1. Conflict of Interest

Every employee is required to proactively disclose any relationships that may lead to conflicts of interest. If a potential conflict arises, it must be reported truthfully to the company. Suppliers claiming personal relationships with company leaders must have their procurement process managed strictly in line with the company's regulations.

In general:

• Companies in which former WUS employees invest, hold shares, or hold key positions are not permitted to become suppliers. If necessary, they must go through the declaration process.
• Employees who leave WUS cannot act as business interfaces with WUS for suppliers within five years of their departure. If this occurs, procurement personnel should request a new point of contact from the supplier.
• Employees must declare any financial interest (direct or indirect) in a business relevant to the company.
• Employees should ask themselves the following questions or consult their supervisor or the Audit Office if unsure:
• Do my personal interests interfere with the company's interests?
• Could this situation be seen as a conflict of interest by others?

Example: An employee responsible for selecting a supplier discovers one of the candidates is owned by their spouse. The employee should either withdraw from the selection process or remove their spouse's company from the list of options.

2. Gifts

Employees must avoid inappropriate behavior, including accepting or offering kickbacks (disguised or otherwise) except in reasonable business dealings. Gifts must be reported in a timely manner and publicly disclosed on the company's platform. Hidden reporting or violations must be reported to a supervisor or the Audit Office.

Examples:

• An employee managing business with a travel agency receives a personal discount not offered to others and fails to declare it. This violates the company’s code of ethics.
• If a supplier invites you to an event that involves travel or special accommodations, consult your supervisor to determine if it is business appropriate.
• In the case of a supplier providing refreshments to employees, report this to procurement to explain the reasons.

3. Sensitive Positions

Each department is responsible for defining sensitive positions and establishing job rotation plans, including rotation schedules and communication strategies. Employees in sensitive positions must comply with the rotation process.

Company employees must:

• Comply with ethics and laws and use good judgment.
• Always put ethics and integrity first when making decisions.
• Avoid any conflicts between personal interests and company interests.

Employees should reflect on their actions using the following questions:

• Is this compliant?
• Is this ethical?
• Is this legal?
• Will this reflect positively on me and the company?
• Would I be comfortable seeing this reported publicly?

If the answer is "no" to any of these questions, the action should not be taken. If unsure, employees should seek guidance from their supervisor or the Audit Office.

4. Requirements for Supervisors

Supervisors must act with integrity, avoiding any conflicts of interest and ensuring they do not misuse their position to gain improper benefits. They should safeguard company assets and act in the company’s best interest, treating all customers, suppliers, competitors, and employees fairly.

Supervisors are responsible for:

1. Encouraging open, honest communication and creating an environment where employees can report concerns without fear.
2. Ensuring their team understands their responsibilities under the company’s Code of Conduct.
3. Promoting professional ethics and compliance with laws.
4. Evaluating employees based on ethical behavior and compliance with the Code.
5. Never encouraging employees to achieve business goals at the expense of ethics or the law.
6. Taking immediate action and reporting any unethical behavior to the Audit Office.
7. Listening carefully to employees' concerns regarding the Code of Conduct and providing clear guidance.
8. Reporting any unethical or illegal behavior promptly.
9. Protecting whistleblowers from retaliation.