maintained.

Compliance – Monitoring – Reporting

• Compliance with these principles is an essential element in our business success. ALDE as a Company is responsible for ensuring these principles are applied throughout the organization.
• The Managing Director is responsible for implementing these principles and is supported in this by the appropriate Management Committee.
• Day-to-day responsibility is delegated to all senior management of the company. Assurance of compliance is given and monitored each year. Compliance is subject to review by the Managing Director and for financial and accounting issues to the Audit Committee.
• Any breach of the Code must be reported. There shall be no criticism for any loss of business resulting from adherence to these principles and other mandatory policies. Provision has been made for employees to be able to report in confidence and no employee will suffer as a consequence of doing so.

Authority

In addition to knowing and understanding this Code, each of us must understand the level of authority included in our job. We must all be careful to act within the limits of that authority.

Guidance

No code or manual can provide complete answers to all questions. In the end, we must rely on our good sense of what our Company’s high standards require. This includes knowing when to seek guidance on the proper course of action. We should expect timely and specific guidance from our supervisors, Managers, ALDE’s legal advisor, the Compliance coordinator or our local compliance coordinators.