We conduct our business in an open, honest, ethical and principled way and we maintain a comprehensive set of compliance policies and procedures in support of our Code of Ethics and Business Conduct. These are reviewed at least annually to ensure they remain current and effective.  In the case of our anti-bribery efforts, they comprise part of our procedures for compliance with applicable laws.

Employees receive mandatory training – both new hires and at regular intervals for all employees – in order to maintain a respectful workplace, prevent bribery and protect personal and company data. Mandatory periodic training covers key topics in depth, such as competition law and records management, which is supplemented by in-person training for higher-risk roles.

We encourage reporting of violations – with an anonymous reporting option – and we prohibit retaliation against anyone who believes and reports a potential violation.

We remain diligent in our ongoing efforts to ensure compliance with applicable bribery and sanctions laws and to mitigate bribery risks. We continue to monitor and assess the implementation of our anti-bribery requirements.