TABLE OF MOST VALUED RESPONSIBILITY WORLD CLASS CONTENTS INTRODUCTION PARTNER WINNING TEAM & INTEGRITY PERFORMANCE RESOURCES Back Next Last Page 15 We prohibit all forms of corruption We avoid conflicts of interest We must strictly abide by anti-corruption laws everywhere that We avoid situations where our personal interests could affect our DID YOU KNOW? Applied operates. This includes, but is not limited to, the United ability to perform our jobs or appear to place our personal interests “Government” is defined broadly and includes States Foreign Corrupt Practices Act (FCPA) and United Kingdom over Applied’s interests. We disclose any actual or potential conflict any government department, agency, office, or Bribery Act (UKBA), which prohibit all forms of bribery and of interest, as well as anything that could be perceived as a conflict. instrumentality at any level, including a government- corruption by our directors, officers, employees, agents, and others This includes the following: owned or -controlled company or a public institution acting on our behalf. This means that we never offer, promise, (such as a government-funded hospital, university, ■ You want to serve as a member of an outside board or school, or research institute), a public international accept or facilitate bribes, kickbacks, or other corrupt activities – advisory group. organization (such as the World Bank or United including money, favors, gifts, entertainment, donations or other Nations), a political party, or a royal family. Visit the benefits or gratuities that are intended to improperly influence Global Ethics & Compliance webpage (ethics/ in your ■ You or a family member have a financial interest or leadership Applied browser) to view a list of government-linked the decision-making of the recipient. This prohibition applies to position in a current or potential supplier, customer, other companies with which Applied works. both public sector and private sector interactions, but we must business partner, or competitor of Applied. APPLIED VALUES IN ACTION exercise extra caution when interacting with a Government Entity ■ or Government Official. You are involved in business activities outside of Applied, such What should I do if I am asked by a technology When exchanging gifts, meals, entertainment, or travel – or other as consulting work, part-time employment, or ownership of an start-up to join its technical advisory board? I outside business. won’t receive a salary, but I will receive stock items or experiences of value – with business partners, you must in the company, and I will have access to its ■ confidential information and intellectual review and comply with the Global Policy on Giving and Receiving You have a close personal relationship (familial or romantic) property. Is this a conflict of interest? Business Gifts, Meals, Entertainment and Travel (“GMET Policy”), with someone working for a current or potential supplier, Yes, the above situation presents a potential conflict including applicable pre-approval requirements. customer, or competitor of Applied, or a Government Official (a of interest. Global Ethics & Compliance should “Government Official” is an employee of a government agency, evaluate whether the company is an existing or government-owned or -controlled company, public institution, potential supplier, customer, or competitor of or a political candidate). Applied, or a potential acquisition or investment target. If it is, it most likely would not be approved. ■ You have a close personal relationship (familial or romantic), or FIND OUT MORE: a business relationship, with any director, officer, employee, or Conflict of Interest Disclosure Form contingent worker of Applied. Corporate Donations Form Global Ethics & Compliance reviews each disclosure, evaluates how Employment of Relatives Policy the conflict can be managed or whether the conflict is so significant Global Anti-Corruption Policy that it cannot be managed. Global Conflicts of Interest Policy Global Policy on Giving and Receiving Business Gifts, Meals, Entertainment and Travel (“GMET Policy”) GMET Approval Form ethics/