Microsoft Word - Auria Hourly Handbook November 2021 - FINA

position). In general, the best policy is to avoid any direct or indirect business connection with significant customers, suppliers or competitors of AURIA unless it is for Company business. No Employee shall participate in, or seek to influence, decisions regarding the selection of a particular vendor or supplier, if such Employee (or any member of his or her family living in the same household) has any financial interest or investment in such vendor or supplier, other than investments of less than 1% of any class of publicly-traded securities, investments in diversified mutual funds and other immaterial investments or financial interests. A conflict involving an AURIA executive officer (other than a President and Chief Executive Officer) will be reviewed by the Legal Department. A conflict involving a President and Chief Executive Officer or a member of the AURIA Board of Directors will be reviewed directly by the AURIA Board of Directors. Conflicts involving any other AURIA Employee will be reviewed by the Employee's supervisor or local human resources representative and the Company's Legal Department after full disclosure by the reporting Employee. In certain limited cases, activities that may raise potential conflicts of interest may be waived and permitted if they are determined not to be harmful to the Company. Such a determination will be made by the applicable parties noted above, depending on the circumstance. No Employee should accept gifts, credits, payments, services, excessive entertainment or anything else with a value of 100 Euros or its equivalent in the local currency or more from an actual or potential competitor, supplier or customer. Permitting a supplier's or customer's Employee to pick up the check at a meal or similar occasions is not inappropriate so long as AURIA business was discussed at arms- length and there was no suggestion of undue or unfair influence. If a gift or other service or object with a value of 100 Euros or its equivalent in the local currency or more is offered to an Employee, such Employee should immediately report the offer to their supervisor or the Company's Legal Department as described in Section XIII. This will ensure that an appropriate response can be discussed with the offeror. However, please remember that local, state and federal laws, including the Foreign Corrupt Practices Act, often impose special rules on relations with government customers and suppliers which may differ from commercial relations. Payments for expenses of government representatives should be reviewed by the Company's Legal Department prior to incurring the expenses and making the payment. Conflicts of interest may not always be apparent, so if an Employee has a question, they should consult their supervisor, local human resources representative or the Company's Legal Department, who will assist in determining if there is a conflict and, if so, how to resolve it without compromising the Company's interests. Prompt and full disclosure is always the appropriate first step towards identifying and resolving any potential conflict of interest or problem. Any Employee who becomes aware of a conflict or potential conflict of interest should bring it to the attention of a supervisor, local human resources representative or the Company's Legal Department. Please consult the procedures described in Section XIV of this Code when confronted with a conflict or potential conflict of interest. Employees are responsible for doing their part to advance AURIA’s legitimate interests when the opportunities arise. Employees are prohibited from appropriating or taking for themselves personally (including for the benefit of family members or friends), or on someone else’s behalf, opportunities that are discovered through the use of Company assets, property, information or position without the consent of the Legal Department. No Employee may use AURIA assets, property, information, or position for improper personal gain (including for the gain of family members or friends), and no Employee may compete with AURIA directly or indirectly. IV. Corporate Opportunities

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