Contact Information for Reporting Channels Discrimination

We believe that new ideas from diverse perspectives lead to better business results. Diversity is simply good business. We embrace diversity of ethnicity, gender, generation, geography and thought. Different perspectives enable us to better understand the complexity of our customers’ needs and to deliver high-value solutions in innovative ways.

It is critical that every ANSA McAL Group employee feels valued and be provided with opportunities to contribute. If you believe your rights have been violated or if you have any other workplace concerns, you should consult your supervisor or another member of your management chain, or call your Human Resources representative directly.

If you do not receive a clear explanation or believe you may not receive an objective or adequate review of the issue from your supervisor or Human Resources, call the #SPEAKOUT hotline at 1833268-1505.

The ANSA McAL Group does not tolerate discrimination. We recognize that highly productive and diverse employees are essential to our success and should be given opportunities to flourish in a barrier-free, non-discriminatory environment. We will conduct all employment practices including activities relating to recruiting, hiring, benefits, leaves of absence, training, transfer, promotion, job assignments, compensation, corrective action and termination in a non-discriminatory manner.

Human Rights and Fair Labour

We are committed to upholding fundamental human rights and believe that all human beings around the world should be treated with dignity, fairness, and respect.

Substance Abuse/ Drug and Alcohol-Free Workplace

The ANSA McAL Group strives to maintain a workplace that is free from illegal and unauthorised use, possession, sale, or distribution of alcohol or controlled substances. Legal or illegal substances shall not be used in a manner that impairs a person’s performance of assigned tasks.

Drug Testing

Our Company reserves the right to have any employee tested if there is reasonable suspicion that he or she is under the influence of drugs or alcohol.

Employees must report if they are using prescription or nonprescription drugs that may impair alertness or judgment, or if they witness an employee impaired and, therefore, possibly jeopardizing the safety of others or ANSA McAL Group business interests.

We require that our suppliers and direct contractors demonstrate a serious commitment to the health and safety of their workers, and operate in compliance with human rights laws. The ANSA McAL Group does not use or condone the use of slave labour or human trafficking, denounces any degrading treatment of individuals or unsafe working condition.

We are committed to following all applicable labour laws and regulations.

Fair Dealing with Everyone

The ANSA McAL Group is committed to dealing fairly with its associates, customers, suppliers and competitors. Employees are expected to promote ANSA McAL Group products and services in a manner consistent with the customer’s expressed financial needs and goals and to provide sufficient information to allow customers to make informed decisions voluntarily and without any form of coercion or undue influence.

Employees are prohibited from taking unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice.

Data Privacy

Confidential (Non-Public) and Proprietary Information

In carrying out business, ANSA McAL Group employees, officers and directors often learn confidential or proprietary information about our Company, business partners and consumers. Such information may include business marketing and service plans, financial information, product architecture, source codes, engineering and manufacturing ideas, designs, customer lists, pricing strategies, to name a few. Employees, officers and directors must maintain the confidentiality of all confidential information so entrusted to them, except when disclosure is authorised or legally mandated. Unauthorised disclosure of such information can be harmful to the ANSA McAL Group or its business partners and consumers.

If you have a problem related to alcohol or drugs, you are encouraged to seek assistance from the Employee Assistance Program or other qualified professionals.

Employee Assistance Programs (EAP)

Alcohol and drug abuse can endanger the health, safety and security of our employees and our customers, adversely affect the quality and effectiveness of our Company operations and potentially harm other stakeholders.

No ANSA McAL Group employee or employee of a contractor may report to work or perform any job duties while under the influence of or impaired by alcohol or drugs. We encourage employees who may have an alcohol or drug problem to seek assistance through a local Employee Assistance Program (“EAP”).

Participation in a Company-sponsored EAP is optional unless an employee receives a mandatory referral to the EAP for reasons of alcohol or drug abuse. Employees who receive a mandatory referral must comply with the program designed by the EAP. Refusal to comply will be grounds for discipline up to and including termination of employment.

If the ANSA McAL Group proprietary information is to be given outside the Company, make sure a written confidentiality and nondisclosure agreement is prepared, and that proper controls are established to manage the flow of information. Seek assistance from the Group Legal Department to review and approve any confidentiality and nondisclosure agreements before execution by the parties involved.

Consumer/Third Party Personal Information

The ANSA McAL Group respects the privacy of all its customers, prospective customers, or other third parties. We must handle personal data responsibly in compliance with all applicable privacy laws and policies (including our records retention requirements). Personal data is information that can directly or indirectly identify an individual, such as name, contact information, financial information and health-related information. Employees who handle the personal data of others must do the following:

Act in accordance with applicable law.

Act in accordance with any relevant contractual obligations.

Collect, use and process such information only for legitimate business purposes.

Limit access to the information to those who have a legitimate business purpose for seeing the information.

Take care to prevent unauthorized disclosure.

Employee Information

The ANSA McAL Group also respects the privacy of its employees. Employee information includes employee medical and personnel records. Access to personal information is only authorized when there is a legitimate and lawful reason, and access is only granted to appropriate personnel. Requests for confidential employee information from anyone outside our Company under any circumstances must be approved in accordance with our policies. It is important to remember, however, that employees should have no expectation of privacy with regard to workplace communication, corrsepondence on Group provided devices, or any personal property brought onto the ANSA McAL Group premises or used for ANSA McAL Group business.

Proper Use and Protection of Electronic Communication

The ANSA McAL Group’s information technology and communications systems are vital to enable us to conduct our business and reach out to our consumers. If you have access to our information systems and computer networks, you are responsible for using the highest standards of behaviour in all of your usage and communications. When you access our networks from remote locations (for example, at home or from other non-Company locations), you are subject to the same standards of use as are employees who access our networks while on Company premises. The data transmitted, received and stored by or within those systems, such as telephones, personal computers, data storage units, email, or pagers, are valuable assets. They must be protected to ensure accessibility for business purposes, that our Company’s reputation is protected, and that we minimize the potential for legal risk. Limited personal use may be acceptable if it is authorized by your work location and does not interfere with your job responsibilities.

Safeguard

Privacy Laws

the following:

Passwords: You are responsible for your corporate credentials. Passwords must meet corporate standards and must be kept private, and therefore not shared, coded into programs or written down. IT Security must be informed in the event that a password is suspected of having been compromised. Do not share your passwords with anyone at any time.

Mobile Security: It is extremely important that you treat your mobile device like any other Corporate IT device. Mobile device security can be breached and infected just like a PC, laptop, etc. Never click links, download files, or execute programs on your mobile device unless it is required and you are certain of the source and legitimacy of the content. Always protect such items from loss, theft or damage.

Acceptable Usage: It is not permitted to use ANSA McAL Group information technology and communications systems (including email, instant messaging, the Internet or intranet) for activities that are harmful, unlawful, unethical, immoral or otherwise contrary to this Code.

Examples of Inappropriate Computer Use:

Never use electronic media to initiate, save, or send items that are hostile, harassing, offensive, threatening, or otherwise inappropriate.

Do not use electronic media to initiate, save, or send chain letters or other widespread non-business distributions.

Do not use electronic media to initiate or participate in any malicious, unauthorized, or fraudulent use of Company resources.

Think before you use ANSA McAL Group electronic media for non-business purposes and comply with the policies of your business unit.

Remember:

Providing Best Quality in Service, Products, Value to Customers

We are dedicated to quality and take personal pride in all the products and services we provide. Our intense, acute focus on the needs of our customers continuously drives us to improve. Our continued success depends on exceeding the expectations of our customers and standing behind everything we do.

Environmental Stewardship

We are committed to conducting business in an environmentally responsible manner and strive to improve our performance to benefit our employees, customers, communities, shareholders, and the environment. We use energy wisely and efficiently and employ technology to minimize any risk of environmental impact. Employees whose work affects environmental compliance must be completely familiar with the permits, laws, and regulations that apply to their work. All employees are responsible for making sure that ANSA McAL Group business is conducted in compliance with all applicable laws and in a way that is protective of the environment.