Decision-Making Guidelines for Ethical

Leaders, by virtue of their positions of authority, must be ethical role models for all employees.

An important part of a leader’s responsibility is to exemplify our corporate values and exhibit the highest standards of integrity

Recognizing ethical issues and doing the right thing in all Group business activities is your responsibility. When engaging in business activities for the ANSA McAL Group, consider the following:

What feels right or wrong about the planned action?

Is the planned action consistent with the Code and Company policies?

How will the planned action appear to your manager, Company executives, the Board, or the general public?

Would another person’s input help to evaluate the planned action?

Compliance with Code of Ethics & Conduct, Relevant Laws and Regulations

As members of the ANSA McAL team, we all have a personal responsibility to uphold and ensure the letter and spirit of our Code every single day. It is important that you are aware of and never violate relevant laws and regulations.

Violating relevant laws, regulations, or this Code, or encouraging others to do so, exposes the Group to risk, including risk to its reputation, and therefore may result in disciplinary action up to and including termination of employment.

You should understand that violations of laws or regulations may also result in legal proceedings and penalties including, in some circumstances, civil and criminal penalties that could affect you personally in addition to a risk of adverse consequences to the ANSA McAL Group. You should also be alert to changes in the law or new requirements that may affect your business unit.

Investigations Process of Code Violations

Once a report is received, the Group Performance Audit Team will investigate it promptly, thoroughly, fairly and confidentially. The Group Performance Audit Team expects all employees to cooperate in investigations fully and candidly. Retaliation will not be tolerated against any team member who cooperates in investigations.

Team members and leaders should not interfere in internal investigations or engage in their own fact-finding. Team members and others involved in internal investigations will be treated with dignity and respect.

After an investigation is completed, appropriate disciplinary and other corrective action will be taken when warranted by the facts. The Group Performance Audit Team may, in appropriate cases and subject to applicable local law, notify government authorities and cooperate with any resulting prosecution or other government action.

In addition, when legally required or otherwise appropriate, the Group Performance Audit Team will report compliance violations in a timely manner to applicable government authorities and cooperate with any resulting official proceedings.

The determination of whether and when to refer a matter to government authorities, or to report compliance violations, will be made by the Group Performance Audit Team after consultation with the Group Legal Department.

Anonymity & Confidentiality

When you make a report to the #SPEAKOUT hotline or to the Group Performance Audit Team, you may choose to remain anonymous, although you are encouraged to identify yourself to facilitate further communication.

If you make your identity known, the relevant personnel of the Company and investigators will take every reasonable precaution to keep your identity confidential, consistent with conducting a thorough and fair investigation.

To help maintain confidentiality, avoid discussing these issues, or any investigation, with other employees. Because we strive to maintain strict confidentiality in all investigations, we may not be able to inform you of the outcome of an investigation.

Making False Accusations

The Company will protect any employee who raises a concern honestly, but it is a violation of the Code to knowingly make a false accusation, lie to investigators, or interfere or refuse to cooperate with a Code investigation.

Honest reporting does not mean that you have to be right when you raise a concern; you just have to believe that the information you are providing is accurate.

Non-Retaliation Statement

We believe it is essential to create an environment in which individuals feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against them, that they will be taken seriously and that the matters will be investigated appropriately and as far as practicable be kept confidential.

The ANSA McAL Group values the help of employees who identify potential problems that the Company needs to address. Any employee who reports a violation in good faith will be treated with dignity and respect and will not be subjected to any form of discipline or retaliation for reporting.

Retaliation against anyone who provides information or otherwise assists in an investigation or proceeding regarding any conduct that the employee believes in good faith is prohibited and constitutes a violation of our Code of Ethics & Conduct and the ANSA McAL Group’s related policies.

An employee who has raised a concern honestly, or participated in an investigation, cannot be the basis for any adverse employment action arising out of their concern, including separation, demotion, suspension, loss of benefits, threats, harassment or discrimination.

If you work with someone who has raised a concern or provided information in an investigation, you are expected to continue to treat the person with courtesy and respect.

Definition of “Good Faith”

Acting in “good faith” means that you provide all of the information you have and believe you are giving a sincere and complete report. Individuals who take action against a person for making a report or participating in an investigation in good faith will be subject to disciplinary action, up to and including termination, as local law permits.

Self-Reporting

Nothing in this Code of Ethics & Conduct shall be construed as excusing any person from their own misconduct or protecting them from disciplinary action as a result of their self-reporting that misconduct. However, the fact that a person self-reported their own wrongdoing will be taken into consideration in determining an appropriate response.

Victims of Retaliation

Any person who reasonably believes that they have been subject to retaliation due to their disclosure of a legal or ethical compliance incident, or potential conflict of interest, should immediately inform their Manager or a Human Resources representative.

Manager Responsibilities

All ANSA McAL Group leaders must show a commitment to our values through their actions. They also must promote an environment where compliance is expected and ethical behaviour is the norm.

All ANSA McAL Group employees must comply with the Company’s values and principles. No one should ask an ANSA McAL Group employee to break the law, or go against the Company’s values, policies and procedures.

Leaders Serve as Ethical Role Models

Leaders, by virtue of their positions of authority, must be ethical role models for all employees. An important part of a leader’s responsibility is to exemplify our corporate values and exhibit the highest standards of integrity.

Leaders must communicate the seriousness of our Company’s expectations for ethical conduct and their own personal support of these expectations by holding everyone accountable for making sound ethical judgments.

Leaders must be alert to any situations or actions that may be unethical or potentially damaging to our reputation.

They must take prompt action to address such situations and be careful to avoid even the appearance of implicit approval.

Workplace Safety & Health

To support this commitment, employees are responsible for observing all safety and health rules, practices and laws that apply to their jobs, and for taking precautions necessary to protect themselves, their co-workers and visitors

Promoting Workplace Safety

Our Company strives to provide a safe and healthy workplace for employees, customers and visitors to its premises. All managers have responsibility for ensuring proper safety and health conditions for their employees. Management is committed to maintaining industry standards in all areas of employee safety and health, including industrial hygiene, ergonomics and safety.

To support this commitment, employees are responsible for observing all safety and health rules, practices and laws that apply to their jobs, and for taking precautions necessary to protect themselves, their co-workers and visitors. Employees are also responsible for immediately reporting accidents, injuries, occupational illnesses and unsafe practices or conditions to their supervisor.

Workplace Violence

Threats, acts of violence and physical intimidation are strictly prohibited. To preserve employee safety and security, unauthorised weapons, firearms, ammunition, explosives and incendiary devices are forbidden on our Company premises or in our Company vehicles.

Violence or threats of violence are strictly prohibited and, if confirmed, will be grounds for immediate termination. Examples of such conduct include harassing or threatening phone calls, email or written communication directed towards an employee or his or her friends/ family members, stalking, and the destruction of personal and/or Company assets.

Behaviour that threatens the safety of people or property, or has the potential to become violent, should be immediately reported to your supervisor, Security, HR, or the #SPEAKOUT Hotline.

Discrimination & Harassment Prevention

Each of us is responsible for creating a culture of trust and respect that promotes a positive work environment. This means treating one another with fairness and courtesy in all of our interactions in the workplace.

We are committed to the principles of equal employment opportunity, inclusion and respect. We prohibit discrimination in employment, employment-related decisions or in business dealings on the basis of an individual’s race, color, ancestry, age, sex, sexual orientation, religion, disability, ethnicity, national origin, marital status, pregnancy or any other status protected by law or local policy.

We also provide an environment free of discrimination to our associates, customers, members and suppliers.

We do not tolerate any form of harassment. Harassment is conduct which inappropriately or unreasonably interferes with work performance, diminishes the dignity of any person or creates an intimidating, hostile or otherwise offensive work environment.

Verbal, visual, or physical conduct of a sexual nature is not acceptable in the workplace and may be determined to be sexual harassment.

Harassment is prohibited regardless of whether it is welcome or unwelcome and regardless of whether the individuals involved are of the same or different sex, sexual orientation, race or other status. If you believe you are being harassed, or if you have witnessed harassment of a colleague, you must report this to your manager, another manager, or Human Resources.

Examples include:

Sexual advances, requests for sexual favours, sexually explicit language, off-color jokes, remarks about a person’s body or sexual activities, displaying sexually suggestive pictures or objects, suggestive looks, leering or suggestive communication in any form, inappropriate touching, both welcome and unwelcome.

We also prohibit other forms of harassment such as: Using slurs or negative stereotyping, Verbal kidding, teasing or joking; Intimidating acts, such as bullying or threatening; any other conduct that shows hostility toward, disrespect for or mistreatment of an individual based on the individual’s legally protected status.

The Group will act promptly and sensitively in investigating your concern and address the issue with the individuals involved. We will ensure confidential treatment of the allegations in order to protect all involved. The Group will not terminate, demote or otherwise discriminate against employees for reporting concerns in good faith.

Discrimination (with Equal Opportunity)

Having a diverse workforce, made up of team members who bring a wide variety of skills, abilities, experiences and perspectives, is something we celebrate as essential to our success. We are committed to the principles of equal employment opportunity, inclusion and respect.

All employment-related decisions must be based on Company needs, job requirements and individual qualifications. Always take full advantage of what our team members have to offer; listen and be inclusive.

We do not tolerate discrimination against anyone, team members, customers, business partners or other stakeholders, on the basis of race, colour, religion, national origin, sex (including pregnancy), age, disability, HIV status, sexual orientation, gender identity, marital status (past or present) military service or any other status protected by the laws or regulations in the locations where we operate.

We comply with laws regarding employment of immigrants and noncitizens and provide equal employment opportunity to everyone who is legally authorized to work in the applicable country.

An employee is expectede to report suspected discrimination right away and never retaliate against anyone who raises a good faith belief that unlawful discrimination has occurred.