Code of Conduct

Ethics

Frontgrade is committed to establishing and maintaining high ethical standards in all aspects of our business. We do this by empowering people to act correctly and to do the right thing in the right way. Ethical behavior is an asset that we value, encourage and reward.

To that end we have a rigorous Ethics and Compliance Program. Every employee – from the C-suite to the newest hire – is trained and retrained in determining if something is wrong and what to do about it. They are encouraged to always be aware and curious and ask questions.

In addition to raising concerns with a supervisor, manager, the Ethics and Compliance Officer, or Human Resources, Frontgrade provides an anonymous helpline – hosted by an independent third-party, which can be accessed by phone or online.

We have also created Ethics Champions for each of our locations. These are trusted senior leaders who carry out a range of compliance activities to help promote a good ethical culture, including acting as a “sounding board,” to whom business unit employees can bring questions or raise concerns in confidence. As such they also provide another channel for the raising of ethical concerns and other issues.

Code of Business Conduct

Our Code of Business Conduct is the centerpiece of our commitment to ensure our employees adhere to the highest standards of business ethics. It gives us a shared clear purpose, uniting all parts of Frontgrade. The Code sets out the core principles and expectations governing the behavior of all employees and is a resource for employees to use whenever they need guidance or if a difficult or uncomfortable work situation is encountered. It helps them make an informed decision or describe what actions to take to find out what to do in order to do the right thing.

Simply put, it provides a framework for employees faced with a difficult business situation. It asks them to consider the following questions before taking any action:

• Is it Legal?
• Is it in line with the behaviors we’ve set for ourselves?
• Does it comply with our Code and Corporate Framework policies and policy requirements?
• What would their family, friends, manager, or colleagues think about their decision?
• Would they feel comfortable if they read about their actions in a newspaper?

These are not just words or suggestions. Failure to comply with any provision of our Code is a serious violation and may result in disciplinary action, including termination of employment. Such consequences may apply to employees who commit misconduct, and to those who condone it, or fail to report it.