Our Companies

Maintaining Accurate Financial Records/ Internal Accounting Controls

Accurate and reliable records are crucial to our business. We are committed to maintaining accurate Company records and accounts in order to ensure legal and ethical business practices and to prevent fraudulent activities. We are responsible for helping ensure that the information we record, process, and analyze is accurate, and recorded in accordance with applicable legal or accounting principles. We also need to ensure that it is made secure and readily available to those with a need to know the information on a timely basis. Company records include payroll, timecards, travel and expense reports, booking information, e-mails, accounting and financial data, measurement and performance records, electronic data files, and all other records maintained in the ordinary course of our business. All Company records must be complete, accurate, and reliable in all material respects. There is never a reason to make false or misleading entries. Undisclosed or unrecorded funds, payments, or receipts are inconsistent with our business practices and are prohibited.

List of Unacceptable Activities:

Investors count on us to use and provide accurate information so they can make good decisions. The following are examples of activities not allowed:

Maintaining undisclosed or unrecorded funds or assets for any purpose.

Making, or asking others to make, false, misleading, or artificial entries on an expense report, time sheet or any other report.

Giving false quality or safety results.

Recording false sales or recording sales outside of the time period they actually occurred.

Understating or overstating known liabilities and assets.

Delaying the entry of items that should be current expenses.

Hiding the true nature of any transaction.

Providing inaccurate or misleading information for Company benefit programs.

Employee Financial Reporting Responsibilities

We must ensure that the accounting and financial records of our Company meet the highest standards of accuracy and completeness. Reporting accurate and complete information is an essential responsibility of each employee.

It is also your responsibility as an employee of our Company to make open and full disclosure to and cooperate fully with, outside accountants in connection with any audit or review of our Company’s financial statements. If you have reason to believe that any of our Company’s books and records are being maintained in a materially inaccurate or incomplete manner, you are required to report this immediately to your Managing Director and the Head of Group Performance Audit.

We rely on you to come forward if you feel that you are being pressured to prepare, alter, conceal or destroy documents in violation of our Company policy. In addition, you must report to any of the individuals mentioned above if you have any reason to believe that someone has made a misleading, incomplete, or false statement to an accountant, auditor, attorney or government official in connection with any investigation, audit, examination or filing with any government agency or regulatory body.

Protection of Company Assets & Resources

Our assets are the resources we use to conduct our business. Use Company assets for legitimate Company business and appropriately safeguard them including against cyber-related attack, theft, loss, waste or abuse. By protecting our assets, we protect our competitive advantage in the marketplace. You also have a responsibility to extend the same degree of care to assets entrusted to our Company by others.

Our assets include:

Physical assets, such as office furnishings, equipment and supplies.

Technology assets, such as computer hardware, software and information systems.

Financial assets, such as cash, securities and credit cards. Our Company’s name, its brand and our customer relationships.

Information assets, such as intellectual property, including information about products, services, systems and other data.

Company assets should be used only for the conduct of the Company’s business, except where otherwise provided by the Code or other Company policies. All physical and technology assets provided by the Company, whether used inside or outside the ANSA McAL Group workplace, are Company property and are provided for your business use.

Never sell, lend or give away Company assets, regardless of their condition or value, unless you are authorised to do so. Employees are allowed to use Company assets such as telephone and internet systems in a responsible and appropriate manner for business and occasional personal purposes.

Records Management

Our records are our corporate memory, providing evidence of actions and decisions and containing data and information critical to the continuity of our business. Records consist of all forms of information created or received by the ANSA McAL Group, whether originals or copies, regardless of media. Examples of Company records include paper documents, e-mails, electronic files stored on hard drive, disk or any other medium (CD, DVD, USB data storage devices, etc.) that contains information about our Company or our business activities.

All records are the property of the ANSA McAL Group and should be retained in accordance with Group Policy. We are responsible for properly labeling and carefully handling confidential, sensitive, and proprietary information and securing it when not in use. We do not destroy official Company documents or records before the retention time expires, but, do destroy documents when they no longer have useful business purpose.

Protection of Intellectual Property

Our intellectual property is among our most valuable assets. Intellectual property refers to creations of the human mind that are protected by various national laws and international treaties. Intellectual property includes copyrights, patents, trademarks, trade secrets, design rights, logos, services names, expertise, and other intangible industrial or commercial property. We must protect and, when appropriate, enforce our intellectual property rights. We also respect the intellectual property belonging to third parties. It is our policy to not knowingly infringe upon the intellectual property rights of others.

Communicating with External Parties

ANSA McAL Group employees are not authorized to speak with the media, investors, and analysts on behalf of our Company unless authorized by our Group Corporate Communications Manager. Unless authorized, do not give the impression that you are speaking on behalf of the ANSA McAL Group in any communication that may become public. This includes posts to online forums, social media sites, blogs, chat rooms, and bulletin boards. This policy also applies to comments to journalists about specific matters that relate to our businesses, as well as letters to the editor and endorsements of products or services.

Social Media

Social media is of growing importance in the marketplace. It enables us to learn from and share information with our stakeholders, as well as communicate with the public about our Company. In addition to following all Company policies, a general rule to remember when utilizing social media is to think about the effect of statements that you make. Keep in mind that these transmissions are permanent and easily transferable, and can affect our Company’s reputation and relationships with coworkers and customers.

To ensure professional handling, all media requests should be directed to the Corporate Communications Department which can be contacted through our public website at ansamcal.com/contact-us/

Your employment postings on internet sites and social media sites such as Facebook or Twitter may include the fact that you work for the ANSA McAL Group, your job title, a job description and your general office location. Be mindful not to disclose confidential and/or proprietary information, about our business, our suppliers or our customers.

ANSA McAL Group employees who choose to make use of social media or otherwise engage in online communications as an identifiable employee of ANSA McAL Group must comply with the Company Social Media Policy at all times and on all forms of social media.

Consistent with the Company’s approach to interacting with the traditional news media, only designated ANSA McAL Group employees are authorized to speak on behalf of the Company on social media. Employees who choose to speak on social media about the Company in any way must make it clear that they are an ANSA McAL Group employee, but not speaking on behalf of the Company or as an official Company representative.

All ANSA McAL Group-branded social media accounts (using “ANSA McAL Group” or any ANSA McAL Group business unit, department or product name as part of the account name or URL and/or using the ANSA McAL Group logo or portion of the logo in any way) must be approved in advance. It is against Company policy for any employee to create an ANSA McAL Group social media account outside of the outlined protocol in the ANSA McAL Group Social Media Policy.

Fraud

It is never acceptable to take any part, no matter how small your role, in any activity that involves theft, fraud, embezzlement, extortion or misappropriation of property. Your participation in a fraud occurs any time that you help conceal, alter, falsify or omit information in our records either for your benefit or at the direction of any others. You must refuse to engage in any questionable activities and must follow up any suspicions.

Closing Remarks

The ANSA McAL Code of Ethics and Conduct is a summary of our standards intended to drive integrity throughout the Group. Thank you for reading our Code and for your support in protecting our reputation, principles and values.