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Policies

INTEGRATED MANAGEMENT POLICY

Our policy is to meet consumer’s expectation and win their confidence with superior quality and wholesome dairy products at competitive prices.

WE STRIVE TO ACCHIEVE THIS GOAL THROUGH :–

Total commitment to consistent excellence in quality of products and services surpassing customers expectations
Procurement of clean milk of highest quality to produce high quality milk and dairy products
Efficient mobilization of resources and development of an inspired workforce by trainings
Integration of high technology and highest order of technical competence by meeting all applicable statutory and regulatory requirements .
Adoption of food safety management system and Eco friendly Processes.
Control of Noise, Air and water pollution by meeting regulatory requirement to safe Environment with continuous improvements.
Committed for health and Safety issues of Employer by providing safety by providing safety measures and Hospitalization in case of emergency .
Committed for Antibribe, Whistle blower and Money Laundering, Discrimination and Harassment, flow of communication Conflicts of Interest .
Committed with saving of Energy in terms of Electricity, water and steam by optimum uses of resources .

We shall endeavor to build a heritage of commitment and excellence to be the “most trustworthy” choice of consumers.

Anti-Bribery & Corruption Policy

1) Introduction

Adherence to good Governance and managing its affairs in a fair, honest, ethical, transparent and legal manner is an integral part of the philosophy of Harbansh Lal Foods Private Limited. Furtherance to its philosophy the Company formulates this Anti Bribery Policy to ensure that no employee of the Company indulges in and associate with any act of bribery, extortion or corruption with any government officials or any person for or on behalf of the Company. This Anti-Bribery Policy is based on the law of Prevention of Corruption Act, 1988 of India and other similar applicable Anti Bribery and anti-corruption Laws of India.

2) Applicability and Purpose

This policy apply to all officers, managers, employees including workers of the Company (including employees temporarily , or anyone else doing with the Company including the suppliers, contractors. The Company has a zero tolerance approach to acts of Bribery and corruption, by employees or anyone acting on behalf of the Company. Any breach of this policy will be regarded as a serious matter by the Company of which is likely to result in disciplinary action.

3) Policy

This Policy reflects the business practices and principles of behaviour that support this commitment to zero tolerance approach to acts of Bribery and corruption,.

(i) General Principals

No bribes of any sort shall be paid or accepted from customers, suppliers, politicians, government / public official, public advisors or representative’s private person or Company for or on behalf of the Company for or in respect of any business or official matters or transactions of the Company.

Bribery is committed when an inducement or reward is provided, in order to gain any commercial, contractual, regulatory or personal advantage for the Company or another party.

(ii) Business Meals and Gifts

All of the following conditions should be satisfied when offering business meals or gifts to Public Officials:

(a) Business meals or gifts offered to Public Officials should be within the range of normal social courtesies;

(b) There must be no circumstances that could give rise to any misunderstanding that such meal or gift is being offered with the intention of gaining any improper business advantage;

(c) Offering a meal or a gift should not violate the Anti-bribery Laws of the country which the Public Official works for; and

(d) The expense of the meal and/or gift should be accurately and properly recorded in the appropriate accounting books.

(e) This policy does not prohibit the practices of providing any customary gifts in a particular market, provided such gifts are appropriate and of reasonable nature in comparison to the general market practice and are properly recorded.

4) Prohibited Activities

(a) The Company Staff/covered parties should not offer and/or provide any pecuniary or other benefits to Public Officials either directly or indirectly (i.e. through a third party). Furthermore, if there is a possibility that any Business Entertainment could give rise to a misunderstanding that the

Company has conducted the Business Entertainment with the intention of gaining an improper business advantage (irrespective of its genuine intention), the Company Staff should not offer the Business Entertainment in such situation.

(b) Offering any cash (including, but not limited to, bills/notes, Cheques, every kind of cash voucher, stock certificates and securities;

(d) Any business meal or gift if the expense is not properly recorded for in the appropriate accounting books and not as per the Code of Conduct Policy of the Company.

5) Policy on Invitations

All of the following conditions must be satisfied in the case of any invitations made to Public Officials:

(a) There must be a legitimate purpose for the invitation of the Public Official, and there must be no circumstances giving rise to any misunderstanding that such invitation has been made with the intention of gaining any improper business advantage;

(b) Any expense for the invitation borne by the Company should be limited to a reasonable amount or actual expenditure;

(d) Such invitation must not violate the Anti-bribery Laws of the relevant country which the Public Official works for;

(e) The expenses for the invitation should be accurately and properly recorded in the relevant accounting books.

6) Consultation Service

If it is difficult to judge whether the planned Business Entertainment is permissible from a review of this Policy, such cases may be referred to the Directors, who will with the help of legal department will decide whether such expense is within the permitted or not under this policy.

7) Reporting incidents of Bribery and Corruption

If any member of the Company Staff discovers any intentional or accidental violation of this Policy, such member of the Company Staff should report such discovery to his/her superior or to the Directors.

STATEMENT OF BUSINESS INTEGRITY

Harbansh Lal Foods Pvt. Ltd.’s ambition is to be recognized as the benchmark for the services we provide. Our mission – to improve the Quality of Daily Life – and our objective – to make each day a better day – can only be achieved if we are also committed to the highest standards of business integrity.

Harbansh Lal Foods Pvt. Ltd. lives by its core values and its ethical principles. Every employee in the Group is expected to share these values and principles. At the center of our ethical principles is our commitment to business integrity.

This Statement of Business Integrity (this “Statement”) sets forth the Company’s standards for achieving business integrity. Adherence to these uncompromising standards is part of what it means to be an employee of an industry-leading, best-in-class company. Harbansh Lal Foods Pvt. Ltd. employees must never compromise adherence to this Statement for financial or other business objectives or personal gain. We do not tolerate any practice that is not born of honesty, integrity and fairness, anywhere in the world where we do business.

Harbansh Lal Foods Pvt. Ltd. employees are expected to abide by these principles without exception, and without seeking loopholes or shortcuts. Everything we do must be judged not only by whether it is legal, but also by considering whether it would appear ethical and fair to our colleagues, to ourselves and to the public.

Refusal to Engage in Unfair Competition

The free enterprise system is based on fair and legal competition. As a leader, Harbansh Lal Foods Pvt. Ltd. does not tolerate unfair practices to compete and win business. All of our selection and purchasing decisions are made objectively, based on price, delivery, quality and other factors, and we expect that our clients and suppliers will do the same. Harbansh Lal Foods Pvt. Ltd.’s commitment to competing fairly and openly is premised on the fact that we obtain and grow our business profitably through intelligence, creativity and hard work. Therefore, we independently determine our own pricing and financial deals and we do not make agreements with competitors to divide markets or clients.

Dealing with Clients, Customer & Employees

Harbansh Lal Foods Pvt. Ltd.’s commitment to dealing honestly and fairly with all our clients, customers and employees is founded upon our core ethical principles of trust, respect for people and transparency. This means we will honor our contractual commitments and uphold both the letter and spirit of our business arrangements. This also means that we will treat our employees fairly and we will fully comply with all applicable laws prohibiting discrimination against our employees and customers.

Refusal to Engage in Corruption

Harbansh Lal Foods Pvt. Ltd. wins business on the strength and quality of our service offerings. We do not give gifts or other things of value to public officials in order to obtain a business advantage, and we do not permit others to do so on our behalf. Nor do we engage in bribery of private parties. We would not, for example, give a gift to a government official, private customer or

prospective client in order to influence a decision relating to Harbansh Lal Foods Pvt. Ltd. or to obtain acontract. Likewise, the Group’s employees do not accept gifts or entertainment from a supplier or prospective supplier in return for business or better pricing. Harbansh Lal Foods Pvt. Ltd. employees will not accept, offer or give anything of value that could compromise an employee’s judgment, inappropriately influence others or reflect negatively on the Company. This includes making illegal or improper political contributions and providing or receiving gifts or entertainment in return for an improper business advantage. In all cases, Harbansh Lal Foods Pvt. Ltd. employees and those representing us are expected to avoid even the appearance of doing something that does not reflect the Company’s standards of integrity and honesty. The Group recognizes that certain limited gifts and business entertainment may fall within the bounds of our standards of business integrity. Therefore, Harbansh Lal Foods Pvt. Ltd. employees may generally offer or provide gifts, entertainment or other things of value to a private party when they are modest in value, consistent with applicable law and local business practiceand are not offered to gain an improper advantage. When dealing with public officials, however, employees must take particular care to make sure that they are following our policies and guidance, since gifts or entertainment that may be permissible when dealing with a commercial customer may be illegal or unethical when dealing with public officials.

Conflicts of Interest

Harbansh Lal Foods Pvt. Ltd. makes all business decisions objectively, not on the basis of any individual employee’s personal benefit or advantage. This means that Harbansh Lal Foods Pvt. Ltd. employees must recognize when a conflict may exist and always act in the best interests of the Company. Integrity dictates that all employees avoid doing anything that presents an actual or a potential conflict of interest. Conflicts of interest exist, for example, when an employee is in a position to influence a Harbansh Lal Foods Pvt. Ltd. decision that could result in a personal gain for the employee, a relative, or a close acquaintance. Conflicts can arise under many circumstances, including when an employee or close relative has a financial interest in a competitor, supplier or client of Harbansh Lal Foods Pvt. Ltd.’s.

Confidentiality, Use of Assets and Insider Trading

Harbansh Lal Foods Pvt. Ltd. employees work professionally and in good faith to advance Harbansh Lal Foods Pvt. Ltd.’s business interests. They are responsible for ensuring that Group assets are not misused or wasted, including Harbansh Lal Foods Pvt. Ltd.’s proprietary business information and other intangible property. All employees have a duty to protect confidential information about Harbansh Lal Foods Pvt. Ltd., its clients, suppliers and employees, even after they leave Harbansh Lal Foods Pvt. Ltd.. Likewise, they must not use Harbansh Lal Foods Pvt. Ltd.’s property or information for their personal gain, or that of their relatives, friends or acquaintances. Employees who have insider information — such as non-public information about financial results, mergers or acquisitions, large contract awards or strategic plans –may not use it to deal in securities of Harbansh Lal Foods Pvt. Ltd.

Financial Statement Integrity and the Group’s Records

Harbansh Lal Foods Pvt. Ltd. strives to earn the trust and confidence of its shareholders, its regulators and the public, and is committed to providing them with accurate, transparent and timely information. The integrity of Harbansh Lal Foods Pvt. Ltd.’s records is essential to these goals, and also ensures that the Company can base its business decisions on full, accurate and reliable information.

Harbansh Lal Foods Pvt. Ltd. and its employees are required to keep accurate and proper books and accounting and other records which give a true and fair view of the financial position, results of operations, transactions, assets and liabilities of the Company. These documents must be maintained in accordance with applicable generally accepted accounting principles and Harbansh Lal Foods Pvt. Ltd.’s own internal controls and accounting procedures. Employees have a duty not to make false or artificial entries in Harbansh Lal Foods Pvt. Ltd.’s books and records for any reason at any time. The Company’s assets may only be used in accordance with management authorization. Harbansh Lal Foods Pvt. Ltd. employees must never do anything that compromises the integrity of the Company’s financial statements, or coerce, manipulate or mislead outside or internal auditors with respect to the Company’s books and records.

Employee Responsibilities and Reporting of Violations

All employees are responsible for understanding and complying with this Statement and with all other applicable Harbansh Lal Foods Pvt. Ltd. policies. Failure to abide by this Statement or other Harbansh Lal Foods Pvt. Ltd. policies may result in disciplinary action up to and including termination of employment in accordance with local laws and applicable collective bargaining agreements. In accordance with local laws and regulations, employees are also responsible for reporting promptly any violations of law or Harbansh Lal Foods Pvt. Ltd. policies of which they become aware, and for raising issues or concerns as soon as issues or questions arise. All reports should be made in good faith and be properly documented. Reports of suspected violations will be treated seriously and confidentially to the fullest extent possible. Employees making such reports will not be subject to retaliation, threats or harassment, and their identity will be held in confidence to the extent permitted by law. The issues raised in this Statement are often complex, and there may be no simple answers or solutions. Unforeseen circumstances will arise in a business as dynamic and wide-ranging as Harbansh Lal Foods Pvt. Ltd.’s.

Code of Conduct

Harbansh Lal Foods Pvt. Ltd. commitment to ethical and lawful business conduct is a fundamental shared value of the Management and all other employees of the Company.

Consistent with its Values and Beliefs, Harbansh Lal Foods Pvt. Ltd. has formulated the following Code of Conduct as a guide. The Code does not attempt to be comprehensive or cover all possible situations. It encourages the Harbansh Lal Foods Pvt. Ltd. team to take positive actions, which are not only commensurate with the Values and Beliefs, but are also perceived to be so. Harbansh Lal Foods Pvt. Ltd. expects all its employees to implement the Code in its true spirit and in case of any doubt or confusion, to consult his/her immediate superior, the head of HR or the Unit Head as relevant.

This Code of Conduct is applicable to the Management and all other employees of the company.

In performing their functions, management and other employees of the Company shall:

act honestly, diligently and in good faith and integrity in all their dealings with and for the Company.
not use any confidential information obtained by them in the course of their official duty, whether from the Company or otherwise, for personal gain, or use / allow the use of such information for the financial benefit for any other person.
not engage in any business, relationship or activity, which might detrimentally conflict with the interest of the Company.
maintain the principle of need to know and also confidentiality of all material non-public information about the Company, its business and affairs.
abide by all applicable laws and regulations
not use their status to seek or accept any personal gains or favours from those doing or seeking to do business with the Company or from other employees of the company.
not accept gifts in cash or kind, either by themselves or by their close family members, particularly if this is likely to lead to a business relationship with the Company. (However, an exception to this may be made for non-cash gifts up to a value of Rs.2000/, and for items that can be reciprocated such as tickets to events, business meals etc. If refusing a gift beyond this value, would affect a relationship with the company, the gift may be accepted and handed over to the Company.)

not share any information regarding the Company, its business and/or affairs with media without the prior approval of the Directors.
not employ any of their relatives or deal with them on Company’s behalf without proper authorization, obtained after disclosing their relationship.
treat all employees with dignity, respect and concern and treat them on parity at all times.

In addition, in performing their functions, the Management shall:

not hold position of Manager/Advisor/Consultant with a competitor company.
inform the Directors of changes in their interests that may interfere with their ability to perform their duties member.

undertake appropriate induction and regularly update and refresh their skills, knowledge and familiarity with the Company.
seek appropriate clarification or amplification of information and, where necessary, take and follow appropriate professional advice and opinion of outside experts at the expense of the Company.
strive to attend all meetings of the Board of Directors and of the Board committees of which he is a member.
participate constructively and actively in meetings of the company.
where they have concerns about the running of the Company or a proposed action, ensure that these are addressed by the Directors and, to the extent that they are not resolved, insist that their concerns are recorded in the minutes of the meeting.
keep themselves well informed about the Company and the external environment in which it operates.
not to unfairly obstruct the functioning of the company
pay sufficient attention and ensure that adequate deliberations are held before approving related party transactions and assure themselves that the same are in the interest of the Company.
ascertain and ensure that the Company has an adequate and functional vigil mechanism and to ensure that the interests of a person who uses such mechanism are not prejudicially affected on account of such use.
report concerns about unethical behaviour, actual or suspected fraud or violation of the Company’s Code of Conduct policy.
acting within his authority, assist in protecting the legitimate interests of the Company, directors and its employees.
not disclose confidential information, including commercial secrets, technologies, advertising and sales promotion plans, unpublished price sensitive information, unless such disclosure is expressly approved by the directors or required by law.

This Code embodies the belief that acting always with the Company’s legitimate interest in mind and being aware of the Company’s responsibility towards its directors is an essential element of the Company’s long-term excellence.

All management personnel and other employees shall affirm compliance with this Code on an annual basis.

Human Rights policy and statement

Preamble Statement
Harbansh Lal Foods Pvt. Ltd. declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the ILO Core Conventions on Labour Standards.

Harbansh Lal Foods Pvt. Ltd. seeks to identify, assess and manage human rights impacts within our value chain in line with the following policy aims:

1. Employees
To respect the human rights of our employees, including non-discrimination, prohibition of child and forced labor, and freedom of association and the right to engage in collective bargaining. No excessive working hours and periodic shift rotation. Employees are given clean and healthy environment to work. No Harsh or inhumane treatment is allowed at any level.

2. Suppliers and Contractors
To evaluate and select major suppliers and contractors, taking into consideration Harbansh Lal Foods Pvt. Ltd.’s Human Rights and Social Policies, and to monitor their performance where appropriate. To advance the application of the ILO Declaration on Fundamental Principles and Rights at Work through engagement and collaboration where necessary. To ensure that there is no child, forced, trafficked or slave labor in the Harbansh Lal Foods Pvt. Ltd. value chain.

3. Local Communities
To respect the cultures, customs and values of the people in communities in which we operate. To contribute, within the scope of our capabilities, to promote the fulfillment of human rights through improving economic, environmental and social conditions and serve as a positive influence in communities in which we operate. To ensure the provision of security is consistent with international standards of best practice and the laws of the country, using security services only where necessary and requiring the use of force only when necessary and proportionate to the threat.

4. Society
To play a positive role, within our spheres of influence, in capacity-building for the realization of human rights. To promote the realization of environmental sustainability and development through our business. To uphold the highest standards in business ethics and integrity and where appropriate to support efforts of national and international authorities to establish and enforce such standards for all businesses.

Harbansh Lal Foods Pvt. Ltd. Human Rights Statement
Harbansh Lal Foods Pvt. Ltd. is committed to developing an organizational culture which implements a policy of support for the internationally recognized human rights contained within the Universal Declaration of Human Rights, and seeks to avoid complicity in human rights abuses.

Harbansh Lal Foods Pvt. Ltd. seeks to improve its human rights performance by referencing and implementing key international principles such as the United Nations Guiding Principles on Business and Human Rights, as well as relevant international conventions and standards such as those of the International Labor Organization.

Harbansh Lal Foods Pvt. Ltd. continues to be involved in multilateral efforts to support human rights through organizations such as the United Nations Global Compact and the Global Business Initiative on Human Rights.

Policy on Child labour, Forced labour & Freedom of Association and Collective bargaining

Child labour

Policy: Harbansh Lal Foods Pvt. Ltd. complies rigorously with all local laws and regulations and in no event employs children below 18 years.

Remediation Plan: Where child labour is found, Harbansh Lal Foods Pvt. Ltd. shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until he is no longer a child

Forced labour

Harbansh Lal Foods Pvt. Ltd does not use any form of forced or involuntary labour, and refrains from practices that can give rise to a risk of involuntary labour.

Freedom of Association and Collective bargaining

Definition: Collective Bargaining is the process by which workers/employees and employer, through their representatives, negotiate over the terms of the employment relationship. The primary goal of collective bargaining is the achievement of a collective bargaining agreement between the employer and employees/workers.

Policy: Harbansh Lal Foods Pvt. Ltd respects its employee’s right to associate freely, form or join organisations of their choosing and to bargain collectively in accordance with recognised international instruments, local laws and regulations, in full freedom and without fear of reprisal, intimidation or harassment. Harbansh Lal Foods Pvt. Ltd also recognises its employees’ right to refrain from collective representation. Harbansh Lal Foods Pvt. Ltd is committed to conduct collective bargaining with freely chosen employee representatives from employees itself.

SOCIAL COMPLIANCE POLICY

In Harbansh Lal Foods Private Limited, we believe that our success is built on a foundation of personal and professional integrity. We understand the challenge of ensuring high social, ethical and environmental standards within our business and throughout our supply chain and are committed to working collaboratively with our suppliers to ensure that that these standards are continually improving. In order to achieve this, Harbansh Lal Foods Private Limited has developed this Social Compliance policy based on the internationally acknowledged ETI base code.

This Policy defines Harbansh Lal Foods Private Limited’s minimum standards, along with the basic principles we expect from all our Suppliers and Contractors. We are committed to ensuring that the standards outlined in the policy are effectively implemented, measured and monitored throughout our supply chain and we require the support of our suppliers to achieve this goal.

1.0 SCOPE

Harbansh Lal Foods Private Limited’s management define this policy as relevant to the organisation itself, its contractors, suppliers and other parties engaged through the supply chain.

2.0 GENERAL PROVISIONS

Business Partners (including but not limited to contractors & suppliers) must comply fully with all legal requirements relevant to the conduct of their businesses.This policy communicates our values and expectations and emphasises the importance of responsible workplace policies and practices, which generally comply, at a minimum, with applicable occupational H&S, environmental and labour laws and regulations. The standards outlined below reflect the values we uphold in our own policies, and we expect our suppliers to follow these standards and requirements:

2.1 Employment is freely chosen

There is no forced, bonded, indentured or involuntary prison labour. Workers are not required to pay fees or lodge “deposits” or original identity papers with their employer and are free to leave their employer after reasonable notice.

2.2 Freedom of Association

The freedom of association and the right to collective bargaining is respected. The employer adopts an open attitude towards the activities of both trade unions and worker organisations. Workers’ representatives are not discriminated against and have access to carry out their representative functions in the workplace.

2.3 Working Conditions

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Applicable occupational Health and Safety regulations will be adhered to, and a working environment which is safe and conducive to good health shall be provided. Workers shall receive regular and recorded health and safety training Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

Responsibility for health and safety shall be assigned to a senior management representative.

2.4 Child Labour

Harbansh Lal Foods Private Limiteddoes not engage in or support the use of child labour. Suppliers and Contractors must not recruit child labour. Suppliers and Contractors must maintain formal documentation that verifies the age of each worker.If children are found to be working in directly for the supplier, the latter shall seek a sensitive and satisfactory solution that puts the best interests of the child first.

2.5 Fair wages are paid

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. Wages shall be paid directly to the workers, at the agreed intervals and in full. Overtime must be paid at an enhanced rate, at a minimum compliant with national legislation. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

2.6 Working Hours

Working hours comply with national laws and benchmark industry standards, whichever affords greater protection.Comply with applicable hour and benefits laws relative to the industry and/or local labour market.

2.7 No Discrimination is Practised

Suppliers and Contractors must comply fully with local laws regarding equality of employment opportunities. There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, nationality, origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

2.8 Regular Employment is Provided

To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

2.9 No Harsh or Inhumane Treatment is Allowed

Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. All disciplinary actions must be recorded and be fair, proportionate and fully compliant with local laws. Suppliers and contractors will ensure access to confidential means of reporting inhumane treatment and workplace grievances.

2.10 Protect the Environment

Conduct business in compliance with all applicable environmental laws, rules and regulations.Waste is minimised and items recycled wherever this is practicable. Effective controls of waste in respect of ground, air and water pollution are adopted. In the case of hazardous materials, emergency response plans are in place. In respect of packaging and paper, undue and unnecessary use of materials is avoided, and recycled materials are used whenever appropriate.

2.11 Business Integrity

Strive to provide a workplace free of bribery and corruption by complying with all applicable laws relating to bribery, money laundering and/or corruption as well as prohibiting the exchange of money or anything else of value to or from anyone, including government officials, to influence actions or obtain an improper advantage.

3.0 IMPLEMENTATION OF THE SOCIAL COMPLIANCE POLICY

Harbansh Lal Foods Private Limitedis committed not only to comply with this Policy within its own business, but to working collaboratively with its Suppliers and Contractors to drive compliance throughout the supply chain. We will support our Suppliers and Contractors in achieving this objective and will abide by the following principles in order to drive this improvement in ethical performance.