We expect all our employees, as well as our third-party intermediaries, to follow these principles and standards and to seek guidance when in doubt from your supervisor, your company contact, or from the options noted in our Code, including theGuideLine
Commercial

Our Approach to commercial Activity

At Koch, we measure our commercial performance not only by our results but by how we achieve them. By conducting our activities lawfully and with integrity, we create virtuous cycles of mutual benefit, maximizing our societal contributions and long-term success.

We comply with all applicable laws and regulations, including antitrust, anti-corruption, anti-money laundering, data privacy, intellectual property, and international trade laws. These laws ensure free and fair competition, prevent corruption, secure financial transactions, protect personal data and intellectual property, and respect international sovereignty.

We act in accordance with Our Values in all commercial activities even if doing so may conflict with short-term interests. We avoid false, misleading, deceptive, or unfair practices and respect the rights and interests of others. We reject advantages obtained through improper means and avoid conflicts of interest. We protect company confidential information and intellectual property and do not participate in unsanctioned boycotts or activities.

We expect all our employees, as well as our third-party intermediaries, to follow these principles and standards and to seek guidance when in doubt from your supervisor, your company contact, or from the options noted in our Code, including the GuideLine.
We expect all our employees, as well as our third-party intermediaries, to follow these principles and standards and to seek guidance when in doubt from your supervisor, your company contact, or from the options noted in our Code, including theGuideLine

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Employee Expectation

Embodying Personal and Business integrity

  • Maintaining integrity in your actions and results (never giving out false information or acting deceptively).
  • Respecting the rights and dignity of every individual.
  • Not buying or selling another company’s securities based on material, nonpublic information. If you have access to confidential information, you must not use it for personal gain or share it with others who might trade on that information.
  • Not participating in any actual or perceived corruption, fraud, and any other conduct that could harm our reputation or violate the law such as:
    • Providing “anything of value” that may influence decisions,
    • Paying facilitation payments, which are prohibited except under emergency circumstances (i.e., health and welfare risks). Some jurisdictions do not recognize this exception.
  • Avoiding exaggeration, speculation, inappropriate language, and derogatory remarks or characterizations in all communications. (This applies to communications of all kinds whether written or verbal.)
  • Ensuring that all business records are accurate and complete (e.g., environmental, safety, operational, personnel, and financial records).
  • Properly managing business records by complying with the records and information management standards and policies that apply to your roles and responsibilities.
Conflicts of Interest
Conflicts of interest occur when personal, social, financial, or political activities interfere with our responsibilities to the company. Actual conflicts must be avoided. Even appearances of a perceived conflict can be damaging and should be avoided. Following are some examples of real conflicts of interest to help you navigate this topic.
Notify your supervisor or reach out to one of the options noted for asking questions if you believe you may have a conflict of interest.
  • You or your close relatives may not engage in any transaction with the company (rentals, purchases, sales, transfers, use of property or services), except when specifically permitted or approved.
  • A friend or relative who works for a competitor, customer, or supplier and directly interacts with you or your business group as part of their role with that company.
  • You or your close relative have substantial interest in a customer, competitor, or supplier.
  • You have an outside business interest or are considering one.
  • Hiring of relatives must be pre-approved by business HR to avoid conflicts of interest.
  • Romantic relationship with others in the workplace can be a conflict and problematic if one party could influence the other’s pay, performance rating, benefits, or terms and conditions of employment.
  • Service or running for public office may be a conflict or impacted by local law. Seek guidance and training, along with learning potential reporting requirements, starting with your supervisor and the other options noted for asking questions.
  • Assisting others in political pursuits is your personal business. Do not use company resources, office equipment, supplies, company time, or our company’s name in those efforts.
Privacy & Data Protection
The company is committed to compliance with all applicable privacy and data protection laws in all countries in which we operate. This commitment is reflected in the respective Privacy Policy(or Infor's Privacy Policy) or Employee Privacy Notice for our employees, customers, suppliers, consumers, and other individuals when we are in the possession of their personal data.
Antitrust / Anti-competition
Our principle-based culture strongly supports free markets. We believe competition in the marketplace benefits all of us as consumers. Antitrust and competition laws exist to protect free and fair competition.
It is illegal for competing companies to form agreements that unreasonably restrain trade.

Never discuss with competitors such things as prices, sales or other discounts, hiring practices, or any other commercial matter on which they compete.

You must contact Legal immediately if you believe any employee has had inappropriate contact with a competitor or a competitor has made a proposal that is inappropriate under competition laws.
Export Control and Trade Sanctions
Many countries have export controls and trade sanctions that restrict economic activities with specific countries, individuals, and entities, and limit the export or re-export of specific items and technologies. Given this, all counterparties to transactions must be screened to ensure compliance with these laws.
Anti-Boycott
We must not participate in or support any boycott of a foreign country that is not sanctioned by the U.S. government.
Anti-Bribery, Understanding Gifts, Gratuities, and Entertainment
We pride ourselves on building strong relationships with customers, suppliers, government officials, and other business associates. At times, and in compliance with applicable law, it may be appropriate to exchange modest gifts or entertainment. Good judgment and common sense are critical in determining the appropriateness of a gift or entertainment. Avoid any relationship that could give the appearance of impropriety or otherwise affect or influence your ability to make good business decisions. Offering, giving, soliciting, or receiving any form of bribe or kickback is strictly prohibited.

Gifts are defined very broadly and can include anything of value, such as cash or cash equivalents, travel, transportation, lodging, meals, drinks, entertainment, use of company materials, facilities or equipment not available or offered to the public, employment offers, a promise of future business opportunities, scholarships, and charitable contributions.

In addition, we strive to avoid any actions that could be perceived as corrupt, such as offering or accepting anything of value to improperly influence business decisions or gain unfair advantages. This applies to all employees and extends to our agents and representatives, reflecting our dedication to principled entrepreneurship and mutual benefit. There are special conditions, reviews, and approvals that need to be in place for government officials. This is also noted in "Navigating Interactions with the Government"section.