Microsoft Word - Auria Hourly Handbook December 2021 - FINA

AURIA SOLUTIONS GROUP, S.A.

Code of Business Conduct and Ethics

TABLE OF CONTENTS

I. Introduction................................................................................1 II. Compliance with Laws, Rules and Regulations .........................2 III. Conflicts of interest ....................................................................3 IV. Corporate Opportunities ...........................................................4 V. Competition and Fair Dealing ...................................................4 VI. Discrimination/Harassment/Anti-Retaliation...............................6 VII. Health and Safety/Employee Relations .....................................6 VIII. Record-Keeping.........................................................................7 IX. Confidentiality ............................................................................8 X. Protection and Proper Use of Company Assets ........................8 XI. Operating in the International Community .................................9 XII. Waivers of the Code of Business Conduct and Ethics...............10 XIII. Reporting any Illegal or Unethical Behavior or Accounting or Auditing Concerns ..............................................10 XIV. Compliance Procedures ...........................................................11 XV. Complaint Reporting Form.........................................................13

I. Introduction

AURIA Solutions Group, S.A. (together with its subsidiaries, "AURIA " or the "Company") has adopted this Code of Business Conduct and Ethics ("Code") , to reflect its commitment to appropriate business behavior and to managing all areas of ethical risk. This Code provides guidance to AURIA Employees to help them recognize and deal with ethical issues, report unethical or illegal conduct, and helps maintain a culture of integrity, honesty and accountability at AURIA. While this Code covers a wide range of business practices and procedures, it cannot possibly cover every issue that may arise. Rather, it establishes a basic set of principles to guide officers and Employees of the Company (each an "Employee", and collectively, the "Employees") . The Company may adopt more specific or restrictive practices and procedures with respect to particular activities or situations. All Employees of AURIA must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. In many instances, it will be appropriate for an Employee to discuss a situation that may arise under this Code with a supervisor or local human resources representative. Where it may not be appropriate to discuss an issue with either of these individuals, the Employee may contact the Company's Legal Department. The contact information for AURIA’s Legal Department is included in Section XIII of this Code. Each person who receives notification of a possible violation of this Code is required to act in accordance with this Code with respect to the situation. The Company believes this Code should be an evolving set of conduct and ethics standards, subject to refinement over time as circumstances warrant. Violation of the standards in this Code will be subject to disciplinary action, up to and including dismissal. Any waiver of this Code must be in accordance with

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