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Code of Conduct and Integrity (“The Code”)

Our Code was first passed and put into practice in 2009. It sets forth highest standards to promote honest and ethical conduct with all of SMARTRAC’s stakeholders, appropriate public disclosures and legal compliance. It is designed not only to prevent any violations of legal requirements but also to ensure that voluntary commitments are upheld. It is binding for all employees worldwide and covers among others conflicts of interest, gifts or entertainment, dealing with government officials, protecting privacy and confidentiality as well as fraud, dishonesty or criminal conduct. Our Code is supplemented by further policies on specific areas.

 

Our Code is reviewed continuously and updated as needed. It is part of SMARTRAC’s constant endeavor to ensure its commitment to lawful and ethical behavior.

 

SMARTRAC is also in the process of implementing a compliance management system at the moment, taking into account the various international compliance regulations. As part of this process SMARTRAC carries out Foreign Corrupt Practices Act and UK Bribery Act orientated due diligence procedures and trains its personnel accordingly. Therefore SMARTRAC is training on the contents of our Code and other compliance policies in face-to-face training sessions as well as in our Group-wide e-learning tools as part of its preventative provisions.