Microsoft Word - Auria Hourly Handbook December 2021 - FINA

Employees are expected to cooperate in internal investigations of misconduct. If an Employee observes or becomes aware of what he or she believes to be illegal, unethical or inappropriate behavior or has accounting or auditing concerns, the Employee should report the behavior (1) to his/her local supervisor, (2) to his/her local human resources representative or, (3) if the Employee feels it would be inappropriate to discuss the matter with the local supervisor or local human resources representative, to the Company's Legal Department as follows: by telephone, requesting the Executive Vice President, General Counsel and Corporate Secretary, at +352 267504 43; by facsimile: +352 267504 99; by e-mail to Legal@AURIAgroup.com; by mail, c/o AURIA Solutions Group, S.A. 73, Côte d’Eich, 1450 Luxembourg, Luxembourg, Attention: Executive Vice President, General Counsel and Corporate Secretary; or pursuant to any other procedures that may be posted from time to time on the Company's intranet website. We must all work to ensure prompt and consistent action against violations of this Code. However, in some situations it is difficult to determine if an action will result, or has resulted, in a violation of this Code. Since we cannot anticipate every situation that will arise, it is important that we have a way to address the applicability of this Code to particular situations. As a guideline, the following are the steps for Employees to keep in mind: ● Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question with which you are faced, and the alternatives you have. Use good judgment and common sense. If something appears to be unethical or improper, it may be. ● Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem or situation. ● Discuss the problem with your supervisor or your local human resources representative. This is the basic guidance for all situations. In many cases, your supervisor or your local human resources representative will be more knowledgeable about the situation and circumstances. Remember that it is the responsibility of your supervisor and your local human resources representative to help solve issues. ● When to report matters to the Company's Legal Department. In the case where it may not be appropriate to discuss an issue with your supervisor or your local human resources representative, or where this Code requires the approval of the Company's Legal Department, you may report the matter to the Company's Legal Department. Any report to the Company's Legal Department should be made to the General Counsel in the manner specified in Section XIII. ● You may report violations of this Code or accounting or auditing concerns without fear of retaliation. All submissions to the Company's Legal Department will be handled in a responsible manner and in compliance with applicable law. The Company does not permit retaliation of any kind against Employees for good faith reports of violations of this Code or accounting or auditing concerns. XIV. Compliance Procedures

● Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act.

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