Misconduct Policy

Company expects its employees and contingent workers to maintain the highest standards of professional conduct, including adhering to applicable laws, rules and regulations, as well as applicable internal policies, alerts and procedures. Company also expects employees and contingent workers (where required) to attend any required face-to-face training and complete any required e-learning within the timeframe specified. The objective of this policy is to establish consistent global standards for the escalation, handling and resolution of misconduct incidents.

In addition to this global policy, employees may also be subject to more detailed regional or local policies regarding misconduct incidents. Regional or local policies are supplements to this global policy. In the event of any discrepancy, the requirements of any applicable local law, rule or regulation in the jurisdiction of the employee takes precedence.

Company reserves the right to supplement, amend or withdraw this global policy at any time and depending on the circumstances of each case, to determine when and to what extent it will adhere to the provisions of this global policy. This global policy does not form part of the terms and conditions of employment of any Company employee or contingent worker. Accordingly, nothing in this policy shall oblige Company to undertake a disciplinary process strictly in accordance with the provisions herein nor shall it restrict Company’s right to undertake the disciplinary process differently, to terminate the employment of an employee or to take any other (or no) disciplinary action against an employee.