Code of conduct

for all the officers and employees of our company and subsidiaries

Tags:
corporate

The Board of Ahlers nv resolved that it is the explicit policy of the Company that no officer or employee of the Company or a subsidiary shall, directly or indirectly, own, be employed by, or receive compensation from outside concerns that conflict, or appear to conflict with the interests of the Company, unless a specific authorization is received from this Board or its Executive Chairman.

General Statement of Policy

Employees must be free from the influence of personal interests which interfere, might interfere, or be thought to interfere with their duties and responsibilities to the Company. Employees’ acts must be motivated by the Company’s best interests rather than any consideration of potential or actual personal advantage.

Accordingly,

1) employees are expected to avoid direct or indirect involvement in any situation where they have a conflict with the interests of the Company, are competing with the Company, or have taken for themselves an opportunity which belongs to the Company;

and

2) employees may not use, disclose or share inside information, which is not otherwise available to the general public, for any manner of personal gain or for the benefit of any third party or in a manner adverse to the interests of the Company.

Conflict of Interest

Employees must not place themselves in a situation where they have or appear to have a direct or indirect interest in, connection with, or benefit from outside commercial activities which are in any way related to the activities of the Company. Circumstances in which such a conflict of interest may be present include:

1) Ownership – directly or indirectly – of a material interest in any competitor, or supplier, contractor, subcontractor, customer or other person or organization doing business with the Company.

2) Acting in any capacity – including director, officer, partner, consultant, employee, distributor, agent or the like – for a competitor, or a supplier, contractor, subcontractor, customer or other person or organization doing business with the Company.

3) Accepting – directly or indirectly – payments, services, or loans, from a supplier, contractor, subcontractor, customer or other person or organization doing business or expecting to do business with the Company.

4) Ownership – directly or indirectly – of any property, including real estate, share of stock, etc., which, if disclosed to shareholders, customers, suppliers or others, would appear to be in conflict with the interests of the Company.

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