CODE OF CONDUCT

01. Why does STFA have a Code of Conduct?
02. Areas of concern
03. Personal obligations
04. Fair Working Environment
05. Conflict of interest
06. Business entertainment and gifts
07. Antitrust
08. Compliance with the law
09. Use and protection of business assets and confidential information
10. Reporting Violations
11. Ask before acting
12. Remember these rules

STFA has adopted this Code of Conduct in order to describe the standards its employees must meet. The code defines what STFA expects of its people regardless of location or background.

The standards are based on:
• Support of and respect for the protection of internationally proclaimed human rights
• Ethical and legal behavior
• Loyalty to STFA
• Fair, courteous and respectful treatment of employees
• Professionalism and good business practice

All employees must adhere to the principles and requirements contained in this code and should consult the code for guidance when acting on behalf of STFA.

This Code contains rules including:

• Personal obligations
• Fair Working Environment
• Conflict of interest
• Bribes, kickbacks, business entertainment, gifts
• Insider trading
• Antitrust
• Compliance with the law
• Use and protection of business assets and confidential information
• Reporting violations

This Code of Conduct shall apply to all operations of STFA and supplements the present or future policies, guidelines and rules adopted by STFA. This Code of Conduct also clarifies the Group’s position in key areas. We strive to ensure that our business partners, customers and suppliers understand our standards and, wherever possible, act accordingly in all areas of concern.

All employees are expected to follow this Code, the law and adhere to high ethical standards. They should demonstrate social and environmental responsibility, professionalism, and use good business practices in performing their jobs.

Candor, trust and integrity are fundamental STFA values which must be respected. Employees should also be familiar with good business practices relevant to their jobs and should implement them conscientiously.

Employees shall use good judgment and common sense in all situations when the requirements of the law or of good business practices appear unclear. Employees should seek advice and direction from their supervisors in such situations.

a) Employees’ Responsibilities

It is the primary responsibility of all employees to abide by this code. Hence, all employees of STFA have the responsibility to;
• Act in accordance with laws and regulations under all circumstances,
• Read the Code of Conduct, learn, understand, internalize, and act in accordance with it,
• Consult their manager or Human Resources about potential violations concerning self or others,
• Urgently report potential violations by self or others; notify manager and/or Human Resources.

b) Managers’ Responsibilities

STFA managers have additional responsibilities, further to those defined for employees. Accordingly, it is the managers’ responsibility to;
• Create and preserve a company culture and working environment that promotes the code,
• Be a role model in practicing the code; educate their personnel on the code,
• Support their employees in expressing their questions and in filing their complaints/notifications concerning the code,
• Offer guidance regarding what should be done when consulted, diligently consider all ethical concerns raised,
• Structure all work processes under his/her responsibility in a way as to minimize ethical risks and implement necessary methods and approaches to ensure compliance with the code.

Each employee is entitled to fair, courteous and respectful treatment by his/her supervisors, subordinates and peers. Through establishing a fair, healthy and safe work environment in which employees are respected and all relevant laws and regulations are complied with, the intent is to improve and increase employee performance, development and commitment.

STFA will not tolerate discrimination or harassment based on race, religion, creed, national origin, sex, disability, age or any other relevant category.

Business transactions must be conducted with the best interests of STFA in mind. Nobody, whether an individual, a commercial entity, or a company with a relationship to a STFA employee, may improperly benefit from STFA through his or her relationship with the employee or as a result of the employee’s position in the company. Furthermore, no employee may personally benefit in an improper way. Employees must avoid situations in which personal interest may conflict with, or even appear to conflict with, the interests of STFA. Situations which may cause conflict between an employee’s responsibilities towards STFA and his/her personal interests should be avoided. Nevertheless, a conflict of interest, or the appearance thereof, may occasionally arise. Should such a situation occur, communication between employer and employee is of utmost importance, and the parties concerned shall attempt to resolve the matter in good faith.

Also, we give utmost importance to fulfill responsibilities to our customers, suppliers and business partners.

Towards our customers; We deliver our services on time and under the promised conditions to our customers. We approach our customers with respect, honour, fairness and courtesy.

Towards our partners; We act with financial discipline and accountability, manage our resources and assets with a sense of efficiency and economy.

Towards our suppliers; We act respectfully and fairly. We protect the confidential information.

STFA employees are prohibited to receive any kind of benefits or gifts, with or without an economic value, that influence or might influence their impartiality, performance, and decision-making while carrying out their duties.

It is forbidden to receive gifts or benefits that are openly or implicitly requiring reciprocation.

It is forbidden for the Company employees to accept unrequited money or to borrow money from sub-employers, suppliers, consultants, competitors or customers; or to request or accept these people and/or organizations to pay their travel expenses, activity expenses, or similar expenditures.

In exceptional cases where local culture requires exchange of gifts that are above the values established by company policy, these gifts may only be accepted in the name of STFA, and upon the approval of STFA top management.

STFA and its employees shall respect the principles and rules of fair competition and shall not violate applicable antitrust laws. STFA act respectfully and fairly as expected from a good customer and ensure to fulfill its liabilities on time.

Compliance with the law is an absolute requirement for STFA and its employees. Each employee is expected to be familiar with the law as it applies to his or her job; management is expected to provide necessary instruction and advice. Employees involved in foreign business transactions must be familiar with all applicable foreign and domestic laws and regulations.

STFA has a wide variety of assets, including physical assets, proprietary information, intellectual property, business strategies, financial information, business plans, technical information, information about employees and customers. Good business practice dictates the careful use and protection of STFA assets. In particular, information and trade secrets should be protected by keeping them confidential and, if appropriate, by seeking additional protection through acquisition of intellectual property rights. STFA employees who receive or learn of confidential business information or trade secrets of STFA may not, for non-business purposes, disclose that information to third parties (including friends and family members) or make any other nonbusiness use of such information. Moreover, they should take reasonable measures to otherwise safeguard and protect information and trade secrets. Handling and dissemination of information is a management task and all employees shall respect the need of STFA for professional information management.

You are encouraged to report any conduct that you believe, in good faith, to be a violation of laws or the Code of Business Ethics to your manager or in accordance with locally established procedure. If your manager is involved in the situation that you wish to report or cannot or has not adequately addressed your concerns, you are requested to report to a manager of higher rank or in accordance with locally established procedure.

Managers are expected to seriously address the issue and work to ensure a satisfactory resolution in alignment with our Group ethics and values and with any local statutory or regulatory obligations.

• Is it legal?
• Does it follow STFA requirements?
• Is it right?
• How would it look to others?
– for example, to our customers, the newspapers, and the people in the communities where we work?

• Know the legal and company requirements that apply to your job.
• Follow these standards.
• There are many ways to get help
– the important thing is to use one of them.
• Ask if you are ever unsure what is the right thing to do.
• Keep asking until you get an answer with which you are comfortable.