Codes
and Principles in Business

Code of Compliance

- Guidelines to comply with AZUR’s Code of Conduct -

Link: AZUR_Code_of_Compliance.pdf

 

WHAT IS EXPECTED FROM EACH EMPLOYEE OF AZUR?

 

Compliance principles

We comply with the legislation in force and the rules & procedures in place within our Company. We are committed to carrying out our business and professional activities in accordance with the legislation in force wherever they take place.  

 

Awareness and accountability

At AZUR we believe that the implementation of adequate principles and control in ethics and compliance includes the evaluation of business partners’ ethics and compliance models.

 

We report inconsistencies

We report to Management and the Code Compliance Officers any known incidents or irregularities in order to remedy the effects and eliminate violations.

 

Comply with the Code of Conduct and the legislation

We understand and comply with the Code of Conduct and the legislation in place wherever we are. We use good judgment and avoid even the appearance of improper behavior. Unawareness of the Code of Conduct will not exempt us from its requirements.

If ever in doubt about a course of conduct, ask yourself:

 

If the answer is “No” to any of these questions, do not do it.

The Code of Conduct applies to everyone working for AZUR, regardless of location, role or level of seniority. This includes all Employees, Managers and Directors of the Company. We expect temporary and contract employees, consultants, agents and any other third party who act in AZUR’s name to act in accordance with the principles of the Code of Conduct.

Every subsidiary and joint venture controlled by AZUR (if applicable) must adopt and comply with the Code of Conduct. Where we participate in, but do not control a joint venture relationship, we will encourage our partners to meet the requirements of the Code of Conduct in both the joint venture and their own operations.

Some situations may seem ambiguous. Exercise caution when you hear yourself or someone else say “It has always been done this way,” “Everybody does it,” “Maybe just this once,” “No one will ever know” or “It will not matter in the end.” These are signs to stop, think through the situation and seek guidance. Importantly, do not ignore your instincts. Ultimately, you are responsible for your own actions. If you are still uncertain, ask for guidance. The Code of Conduct tries to capture many of the situations that employees will encounter, but cannot address every circumstance. You can seek help from the Code Compliance Officer or from AZUR’s Management.

You are also required to report violations, and suspected violations, of the Code of Conduct. This includes situations where others ask you to violate the Code of Conduct. There will never be penalties for making any reports, and every effort will be made to maintain confidentiality.

 

WHAT IS EXPECTED FROM EACH MANAGER OF AZUR?                                                               

 

Promote a Culture of Ethics and Compliance

Those involved in the management of our company, those who are managers or who supervise other employees have a special responsibility to comply with the compliance of the Code of Conduct. Often, they are the first point of contact when an employee has the courage to report a problem. It is essential that you are prepared to listen carefully and respond properly. Managers must lead by example, and act as role models for others. As a Manager you should:

 

 

Respond to Questions and Concerns

If approached with a question or concern related to the Code of Conduct, listen carefully and give the employee your complete attention. Ask for clarification and additional information. Answer any questions if you can, but do not feel that you must give an immediate response. Seek help if you need it. If an employee raises a concern that may require investigation under the Code of Conduct, contact the Code Compliance Officer.

 

HOW TO USE AND COMPLY WITH THE CODE OF CONDUCT

 

Seeking Guidance

If you have any questions about the Code of Conduct or a situation, ask the Code Compliance Officer before you take action: Your Code Compliance Officers are your General Manager and the Legal Advisor.

 

Obtaining Approvals

Under the Code of Conduct, certain actions require prior written approval. Where approval is required, both Code Compliance Officers must approve (if you have more than one applicable Code Compliance Officer). For recurring or ongoing actions, this approval should be renewed annually, or anytime there is a change in either the situation or any of the Code Compliance Officers. Copies of these approvals should be submitted by each Code Compliance Officer to and maintained by the Legal Department, and made available to auditors or investigators if required.

 

Raising Concerns

We all have an obligation to uphold the ethical standards of AZUR and we must all take responsible steps to prevent Code of Conduct violations. If you observe behavior that concerns you, or that may represent a violation of our Code of Conduct, raise the issue promptly. Doing so will allow the Company to deal with the issue and correct it, ideally before it becomes a violation of law or a risk to the environment, health and safety.

 

You have several options for raising issues and concerns. Whether you are asking for guidance or expressing concern, you should always contact your Manager. If you prefer, you can contact any of the following:

 

All Code violations are required to be reported to AZUR’s Board of Directors and, therefore, should be fully documented together with details of the corrective action taken. A report to this effect should be submitted to the Board of Directors as soon as possible, but normally not later than one month after the date that local Management became aware of the violation or possible violation.

 

Anonymity and Confidentiality

When you raise concerns regarding potential Code of Conduct violations, you may choose to remain anonymous, although you are encouraged to identify yourself to facilitate communication. If you make your identity known, we will take every reasonable precaution to keep your identity confidential, consistent with conducting a thorough and fair investigation and compliance with applicable law, and we will acknowledge your report and keep you updated where possible. Because we strive to keep all investigations strictly confidential, we may not be able to inform you of the outcome of an investigation. To maintain confidentiality, avoid discussing these issues, or any investigation, with other employees.

 

Investigations and Disciplinary Actions

The Company takes all reports of possible misconduct seriously. We will investigate the matter confidentially, make a determination whether the Code of Conduct or the law has been violated, and take appropriate corrective action. If you are involved in a Code of Conduct investigation, cooperate fully and answer all questions completely and honestly.

For each Code of Conduct violation, discipline is determined based on the nature of the violation, mitigating and aggravating factors, and the precedent for discipline (or range of discipline). Discipline for Code of Conduct violations has a broad range, including but not limited to one or any combination of the following: a letter of reference, final written warning, suspension, demotion, loss or reduction of bonus or option awards, and dismissal. AZUR has a position of zero tolerance for theft of Company assets. In addition, we may seek reimbursement for losses or recovery of damages by a civil suit or refer the matter to local authorities for criminal procedures. Any disciplinary action for failure to observe the Code of Conduct will be taken in accordance with applicable laws and employment contracts and will be settled in compliance with disciplinary investigation procedures applicable in AZUR.

 

No Punishment

AZUR values the help of employees who identify potential problems that they need to address. The fact that an employee has raised a concern honestly, or participated in an investigation, cannot be the basis for any adverse employment action, including dismissal, 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 should continue to treat the person with courtesy and respect. If you believe someone has punished you, report the matter to your Code Compliance Officer.

 

Making False Accusations

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

 

RULES OF CONDUCT WITHIN THE COMPANY

 

Working Together

Within our Company we promote equality of opportunity. Selection and reward are based on merit without regard to race, color, religion, sex, gender, sexual orientation, citizenship status, national origin or disability. We will comply with all applicable laws relating to employment practices and expect all of our employees to treat each other with dignity and respect.

 

Protect the Company’s assets and use those assets in the manner intended

Company assets should only be used for legitimate business purposes and are meant for company, not personal, use. Do not use Company assets for your personal benefit or the benefit of anyone, other than the Company. Common sense should prevail of course. The occasional personal phone call from your workplace, for example, is inevitable. Substantial personal phone calls, however, could represent misuse. The point is to recognize that theft or deliberate misuse of Company assets is a violation of the Code of Conduct.

Company policy may allow additional personal use of certain assets, such as a Company car or smart devices. Always check relevant local policies and regulations to ensure that you are using Company assets as intended.

Examples of Company Assets: Company machinery & tools, Company money, Company products, employees' time at work, computer systems and software, telephones, smart devices, photocopiers, Company vehicles, proprietary information, Company trademarks, etc.

Theft of Company assets - whether physical theft such as unauthorized removal of Company product, equipment or information, or theft through misappropriation or intentional misreporting of time or expenses - may result in termination of the employment contract and criminal prosecution. We treat workplace theft of assets belonging to other employees the same way we treat theft of AZUR’s assets.

The use of Company assets outside of your Company responsibilities, such as using Company materials or equipment to support personal interests, requires prior written approval from the Code Compliance Officer. You must have this approval renewed annually if you continue to use the asset outside of work.

It is also considered Company assets the working time. Using the working time for any other purpose constitutes a violation of the Code.

 

Corporate Opportunities

During the course of your employment, you may learn about business opportunities that you are interested in pursuing outside of the Company. You may not take for yourself (or direct to someone else) any opportunity you discover through your position at our Company or through the use of Company property or information without the prior written consent of the Code Compliance Officer.

 

Technology

Computer systems and equipment of AZUR are meant for company use, and for use in accordance with AZUR’s Regulations. For example, they should never be used for outside Company’s operations, for illegal activities. You may not download or store illegal content or programs from the Internet on your Company computer. Always use licensed software with the consent of AZUR’s IT Manager.

Lack of diligence by an individual can lead to a breach of our information security affecting the whole company. Everyone who uses Company digital systems - employees, contractors, consultants and other people with temporary access - must ensure that these resources are used appropriately and in line with AZUR’s Regulations. You are required to:

 

Insider Trading

You may not buy or sell stocks or securities of AZUR or another company based on nonpublic information. Trading in stocks or securities based on material nonpublic information, or providing material nonpublic information to others so that they may trade, is illegal and may result in prosecution.

 

Personal Information

The Company respects the privacy of all its employees, business partners and consumers. We must handle personal data responsibly and in compliance with all applicable privacy laws. Employees who handle the personal data of others must:

 

 

The Company will safeguard the confidentiality of employee records by advising employees of all personnel files maintained on them, collecting only data related to the purpose for which the files were established and allowing those authorized to use a file to do so only for legitimate Company purposes. Employees will be allowed to inspect (and challenge for correction as necessary) all information in their personnel files, except for confidential letters of recommendation, material relating to other employees, investigatory and audit materials, and unless otherwise provided under applicable law. We have adopted a Data Protection procedure setting out in detail our policies regulating the handling of personal data. We must comply at all times with all applicable laws relating to employee records and personnel files.

 

Conflicts of Interest

 

Act in the best interest of the Company while performing your job. A conflict of interest arises when your personal activities or relationships interfere, or appear to interfere, with your ability to act in the best interest of the Company.

Never use your position within the Company for personal benefit or to benefit a family member. Avoid personal financial transactions with customers and suppliers that may influence your ability to perform your job. The use of working time, AZUR assets or the position held within AZUR to collaborate, for a fee or free of charge with other legal entities, AZUR partners in the interest of these partners, constitutes a violation of the Code of Conduct.

Determining Conflicts of Interest: It is important that every business decision we make as AZUR employees is based on the needs of the Company and not on personal interests or relationships. A conflict of interest exists when an employee’s personal interests are harmful to the interests of the Company. It is important to avoid even the appearance of a conflict of interest. Almost all conflicts of interest can be avoided or resolved if properly disclosed. If you notice that your personal interests may conflict with your role in the Company or if you believe that another employee may have a conflict of interest, talk to your boss or seek advice from one of the other resources listed in this Code of Compliance.

 

Relatives and Friends

 

Many employees have relatives who are employed by or invest in or have substantial financial or commercial relationships with customers or suppliers of the Company. These financial interests do not create a conflict under the Code of Conduct unless:

 

Who is my “relative” under the Code of Conduct? A spouse, parent, sibling, grandparent, child, grandchild, mother- or father-in-law, or domestic partner are all considered relatives. Also included is any family member who lives with you or who is otherwise financially dependent on you, or on whom you are financially dependent or with whom you have financial transactions. Even when dealing with family members beyond this definition, take care to ensure that your relationship does not interfere, or appear to interfere, with your ability to act in the best interest of AZUR.

In either of these situations, you must notify the Code Compliance Officer in writing, and you must renew this notification annually. If your relative is employed by a competitor of the Company, you must also notify the Code Compliance Officer, and renew it annually.

You may have friends who are employed by, or have ownership interests in, customers or suppliers of the Company. If you deal with such a customer or supplier, take care to ensure that your friendship does not affect, or appear to affect, your ability to act in the best interest of the Company. If you are uncertain whether your friendship may create an issue, consult your manager or the Code Compliance Officers.

In addition, personal relationships at work must not influence your ability to act in the best interest of the Company, and must not affect any employment relationship. Employment-related decisions should be based on qualifications, performance, skills and experience.

 

 

Business and Financial Records

Ensure the accuracy of all Company business and financial records. These include not only financial accounts, but other records such as business plans, budgets, quality reports, time records etc. Ensuring accurate and complete business and financial records is everyone’s responsibility. Accurate recordkeeping and reporting reflect on AZUR’s reputation and credibility, and ensures that the Company meets its legal and regulatory obligations. It also ensures that performance is judged and compensation is awarded fairly among employees.

 

 

 

Product Quality

 

Our customers have chosen us because of the product quality we deliver to them. Each of us have to be aware of and follow Company policies and procedures that protect the quality of our products. In addition, we expect our suppliers to ensure the quality and safety of the products and services they provide to us. For this reason, we choose suppliers who share our values and who deliver superior products and services.

 

Intellectual Property

 

Our Company’s intellectual property, whether licensed or owned, is among its most valuable assets. We therefore must protect our Company’s intellectual property rights. Intellectual property refers to anything we create on Company time, at the Company’s expense or within the scope of our job duties. AZUR owns the rights to anything we create through our work with the Company to the full extent permitted by law, regardless of whether this property is patentable or able to be protected by copyright, trade secret or trademark. Examples of intellectual property include copyrights, patents, trademarks, trade secrets, design rights, logos, software programs, business processes and delivery or production methods.

 

Use of Information

 

Nonpublic Information: Many of us have access to confidential, nonpublic information through the work we do. Nonpublic information is any information that has not been disclosed or made available to the general public. It is your obligation to safeguard the Company’s nonpublic information. Unless it is necessary as part of your work responsibilities, you may not share this information with anyone outside the Company, including your family members and friends. This information is Company property and you may not disclose it to others even after you leave the Company. You should also limit the sharing of Company nonpublic information within the Company to those of your colleagues who need to know such information for business purposes.

What is Nonpublic Information? It is any information that the Company has not disclosed or made generally available to the public. Examples include information related to employees, inventions, contracts, strategic and business plans, financing transactions, major management changes, new products, marketing campaigns, mergers, acquisitions and divestments, technical specifications, pricing, proposals, sales data, financial data, product costs.

 

 

 

Workplace Health and Safety

 

Health and Safety are key values of AZUR. We always comply with applicable health and safety rules and regulations. In addition, we consistently promote safe operating practices and avoid undue risk to our colleagues and our communities. Our commitment includes ensuring the health and well-being of all our employees. We intend to be a model in our industry for occupational health and safety. We require all employees to follow safe work practices in the interest of their own safety as well as that of fellow employees.

 

Safety is the responsibility of each and every employee. Employees can prevent injury to themselves and their co-workers by always following safe work practices and reporting any unsafe conditions they observe. Many employees go beyond these basic responsibilities by participating on safety committees, giving management input on safety policies and procedures, helping conduct safety inspections or assisting with accident investigations. Employees may address occupational health and safety issues with the occupational safety officer at their unit or the company's occupational safety personnel.

 

Outside Investments

Avoid investments that could affect, or appear to affect, your decision-making on behalf of AZUR, including investments in customers, competitors or suppliers of AZUR. If you have discretionary authority in dealing with another company as part of your job, you may not have any financial interest in that company – even an indirect interest through, for example, a family member – without prior written approval from the Code Compliance Officer.

 

 

Outside Employment

You should not compete, either on your own or in collaboration with third parties, against AZUR. If you would like to serve as an officer or manager or consultant to an outside business on your own time, you must receive prior approval in writing from the Code Compliance Officer, which must be updated annually.

Before accepting payment for speeches or presentations related to AZUR or your work at AZUR, always get your Code Compliance Officer’ prior written approval. You are permitted, however, without requiring any approval, to serve on charity boards or in family businesses that have no relationship to AZUR.

 

 

Gifts, Meals and Entertainment, Anti-bribing

It often is customary to exchange gifts and entertainment with customers and suppliers. The key to such exchanges is to maintain an arm’s-length relationship. Avoid excessive or lavish gifts, meals or entertainment that may give the appearance of undue influence. Always consider whether the gift, meal or entertainment you plan to give or receive could be regarded as excessive or inappropriate, could lead to or imply any obligation, or could be interpreted as a bribe.

 

Receiving Gifts, Meals or Entertainment:

Declining Gifts, Meals or Entertainment:

Giving Gifts, Meals or Entertainment:

Anti-bribing: AZUR must comply with laws prohibiting the payment of bribes to government officials or others to obtain or maintain business. In short, these laws prohibit the payment, solicitation, offer or receipt of bribes to further the interests of our Company. These laws may apply whether the bribe was offered or paid directly by an AZUR employee or by agents, joint venture partners, brokers or consultants acting on behalf of AZUR. Bribes can take several forms:

AZUR provides training to employees whose positions could place them in situations where these issues may arise. You must conscientiously apply this training in practice. If you believe that a bribe may have been offered or paid by you or another employee or by a contractor or agent working for AZUR, or if you have any questions about the application of these laws, you must communicate promptly using the resources described in this Code.

 

Loans

Personal loans from the Company to Directors and Managers are always prohibited. Loans from the Company to business entities affiliated with any of the Company’s Directors or Managers may be entered into for legitimate business purposes. Loans from the Company to other employees and their family members must be approved in advance and in writing by AZUR’s management.

 

RULES OF CONDUCT IN RELATION WITH EXTERNAL STAKEHOLDERS

 

Bribery is Forbidden- Rules

You must never engage in bribery. A bribe or bribery is giving or offering anything of value or any advantage, whether directly or indirectly, to any person, in order to induce that person or any other person to perform a function or activity improperly. Bribery is also requesting or receiving anything of value or any advantage, whether directly or indirectly, from any person, intending that, as a consequence, a relevant function or activity should be performed improperly, whether by you or another person.

 

A bribe can be financial or otherwise, and can include giving or receiving money, loans, contributions or donations, travel, offers of employment, refunds, rebates, goods, services or anything else that could be considered to have value. Gifts or entertainment may be construed as forms of bribery in certain circumstances. A bribe can also take the form of a “reward” and be paid after the improper performance of the relevant duty or obligation has taken place.

Many countries have passed legislation criminalizing bribery. The sanctions for violating these laws can be severe, including significant individual and corporate fines, and even imprisonment. The Company will not condone, under any conditions, the offering or receiving of bribes or any other form of improper payments. Even the appearance of a breach of anti-bribery or anti-corruption laws could do significant damage to the Company’s reputation. You should exercise particular care in dealings with Government Officials to ensure there can be no suggestion of impropriety.

Improper Payments by Third Parties: AZUR may be held liable for bribes paid by a third-party agent or consultant acting on the Company’s behalf. Take particular care when evaluating a prospective third party who might interact with a Government Official, customer, supplier or consumer on behalf of the Company. You must not engage a third-party agent or consultant if you have reasonable grounds to believe that the agent or consultant may attempt to bribe any person on behalf or for the benefit of the Company.

   

Dealing with Government Officials

Transactions with Government Officials are not the same as conducting business with private parties, and are covered by special legal rules. Consult the Code Compliance Officer to be certain that you are aware of, understand and abide by these rules.

Although you must never offer bribes to anyone or accept bribes from anyone, you need to be particularly vigilant not to engage in any bribery or improper dealings with Government Officials. Do not offer, promise, give or authorize any financial or other advantage to anyone (including a family member, relative or person associated with a Government Official) if the circumstances may give the appearance of seeking to influence the Government Official to obtain or retain business or an advantage in the conduct of business.

You must obtain prior written approval from your Code Compliance Officer before providing anything of value or any advantage to a Government Official.

 

Who are Government Officials?

 

It is your responsibility to understand whether someone you deal with is a Government official. When in doubt, consult Company legal advisor.

 

Political Donations and Activity

Charitable Contributions: As part of our commitment to good corporate citizenship, General Managers are authorized to make charitable contributions. These contributions may take the form of goods or services, technical assistance or training, financial support, or sponsorship of events. However, particular care must be taken to assure that the recipient charity is a bona fide charity, regulated and supervised as such in the jurisdiction, and that we have no reason to believe that the charity itself may be operated directly or indirectly for the private benefit of any Government Official. If any Government Official is a director or officer of the charity, is otherwise closely associated with the charity, or requests that the Company donate to the charity, you should inform the Legal Department who will advise the responsible executive what inquiries or other procedures are required in order to obtain a high level of assurance that the contribution will not be used to make a prohibited payment.

 

Dealing with Customers, Suppliers and Consumers

 

The Company values its partnerships with customers, suppliers and consumers. Treat these partners in the same manner we expect to be treated. Always deal fairly with customers, suppliers and consumers, treating them honestly and with respect:

 

 

Third Parties and the Code of Conduct

 

Where AZUR engages external service providers or other third parties to act as agents on its behalf, the manager responsible for the engagement must draw the attention of the external service provider or other third party to the Code of Conduct.

Agreements with agents, independent sales representatives, marketing consultants and promotion companies all present compliance risks. Remember, the use of the Company’s funds or assets for any unlawful purpose is prohibited and is against Company policy. Agreements with such third parties should be in writing and should clearly and accurately set out the services to be performed, the basis for earning the commission or fee involved, and the applicable rate or fee. Any such payments to agents, independent sales representatives and consultants must be reasonable in amount, not excessive in light of the practice in the trade, and commensurate with the value of the services rendered.

Any action or payment, which is improper when made by an employee of the Company, is also improper if undertaken by an agent, consultant, or other third party on behalf of the Company, where the Company knows or has reason to know that the payment or action will be made.

Employ and deal with only qualified and reputable individuals or firms by identifying candidates’ qualifications and legitimate business reasons for choosing the candidate, interviewing and meeting such candidate.

 

Consultants, independent contractors and other third parties engaged by AZUR should receive a copy of the Code of Conduct and be informed that they are obliged to comply with it. They should also specifically be informed about their right and responsibility to seek advice and report violations of the Code of Conduct.

 

Dealing with Competitors

 

Competing Fairly: AZUR’s policy is based on fair competition. We do not seek competitive advantages through illegal or unethical business practices.

   

Competition Law

 

AZUR competes fairly, and complies with all applicable competition laws around the world. These laws often are complex, and vary from country to country, both in the scope of their coverage and their geographic reach. Conduct permissible in one country may be unlawful in another. Penalties for violation can be severe. Intentional breach of any laws or the Competition Law Guidelines is a Code violation.

 

 

Competitive Intelligence

 

Employees are encouraged to collect, share and use information about our competitors, but to do so only in a legal and ethical manner. Just as AZUR values and protects its own nonpublic information, we respect the nonpublic information of other companies.

Acceptable Intelligence Gathering: It is acceptable to collect competitive intelligence through publicly available information or ethical inquiries. For example, you may gather and use information from sources such as:

 

You may also ask third parties about our competitors, or accept competitive intelligence offered by a third party, so long as there is no reason to believe that the third party is under a contractual or legal obligation not to reveal such information.

 

Prohibited Activities: The following basic restrictions apply to our ability to gather competitive intelligence:

 

 

Environmental Protection

   

The Company recognizes its responsibility for the protection of human health, the environment and natural resources. Our highest priority is protecting the safety and health of our employees, consumers, customers and members of the communities where we do business.

We always operate our facilities and conduct our operations in compliance with all applicable environmental laws, regulations and permits. Where none exist, we set ourselves appropriately high standards. Throughout our operations, we consider the environmental implications of the business decision that we make. In doing so, we seek to support environmental sustainability and biodiversity.

We are committed to re-use, recycling and recovery programs for wastes and to disposing of unrecoverable wastes safely and with minimal impact, and we apply strict conservation methods to our use of resources, including water, packaging, energy and other raw materials.

 

 

ADMINISTRATION OF THE CODE OF CONDUCT

 

The Code of Conduct is designed to ensure consistency in how employees conduct themselves within AZUR, and in their dealings outside of the Company. No set of rules can cover all circumstances. With appropriate consultation and written permission, these guidelines may be varied as necessary to conform to local law or contract. These guidelines do not create any contractual rights of any kind between AZUR or any of its employees. In addition, all employees should understand that these guidelines do not modify their employment relationship, whether at will or governed by contract. AZUR reserves the right to amend or alter the Code of Conduct at any time and for any reason.

 

Responsibility

 

The responsibility for administering the Code of Conduct rests with the Legal Department. The Code Compliance Officer, in conjunction with the HR Department, and the Legal Department of AZUR, shall conduct training of employees, representatives and contractors reasonably designed to inform them of this Code, assist them in understanding how the Code of Conduct would apply to situations and fact patterns relevant to them, and how to deal with situations in which conduct prohibited by the Code of Conduct may be solicited or encountered.

 

Reporting of Code of Conduct Decisions and Investigations

 

The Code Compliance Officer periodically reports pending Code of Conduct investigations and final Code of Conduct decisions, including disciplinary actions taken, to the management of the Company. See also page 7 above under the heading “Raising Concerns” for further information about the reporting and investigation of potential Code of Conduct violations.

 

Signature and Acknowledgement

 

To help ensure compliance with the Code of Conduct, the Company requires all Directors and Managers to go through training upon hiring and every two years. All Directors and Managers must sign the attached acknowledgement form confirming that they have read the Code of Conduct and agree to abide by its provisions. The Managing Director of Company together with Legal Department of AZUR must review the Code of Conduct and acknowledge all Directors and Managers their understanding and adherence on a bi-annual basis on the attached form. Failure to read the Code of Conduct or sign the acknowledgement form does not excuse from compliance with the Code of Conduct. Legal Department of AZUR will make a brief presentation of the Code of Conduct to all employees of the company, once every two years.

 

It’s Up to You

 

Administration of the Code of Conduct is everyone’s responsibility. There are colleagues to help you do the right thing. If you act with integrity and seek guidance when you are uncertain, you will be doing the right thing.

 

Date: October 22, 2021

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