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Code of Business Conduct

Introduction

The ENNOVI Code of Business Conduct (“Code”) is an important component of how we put our values into practice. It is founded upon our belief that, as a company, we are most successful when we show values of integrity, transparency, and ethical conduct in our workplace, with our partners, and in our community.

As a global leader in our industry, we hold all employees to high standards of ethics and integrity. Our continued success requires our commitment and discipline in ensuring that those high standards are embraced in all that we do, both in the workplace and in our community.

This Code outlines our values and expectations for our employees, including our directors and officers (“Company Personnel”). We expect Company Personnel to thoroughly read this document and understand it. It is here for you to incorporate into your work at ENNOVI. It is also in place so that you know the resources available if you need support, have a question, or wish to make a report regarding unethical conduct within our company.

Applicability

This Code applies to all Company Personnel.

Our Values

We are committed to acting with integrity–it is the right thing to do, protects our company, and allows us to fulfill our obligations to our stakeholders. We believe that how we achieve our success is equally as important as success itself.

Manager Responsibility When a Concern Is Reported to Them:

Managers must promptly address any concerns brought to their attention and, report them in accordance with our whistleblowing policy. If a manager neglects or fails to address an issue escalated by an employee, they may be subject to disciplinary action. If necessary, you can contact the Legal Department for assistance.

Failure to Comply

Company Personnel who violate or fail to comply with this Code or any matters addressed in this Code may face disciplinary action, including and up to termination of employment.

Retaliation:

We do not tolerate retaliation, harassment, or victimization against anyone who raises a concern in good faith about a violation of this Code or assists with an investigation. Any Company Personnel found to have retaliated shall be subject to disciplinary action, including and up to termination of employment.

Our Code of Business Conduct Is Organized into Four Sections:

  • Our Business
  • Our People
  • Our Assets
  • Our Community

I. Our Business

We are committed to complying with all laws and regulations, whether local, national, or regional, that apply to our company. Violations of these laws can result in significant harm to our company, including financial penalties, criminal proceedings, and damage to our business relationships and reputation. Therefore, we must be familiar with and follow the applicable laws and company policies.
  • Anti-Bribery and Anti-Corruption Laws

    Corruption, which encompasses giving, receiving, promising, or asking for anything of value with intent to influence an act or decision, obtain or retain business, or gain improper business advantage, is strictly prohibited. This prohibition applies to our interactions with counterparties, including private individuals, government officials, private companies, or public organizations.

    We require compliance with all anti-bribery and anti-corruption laws in all the countries we operate in. Violating these laws can have severe consequences for you and our company. If the only way to obtain the business is through corrupt means, we will choose to walk away from the deal.

    We have established an Anti-Bribery and Anti-Corruption Policy to underscore our commitment to combating corruption. You can access this policy via the ENNOVI Intranet.
  • Anti-Money Laundering

    Money laundering is the process by which the origin of money gained through illegal activities, such as terrorism, fraud, or bribery, is disguised, making it appear to come from legitimate sources. This typically involves a series of transactions designed to obscure the true source of the funds.

    You must remain vigilant and be aware of potential red flags, avoiding involvement in activities that raise suspicions of money laundering. Examples of red flags include receipt of unusually large cash payments without a clear reason or payments received from accounts that do not match the customer’s name or location. If you encounter any of these red flags, please report them to the Legal Department.

    Our company is committed to maintaining business relationships with reputable customers, suppliers, and other parties whose business activities and financial resources are legitimate.
  • Antitrust and Competition Laws

    Antitrust and competition laws play an important role in fostering and promoting free and fair competition among businesses, preventing abusive behavior in the market, and protecting consumer interests. These laws generally prohibit:
    • Arrangements with competitors that restrict trade in some way, for example, price fixing, bid rigging, and predatory pricing;
    • Abuse of intellectual property rights; or
    • Use of market power to unfairly disadvantage competitors.


    We are expected to follow all antitrust and competition laws, as violations of these laws can expose our company and employees to criminal penalties, large fines, and civil lawsuits. We must exercise caution when interacting with competitors, conducting benchmarking activities, or having information exchanges or collaborations with competitors in conferences or trade shows. Sensitive topics related to pricing, costs, and market segments should never be discussed. If you are faced with such a situation, promptly disengage yourself from the conversation, walk away, and report the incident to the Legal Department.

    We have established an Antitrust and Competition Law Compliance Policy, which provides detailed guidance for complying with these laws. You can access this policy via the ENNOVI Intranet.
  • Data Privacy and Protection

    The protection of natural persons in relation to the processing of personal data is regarded as a fundamental right. Protection of personal data is vital for safeguarding individuals’ privacy, ensuring compliance with relevant laws, and maintaining trust with our stakeholders. Many countries have laws governing the collection, storage, and use of personal data. In those instances where we are entrusted with the personal data of our employees and business partners, we have an obligation to use, process, and retain personal information only to the extent permitted by laws, regulations, and our company’s policies.

    We have established a Global Data Protection Policy to provide detailed guidance on the proper handling of personal data. You can access this policy via the ENNOVI Intranet.
  • Accuracy of Company and Public Records

    Our business records (including financial statements) must be accurate, fair, and complete. It allows us to explain the true nature of our company’s transaction and financial position, and enables the preparation of a fair and accurate financial statement.

    We have a duty to ensure the accuracy, completeness, and truthfulness of all records that are created, maintained, or reported in the course of our duties. This includes, but is not limited to, financial statements, expense reports, invoices, or any other documentation relevant to our business.

    Altering, falsifying, or intentionally misleading with regard to records, transactions, or any company-related information is strictly prohibited. If you want to know more about our Financial Policy and its related procedures and guidelines, please consult the Finance Department.
  • Trade Compliance

    Trade compliance is the process of ensuring that our international trade activities, including exporting and importing of goods, services, and technology, adhere to trade compliance laws and regulations. Some of the key trade compliance laws that apply to our business activities are:
    • Export controls are laws, regulations, and policies restricting the movement of goods, technologies, or software to certain parties, end uses, and places. These laws and regulations safeguard national security by preventing the development and proliferation of weapons of mass destruction, protecting sensitive technologies, and advancing national security policies.
    • Sanctions are restrictive measures designed to influence the behavior of certain countries, regions, organizations, or individuals by restricting their economic activities.
    • Import regulations are regulations that govern the entry of goods into a country and ensure compliance with local laws and standards.
    We have established a Global Trade Compliance Policy to provide more comprehensive guidance on the trade rules that apply to our company and the actions required to stay compliant. You can access this policy via the ENNOVI Intranet.

II. Our People

As a global organization with employees from all over the world, we value and celebrate the rich and diverse culture they bring to our company. We believe in a company atmosphere of fairness, equal opportunity, and mutual respect.
  • Non-Discrimination and Preventing Harassment

    We strive to provide equal opportunities for our employees and job applicants. Our employment decisions are based on business needs, qualifications, and the ability to perform the job effectively. We maintain a dignified work environment and respect for all our employees. Harassment or discrimination of any kind is strictly prohibited and will not be tolerated.

    To ensure our employees feel safe, we have established a mechanism to report incidents of harassment or discrimination. If you experience or witness any behavior that is harassing or violates our non-discrimination practices, we urge you to escalate the matter using our whistleblowing reporting channels.

    To know more about our company’s processes supporting diversity, equity, and inclusion, please consult with the Human Resources Department.
  • Conflicts of Interest

    We expect you to act in the best interest of our company and avoid situations where your personal interest may conflict with the interest of our company. Conflict of interest occurs when your personal, social, financial, or other activities or relationships interfere with your objectivity or loyalty to our company.

    You are required to tell your manager about any situation that presents the possibility of a conflict of interest. Undisclosed conflicts are prohibited and can result in disciplinary action. Once disclosed, we will assess the nature and extent of the conflict and may implement measures to mitigate the conflict, such as recusal from specific decisions, reassignment of responsibilities, or other appropriate measures.

    We have established a Conflict of Interest Policy to provide more detail on this topic. You can access this policy via the ENNOVI Intranet.
  • Safe and Healthy Work Environment

    Your safety and well-being and that of our visitors are of utmost importance to us. We are committed to providing a healthy work environment across all our offices and manufacturing facilities. We require all Company Personnel and visitors to adhere to our company’s workplace policies and procedures and to always put health and safety first.

    A safe and healthy work environment adds to our competitive advantage. It supports employee well-being by enhancing physical and mental health, and increasing engagement, productivity, and job satisfaction. Additionally, implementing thorough health and safety measures reduces accidents and injuries, safeguards employees while minimizing costs linked to absenteeism and medical expenses, thereby benefiting you and our company.

    If you encounter any unsafe conditions, unsafe behaviors, or violations of our workplace policies and procedures, it is expected that you promptly report them to your local management team or through our whistleblowing reporting channel.

III. Protecting Our Assets

  • Use of Company Assets

    We provide you with assets and resources to perform your job. These include but are not limited to phones, information systems, and software. You are responsible for taking care of these resources and using them for business purposes only. Personal use of company-issued devices (e.g., laptops or mobile phones) is permitted, provided such use is for a limited amount of time, does not interfere with your performance and does not violate any countries’ laws or our company policies.

    It is essential to use company assets in a manner consistent with security and confidentiality standards set by our company. Protecting sensitive company information is of utmost importance. Please be aware that our company reserves the right to monitor the use of its assets, especially information systems, to ensure compliance with our information security policies.

    We have established an Acceptable Usage Policy to provide more guidance on access control of information, information processing, and how to protect information assets. You may access this policy via the ENNOVI Intranet.
  • Intellectual Property and Confidential Information

    Our intellectual property and confidential information, as well as third-party confidential information provided to us in the course of our business relationship, are vital assets and must always be protected.

    Intellectual property includes our copyrights, patents, trademarks, brand names and logos, research and development, ideas, inventions, and trade secrets.

    Confidential information includes any information, regardless of form, relating to our company’s business, including but not limited to commercial, operational, technical, financial, and proprietary information, trade secrets, and know-how; confidential information received from third parties; and other company information not generally known to the public, where its improper disclosure would put our company at a competitive disadvantage or benefit our competitors. Examples are organizational structure, product plans, customer list, pricing proposals, marketing strategies, research and development data, unpatented inventions, business processes, and technology.

    You must not use Company Intellectual property and confidential information for your personal gain. You must also maintain the confidentiality of the information you are privy to, whether it belongs to our company, our partners, or third parties, except when disclosure is authorized by our Legal Department or by law.

    We have established a Policy Regulation of Confidential Information to provide more information on how to protect and handle confidential information. You may access this policy via the ENNOVI Intranet.

IV. Our Community

We abide by laws that apply to our business in everything we do. We are mindful of how we conduct ourselves and its impact on our work environment and surrounding community.
  • Environmental Protection

    Prioritizing environmental protection yields various benefits for our company and our Company Personnel. It nurtures a responsible corporate image, attracting eco-conscious individuals as employees, customers, and partners. Adhering to environmental regulations secures our company’s long-term viability and sustainability.

    Moreover, promoting resource conservation demonstrates responsibility and mitigates the impact of climate change. Ultimately, respecting the environment enhances our company’s success and fosters a contented and engaged workforce.

    We respect the environment and diligently follow all environmental laws wherever we conduct business. Beyond that, we strive to continuously improve our environmental impact through our company’s business practices to support long-term viability and sustainability.

    Fostering a positive sense of environmental commitment supports our responsible corporate image, and helps attract eco-conscious individuals as employees, customers, and partners. Moreover, promoting resource conservation demonstrates fiscal and environmental responsibility and helps to mitigate the impact of climate change on our communities, enhancing our company’s success and engaging like-minded stakeholders.

    We have established an Environmental, Health and Safety Policy which provides details of our environmental initiatives. You can access this policy via the ENNOVI Intranet.
  • Philanthropy

    Contributing in a positive way to community growth and development is important to us. We consider it a social responsibility and part of our overall business strategy.

    Our employees engage in local programs to help empower their communities through volunteer work and donations. We consider it a core value to participate in community initiatives and help those in need.
  • Working with Suppliers

    Our company’s success relies heavily on our relationships with our trusted suppliers. We believe in conducting fair and transparent procurement by carefully selecting suppliers based on the products and services that meet our needs. When making our decisions, we consider various factors such as reliability, ethical business practices, price, delivery, and quality.

    We hold our suppliers to a high standard of ethical conduct, and expect them to comply with all applicable laws and regulations, including anti-bribery and anti-corruption, labor and employment, and human rights laws. We will not tolerate any unethical practices, and any supplier found to engage in such behavior will be reviewed and may face termination of their business relationship with us.

    As a company committed to long-term sustainability and environmental stewardship, we prioritize suppliers who share our vision and dedication. We encourage our suppliers to adopt eco-friendly practices, reduce their environmental footprint, and comply with environmental regulations. Together, we can create a brighter, greener future for all.

    For more information, refer to our Supplier Code of Conduct, and Sustainable Procurement Guidelines. You can access these policies via the ENNOVI Intranet.
  • Political Contributions

    We are politically neutral and do not make political contributions to anyone or any organization anywhere we operate. You are free to support people and causes of your choice with your own time and resources.

    However, you may not make political contributions on behalf of our company or give the impression that our company is politically affiliated. Reach out to the Legal Department if there is any doubt or suspicion that such acts have been committed.

Any Questions?

If you have questions regarding anything in this Code or want to report a concern, please speak with your line manager or Human Resources representative. If that is not an option, you may contact any of the following representatives:
  • Members of the Board of Directors
  • Senior Leadership and Managers in the organization
  • Human Resources Department (for employment, benefits, and workplace issues)
  • Legal Department (Corp.Compliance@ennovi.com) (for interpretation of this Code and guidance about how to conduct business in a compliant manner)
  • Finance Department (for advice on this Code or company policies related to financial, company controls, and accounting matters)
  • Information Technology Department (for concerns regarding cybersecurity or data incidents, potential or actual system and data breaches and inadvertent disclosures) ipx.itsecurity@interplex.com
  • Quality Department (for concerns regarding quality, safety, and regulatory compliance of our products)
  • Procurement Department (for concerns regarding Supplier Management and Sustainable Procurement)
  • Corporate Sustainability and ESG Department (for concerns relating to environment, workplace security, safety and health) sustainability@ennovi.com
You may also report a concern through our Ethicspoint whistleblowing hotline or web intake site at:
https://ennovi.ethicspoint.com
corp.compliance@ennovi.com

Learn more about our COBC
Last updated: 24 January 2024
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