To safeguard the SigmaKalon reputation, we must not only conduct ourselves in accordance with high ethical standards but also be perceived to be acting ethically at all times.

The following Code of Conduct provides guidance to ensure that SigmaKalon employees maintain high standards in their ethical behaviour.

Safety, Health, Environment and Quality
SigmaKalon places safety, quality and the protection of health and the environment at the centre of its company objectives.

Every employee is responsible for ensuring that its involvement in the Group's activities is carried out in full compliance with the SigmaKalon Group Charter for health, safety, quality and environmental protection.

Every employee must observe the provision of the Charter at all times and act in the best interest of the safety of both themselves and other employees.

Respect for employees
SigmaKalon will respect the human rights of its employees and will treat them with respect.

The relationships between all employees shall be based on integrity and mutual respect.

Each employee is expected to be loyal, to be attentive to the quality of their individual relations with their colleagues and to abstain from any act of discrimination.

Open and honest relations with customers, suppliers and business partners
SigmaKalon deals openly and honestly with its customers, suppliers and business partners.

Every employee's interaction with customers, suppliers and business partners shall be fair, honest and in strict compliance with contractual undertakings and applicable law and regulations. The giving or receiving of gifts or entertainment must remain within acceptable limits both regarding to what is customary and with reference to any anti-corruption legislation and the SigmaKalon Group Management Standards.

In case of doubt, every employee must obtain the approval of a Group Management Board (GMB) member. In no case shall an employee solicit a gift or an invitation.

 

Integrity and fairness in all aspects of the business
SigmaKalon strives for integrity and fairness in all aspects of its business and expects the same in its relationships with all those with whom it does business.

Every employee may be faced with a situation in which their own personal interests or that of persons or entities with which they are close or have a link may conflict with that of the Group. The employee must in such a case, make his or her decision in good conscience. Taking into consideration the obligation of loyalty to the Group and, in case of doubt, consult a SigmaKalon Group Management Board Member.

Always comply with competition law
SigmaKalon's policy is always to comply with competition law and other trade regulatory law that affects its business. Everyone working within SigmaKalon, including directors, managers and all employees, are charged with the duty and responsibility of complying with this policy.

"Zero tolerance" of corruption
SigmaKalon applies a principle of "zero tolerance" towards corruption.

All employees must never make or receive any corrupt payment or any other form of bribery to obtain, retain or direct business, or to acquire any improper advantage. All business transactions and payments must be properly documented and auditable. In accordance with this principle of "zero tolerance", every employee is obliged to report suspicion or evidence of corruption committed by colleagues or others to a Group Management Board Member.

Quality of financial information
SigmaKalon will provide shareholders and other interested parties with appropriate and accurate financial information, in a timely and commonly agreed manner.

Every SigmaKalon employee who either has information which can have an impact on the financial statements of any group company or, who has direct or indirect responsibility for generating financial statements has a responsibility to ensure that transactions are recorded accurately and promptly.

SigmaKalon in society
SigmaKalon manages its activities to meet the requirements of all applicable laws and regulations in the countries where its activities are conducted. SigmaKalon will show respect to the traditions and cultures of the countries in which it is present. SigmaKalon does not make payments or contributions to political parties, organisations or their representatives or take part in party politics.

Every employee is required to keep any involvement in the political process separate from its roles and responsibilities as employee.

Measures to protect confidentiality and intellectual property
SigmaKalon protects the confidentiality of employee records.

Every employee is required to take the necessary measures to protect the confidentiality of any information acquired in the course of their employment. Employees must similarly respect rules concerning intellectual and industrial property.

Every employee is required to observe strict secrecy about the affairs of the Group and shall not improperly divulge trade secrets, technical information or information including the finances, forecasting, running, organisation, management, marketing and purchasing of the Group at any time, whether during or after their period of employment with the Group.

Other policies and procedures
This code is to be considered in combination with all other policies and procedures within SigmaKalon.

They exist to ensure that the business objectives of SigmaKalon are achieved in the proper manner. References to these policies and procedures can be found in the SigmaKalon Group Management Standards document.