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Compete Fairly 

We are committed to fair competition and to complying with applicable competition laws, rules, and directives. Competition laws are designed to promote open and vigorous competition in the marketplace. They prohibit arrangements between parties that restrict competition, and where a business has market power, it has a responsibility not to use that power to act in a way that harms competition. We follow competition and anti-trust laws, making sure that our Company is never involved in any conduct that is likely to damage fair competition. We believe that our Company will prosper in a marketplace that is competitive and will achieve success based on the quality of our products and services.

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Never Offer or Accept a Bribe

Bribery is illegal, and we prohibit it. We never compromise our commitment to the law or integrity by engaging in, or appearing to engage in, bribery or any other form of corruption. We do not seek to influence anyone, directly or indirectly (through a third party), through bribes or kickbacks or any other improper or unethical means, or in a manner that could compromise our reputation and values. In addition, the Company maintains procedures designed to ensure that our suppliers and business partners are reputable, do not engage in bribery, and comply with applicable laws and Company policies.

Handle Gifts and Business Entertainment Responsibly
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Handle Gifts and Business Entertainment Responsibly

Gifts and business entertainment must be handled responsibly and in accordance with the Company’s policies. Offering or accepting gifts and business entertainment can provide legitimate opportunities to promote our Company’s products and services, to network, and to build business relationships. If handled inappropriately or if offered or accepted with improper intent, however, gifts or business entertainment could impair our business judgment or that of our suppliers and business partners, compromise our business relationships, damage our Company’s reputation, and violate the law.

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Interact with Governments and Engage in Political Activities Legally and Ethically

Our interactions with governments and our political activities comply with applicable laws, regulations, and Company policies. Our Company works with government entities and interacts with government officials to protect our business objectives and achieve public policy goals. Our Company policies outline the requirements, limitations and restrictions for engaging in activities such as lobbying for a cause or piece of legislation, hiring a third party to advocate on the Company’s behalf, offering anything of value to a government official, contributing to a political candidate or committee, selling our products and services to a government agency, or otherwise interacting with government officials. We also recognize that employees may participate in their personal capacity in political activities in the communities in which we live and work. When engaging in political activities and interacting with government, we adhere to the highest legal and ethical standards, and comply with Company policy.

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Abide by Applicable Money Laundering, Criminal Financing, and Tax Evasion Laws

We abide by applicable laws designed to prevent and detect money laundering, criminal financing, and tax evasion. We prohibit engaging in any attempt to disguise or “launder” the proceeds of criminal activity to make the source of the funds appear legitimate. We are committed to conducting business with reputable business partners, receiving funds from legitimate sources, and complying with anti-money laundering and anti-tax evasion laws.

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Comply with International Trade Controls

We commit to conducting business globally in compliance with applicable international trade control laws and regulations. International trade control laws and regulations govern the transfer of goods, software, services, and technology across borders and the conduct of business with certain countries, governments, entities, and individuals. These laws and regulations include export and import regulations, anti-boycott laws, as well as economic sanctions, and are often based on national security and foreign policy concerns. We operate around the globe and our respect for these laws and regulations avoids penalties and preserves the Company’s reputation and our ability to succeed in a global business environment.

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Protect the Environment

Protecting the environment for future generations is important to us, so not only do we comply with applicable environmental laws and regulations, we also foster a culture of sustainable innovation and environmentally responsible business decisions. We seek to minimize environmental impacts through responsible use of resources. This includes reducing energy use, utilizing renewable energy where practical to do so, minimizing the generation of hazardous waste, and recycling and reusing materials.

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Foster Ethical Relationships with Suppliers and Other Business Partners

We strive to partner only with those who share our values. A critical part of doing business is partnering with others, and we believe that partnerships are built on trust and mutual advantage. We interact honestly and with integrity in the marketplace and expect our business partners to do the same, including by obeying laws and regulations relating to labor and employment, including human trafficking and forced labor prevention; health and safety; the environment; privacy and information security; anti-money laundering; anti-tax evasion; and anti-corruption. We are committed to providing competitive opportunities for diverse suppliers to earn our business, and we evaluate supplier offerings on the basis of their quality, reliability, performance, price, service, and technical requirements. We also expect our business partners to share our commitment to integrity and ethical business behavior. This is set out in more detail in our Code of Conduct for Suppliers and Other Business Partners.

Code of Conduct Resources

Resources

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