The Code of Conduct is approved by the board of directors of HOLOS – Soluções Avançadas em Tecnologias de Informação (“HOLOS” or the “Company”). The Code applies to Holos and its subsidiaries which are collectively defined as the “Holos Group” and applies to the Holos Group’s worldwide workforce. This code of conduct is based on Google’s Code of Conduct.

As a Holos Group workforce member, the communities in which we conduct our business operations are all affected by our actions, and benefit when we do the right thing. Without guiding principles, it is not easy to always know how to identify the right path to take, or, when we identify it, to follow it. That is why we need guiding principles.

Neither the Code nor any of the Principles, Practices or Procedures are intended to, and do not create any contractual rights enforceable against the Holos Group by any workforce member, shareholder, customer, supplier or other third party. They help each of us to know what is expected of us as workforce members to make sure we act knowingly and with integrity.

The Holos Code of Conduct is one of the ways we put Holos’s values into practice. It’s built around the recognition that everything we do in connection with our work at Holos will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical as well as aspirational reasons: Our commitment to standards helps us hire great people, build great products, and attract loyal users. Respect for our users, for the opportunity, and for each other are foundational to our success, and are something we need to support every day.

So please do read the Code and Holos’s values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, and to encourage others to incorporate, the principles of the Code and values into our work. And if you have a question or ever think that one of your fellow or the company as a whole may be falling short of our commitment, don’t be silent. We want – and need – to hear from you.

Who Must Follow Our Code?
We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Holos employees and Board members, we expect Holos contractors, consultants, and others who may be temporarily assigned to perform work or services for Holos to follow the Code in connection with their work for us. Failure of a Holos contractor, consultant, or other covered service provider to follow the Code can result in termination of their relationship with Holos.

What If I Have a Code-Related Question or Concern?
If you have a question or concern, don’t just sit there. You can contact your manager, your Human Resources representative, or Ethics & Compliance. You can also submit a question or raise a concern of a suspected violation of our Code or any other Holos policy through the Ethics & Compliance Helpline ( Finally, if you believe a violation of law has occurred, you can always raise that through the Ethics & Compliance helpline or with a government agency.

No Retaliation
Holos prohibits retaliation against any worker here at Holos who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact Ethics & Compliance.

I. Serve Our Users
Our users value Holos not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:

1. Integrity
Our reputation as a company that our users can trust is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All of our communications and other interactions with our users should increase their trust in us.

2. Usefulness
Our products, features, and services should make Holos more useful for all our users. We have many different types of users, from individuals to large businesses, but one guiding principle: “Is what we are offering useful?”

3. Privacy, Security, and Freedom of Expression
Always remember that we are asking users to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of users’ personal information, and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.

Holos is committed to advancing privacy and freedom of expression for our users around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content. Contact Ethics & Compliance if you have questions on implementing these standards in connection with what you do at Holos.

4. Responsiveness
Part of being useful and honest is being responsive: We recognize relevant user feedback when we see it, and we do something about it. We take pride in responding to communications from our users, whether questions, problems, or compliments. If something is broken, fix it.

5. Take Action
Any time you feel our users aren’t being well-served, don’t be bashful – let someone in the company know about it. Continually improving our products and services takes all of us, and we’re proud that Holos workers champion our users and take the initiative to step forward when the interests of our users are at stake.

II. Support Each Other
We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. Holos workers are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.

1. Equal Opportunity Employment
Employment here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

2. Harassment, Discrimination, and Bullying
Holos prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied or harassed by anyone at Holos, or by a Holos partner or vendor, we strongly encourage you to immediately report the incident to your supervisor, Human Resources (HR) or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to Human Resources. HR will promptly and thoroughly investigate any complaints and take appropriate action.

3. Drugs and Alcohol
Our position on substance abuse is simple: It is incompatible with the health and safety of our employees, and we don’t permit it. Consumption of alcohol is not banned at our offices, but use good judgment and never drink in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

4. Safe Workplace
We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring a weapon to work. If you become aware of a violation of this policy, you should report it to Human Resources immediately.

III. Avoid Conflicts of Interest
When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Holos or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of Holos.If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and Ethics & Compliance. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.

Below, we provide guidance in seven areas where conflicts of interest often arise:

1. Personal Investments
Avoid making personal investments in companies that are Holos competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Holos.

When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, Holos’s business, and what you do at Holos, including whether the company has a business relationship with Holos that you can influence, and the extent to which the company competes with Holos. You should also consider 1) any overlap between your specific role at Holos and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.

Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include Holos competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund’s investment activity.

2. Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business
Avoid accepting employment, advisory positions, or board seats with Holos competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm Holos. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your manager before accepting a board seat with any outside company. Holos board members and employees who are VP and above should also notify Ethics & Compliance. Finally, do not start your own business if it will compete with Holos.

3. Business Opportunities Found Through Work
Business opportunities discovered through your work here belong first to Holos, except as otherwise agreed to by Holos.

4. Inventions
Developing or helping to develop outside inventions that a) relate to Holos’s existing or reasonably anticipated products and services, b) relate to your position at Holos, or c) are developed using Holos corporate resources may create conflicts of interest and be subject to the provisions of Holos’s Confidential Information and other employment agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, consult Ethics & Compliance.

5. Friends and Relatives; Co-Worker Relationships
Avoid participating in management of or decision-making regarding potential or existing Holos business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.

To be clear, just because a relative, spouse/significant other, or close friend works at Holos or becomes a Holos competitor or business partner doesn’t mean there is a conflict of interest. However, if you are also involved in that Holos business relationship, it can be very sensitive. The right thing to do in that situation is to discuss the relationship with your manager and Ethics & Compliance.

Finally, romantic relationships between co-workers can, depending on the work roles and respective positions of the co-workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved.

6. Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, entertainment, and other business courtesies from a Holos competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant.

Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many Holos business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, and be aware that you may need to obtain manager approval.

Contact Ethics & Compliance if you have any questions. See the discussion of Anti-Bribery Laws in Section VII(4) for guidance on when it is appropriate to give gifts and business courtesies in the course of doing Holos business.

7. Use of Holos Products and Services
Avoiding potential conflicts of interest also means that you should not use Holos products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of Holos. For example, you should never approve Holos accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as a Holos worker to participate in or to generate a financial benefit for yourself or others. If you find yourself subject to a conflict of interest regarding the use of Holos’s products, services, tools, or information, discuss the situation with your manager or Ethics & Compliance.

IV. Preserve Confidentiality
We may get press attention around our innovations and our culture, and that will be fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential Holos material – we must also:
properly secure, label, and (when appropriate) dispose of Confidential Holos material;
safeguard Confidential information that Holos receives from others under non-disclosure agreements;
take steps to keep our trade secrets and other confidential intellectual property secret.

1. Confidential Information
Make sure that information that is classified as “Need to Know” or “Confidential” in Holos’s Data Classification Guidelines is handled in accordance with those Guidelines and Holos’s Data Security Policy. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, Holos policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.

There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information.. If you’re in a gray area, be cautious in what advice or insight you provide to others or, better yet, ask for guidance from Ethics & Compliance.

And don’t forget about pictures you and your guests take at Holos – it is up to you to be sure that those pictures don’t disclose confidential information.

Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.

2. Holos Partners
Just as you are careful not to disclose confidential Holos information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Holos’ board. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.

3. Competitors/Former Employers
We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any Holos worker former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it. Should you happen to come into possession of a competitor’s confidential information, contact your manager immediately.

4. Outside Communications
You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of Holos unless you’re authorized to do so by the company. The same applies to communications with the press. Finally, check with your manager before accepting any public speaking engagement on behalf of the company. In general, before making any external communication or disclosure, you should require internal clearance.

V. Protect Holos’s Assets
Holos has a well-earned reputation for openness with confidential information shared within the company. Our ability to continue these practices depends on how well we conserve company resources and protect company assets and information.

1. Intellectual Property
Holos’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use Holos’s (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the Marketing team. We strongly encourage you to report any suspected misuse of trademarks, logos, or other Holos intellectual property to your manager.

Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Holos and you to criminal and civil fines and penalties. Please seek advice from your manager before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to Holos proprietary information. You should also check with your manager if developing a product that uses content not belonging to Holos.

A word about open source – Holos is committed to open source software development. Consistent with our policy of respecting the valid intellectual property rights of others, we strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against Holos, as well as significant damage to the company’s reputation and its standing in the open source community. Please seek guidance from your manager before incorporating open source code into any Holos product, service, or internal project.

2. Company Equipment
Holos gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the Holos stuff we are given. Company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Not sure if a certain use of company assets is okay? Please ask your manager or Human Resources.

3. The Network
Holos’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security policies. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smart phone or think that your network password may have been compromised – please promptly report the incident.

4. Physical Security
If you’re not careful, people may steal your stuff. Always secure your laptop, important equipment, and your personal belongings, even while on Holos’s premises.. Don’t tamper with or disable security and safety devices. Watch people who “tailgate” behind you through our doors. If you don’t recognize a Holos worker, please ask for valid identifier (and, as appropriate, direct the person to a receptionist for assistance). Promptly report any suspicious activity.

5. Use of Holos’s Equipment and Facilities
Anything you do using Holos’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, Holos may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises.

VI. Ensure Financial Integrity and Responsibility
Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of Holos is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at Holos – not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to Holos, sign a new business contract, or enter into any deals on Holos’s behalf.

To make sure that we get this right, Holos maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.

Stay in full compliance with our system of internal controls, and don’t hesitate to contact Ethics & Compliance if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Holos.

1. Spending Holos’s Money
A core Holos value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on Holos’s behalf, make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner on Holos, always record in our expense reimbursement tool the full names and titles of the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager. Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.

2. Signing a Contract
Each time you enter into a business transaction on Holos’s behalf, there should be documentation recording that agreement, approved by Holos board. Signing a contract on behalf of Holos is a very big deal. Never sign any contract on behalf of Holos unless all of the following are met:

You are authorized to do so under our Signature Authority and Approval Policy. If you are unsure whether you are authorized, ask your manager
The contract has been approved by Holos board. If you are using an approved Holos form contract, you don’t need further approval unless you have made changes to the form contract or are using it for other than its intended purpose
You have studied the contract, understood its terms and decided that entering into the contract is in Holos’s interest
All contracts at Holos should be in writing and should contain all of the relevant terms to which the parties are agreeing – Holos does not permit “side agreements,” oral or written.

3. Recording Transactions
If your job involves the financial recording of our transactions, make sure that you’re fully familiar with all of the Holos policies that apply.

Immediately report to the Board any transactions that you think are not being recorded correctly.

4. Reporting Financial or Accounting Irregularities
It goes without saying (but we’re going to say it anyway) that you should never, ever interfere in any way with the auditing of Holos’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other Holos records.

If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to Ethics & Compliance.

5. Hiring Suppliers
As Holos grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Holos. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision. Please do not hesitate to ask your manager if you have any questions regarding how to procure equipment or services.

6. Retaining Records
It’s important that we keep records for an appropriate length of time. The Holos Records Retention Policy suggests minimum record retention periods for certain types of records. These are great guidelines, but keep in mind that legal requirements, accounting rules, and other external sources sometimes specify longer retention periods for certain types of records, and those control where applicable. In addition, if asked by Holos board to retain records relevant to a litigation, audit, or investigation, do so until Holos board tells you retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact your manager.

VII. Obey the Law
Holos takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. A few specific laws are easy to violate unintentionally and so are worth pointing out here:

1. Trade Controls
Portuguese, European and international trade laws control where Holos can send or receive its products and/or services.
The bottom line: If you are in any way involved in sending or making available Holos products, services, software, equipment, or any form of technical data from one country to another, work with your manager to be absolutely sure that the transaction stays well within the bounds of applicable laws. If you or your manager are not sure, please contact Ethics & Compliance.

2. Competition Laws
Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition. Generally speaking, these laws prohibit 1) arrangements with competitors that restrain trade in some way, 2) abuse of intellectual property rights, and 3) use of market power to unfairly disadvantage competitors.

Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for Holos.

Examples of prohibited conduct include:
agreeing with competitors about prices
agreeing with competitors to rig bids or to allocate customers or markets
agreeing with competitors to boycott a supplier or customer

Other activities can also be illegal, unfair, or create the appearance of impropriety. Such activities include sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors, entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor using Holos’s strength to gain an unfair competitive advantage.

Although the spirit of these laws is straightforward, their application to particular situations can be quite complex.

Holos is committed to competing fair and square, so please contact Ethics & Compliance if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated Holos’s Antitrust Policies will, subject to local laws, be disciplined, up to and including termination of employment. If you suspect that anyone at the company is violating the competition laws, notify Ethics & Compliance immediately.

3. Insider Trading Laws
As we said earlier, internally we share information, including non-public information, about Holos’s business operations pretty freely. In addition, you may overhear a hallway conversation or come across a memo at a copy machine, either of which might involve confidential information. To use this non-public information to buy or sell stock, or to pass it along to others so that they may do so, could constitute insider trading. Insider trading not only violates this Code, it violates the law. Don’t do it.

4. Anti-bribery and anti-corruption Laws
Like all businesses, Holos is subject to lots of laws, both Portuguese, European and non-European, that prohibit bribery and corruption in virtually every kind of commercial setting. The rule for us at Holos is simple – don’t bribe or corrupt anybody, anytime, for any reason.

5. Non-government relationships
You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of Holos. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate. Before providing any business courtesies and contact Ethics & Compliance if you have any questions.

6. Dealing with government officials
Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you’re dealing with a government official. “Government officials” include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything of value to government officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for government officials’ relatives. Never give gifts to thank government officials for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of Holos products). Payment of such expenses can be acceptable (assuming they are permitted under local law) but may require pre-approval from Ethics & Compliance.

7 – Facilitation payments Laws
Again, like all businesses, Holos is subject to lots of laws, both Portuguese, European and non-European that prohibit facilitation payments in virtually every kind of commercial setting. The rule for us at Holos is simple – facilitation payments are not allowed anytime, for any reason.

VIII. Conclusion
It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Holos workers to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions of your manager, or Ethics & Compliance.

And remember… be honest, and if you see something that you think isn’t right – speak up!