CODE of

CONDUCT
& ETHICS
As international expert in fastening and assembly solutions, ARaymond
is committed to doing business the right way.

For more than 150 years, we have upheld standards of responsible

and ethical behaviour in our own operations, and have looked for
a similar commitment from our Business Partners.

In all of the countries where ARaymond is present, our ambition

is to conduct all our activities with integrity and respect.

In addition to our innovative management style, Integrity and Respect

are the foundation that guarantees long-term visibility and a sustainable
future for our enterprise.

They are the cement of our actions, they are the basis of the trust that
we must have within our organisation and with our business partners.

Our Code of Conduct & Ethics defines the standards of behaviour

for our workplace and gives us precise guidelines as to how we may
protect the people within our organisation, the ARaymond Network,
our business partners and the environment.

It also demonstrates our objective to respect Industry Standards

and Legal requirements wherever we are present in the world.

Integrity and respect are the foundation of our corporate culture,

they are precious to who we are and we must never compromise this.

Antoine Raymond
 Introduction............................................................................................. 7
BASIC BEHAVIOURAL REQUIREMENTS....................................................................................................................................................................... 8
MAKING ETHICAL DECISIONS....................................................................................................................................................................................... 8
NETWORK COLLABORATION GUIDELINES.............................................................................................................................................................10

Human and environmental principles .............................................11

HUMAN RIGHTS AND RIGHTS AT WORK..................................................................................................................................................................12
HEALTH AND SAFETY ....................................................................................................................................................................................................12
DATA SECURITY AND PROTECTION OF PERSONAL DATA.................................................................................................................................14
PROTECTION OF THE ENVIRONMENT......................................................................................................................................................................14

Business principles...............................................................................15
PRODUCT SAFETY AND QUALITY .............................................................................................................................................................................16
ANTI-TRUST LAWS ..........................................................................................................................................................................................................16
ANTI-CORRUPTION LAWS.............................................................................................................................................................................................16
INTERNATIONAL TRADE, EXPORT ISSUES AND "BLACKLISTS".........................................................................................................................17
CONFLICT OF INTEREST.................................................................................................................................................................................................18
CONFIDENTIALITY ..........................................................................................................................................................................................................19
INTEGRITY, RECORDS AND FINANCIAL INFORMATION......................................................................................................................................20
BASIC RULES FOR MAKING PAYMENTS....................................................................................................................................................................20
MONEY LAUNDERING ...................................................................................................................................................................................................21
INTEGRITY AND PROMOTION OF BEST BUSINESS PRACTICES........................................................................................................................22

Application and governance ..............................................................23

REPORTING PROCEDURE AND COMPLIANCE AUDITS.......................................................................................................................................24
DISCIPLINARY MEASURES............................................................................................................................................................................................25
LOCAL LAWS AND REGULATIONS; LOCAL POLICIES AND GUIDELINES.......................................................................................................26
CONCERNS AND QUESTIONS......................................................................................................................................................................................26
EFFECTIVE DATE...............................................................................................................................................................................................................27
AMENDMENTS TO THE CODE OF CONDUCT & ETHICS......................................................................................................................................27
In ARaymond*, we believe being compliant with all applicable laws and
regulations and having high ethical standards is the way to secure the long-term success of
ARaymond. This, in turn, serves the interests of the ARaymond personnel, clients, shareholders
and the companies within the ARaymond Network best.

This Code of Conduct & Ethics provides the framework for the conduct of all directors,
officers, managing directors, managers and employees of ARaymond ("Employees") and
defines the basic rules of conduct within ARaymond and with our business partners. It also
reflects the underlying ARaymond values.

With effect as of 1st July 2018, ARaymond has established a compliance programme to ensure
that the operations of ARaymond and the conduct of its Employees are in full compliance with
the Code of Conduct and Ethics.

* In this document, "ARaymond" refers to the ARaymond Network, and includes all the companies within its
organization worldwide with the exception of joint ventures.

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 Introduction

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BASIC BEHAVIOURAL REQUIREMENTS Sometimes, however, situations arise where
the correct course of action is not entirely clear.
ARaymond complies with all applicable Laws
Our guiding decision process to be used by
and Regulations of the respective Legal system
ARaymond Employees to address issues is set
in which it works. Our reputation is determined
by the actions of our Employees and by the way out in the following diagram.
each Employee presents and conducts himself/
herself. Illegal and inappropriate behaviour
of a single Employee can cause considerable
damage to ARaymond.
Therefore, we expect that each Employee
behaves in a way which maintains and promotes
the high reputation of ARaymond and that they
are familiar and fully compliant with the rules
laid down by the Code of Conduct & Ethics.

MAKING ETHICAL DECISIONS

ARaymond understands that its Employees
know instinctively what is right and what is not.
Our general rule is, if something doesn’t feel
right, don’t do it.

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 Ask yourself the following questions

1 2 3 4 5
Is it the
Would I "right" thing
be happy to do?
YES to all
explaining Would As an
Is it inline what I ARaymond employee question?
YES YES YES YES YES
with our did to my be of an
Is it allowed?
Is it legal?
core values colleagues, comfortable international Proceed
and the family and if this company, with the
Code? friends appeared in ask yourself
particular
without the media? how it would
shame or be viewed action
discomfort? in a global
context

No/ No/ No/ No/ No/

Not sure Not sure Not sure Not sure Not sure

Do not Do not Do not Do not Do not

proceed with proceed with proceed with proceed with proceed with
the action the action; the action; the action; the action;
and contact seek advice seek advice seek advice seek advice
the legal or and guidance and guidance and guidance and guidance
compliance if required. if required. if required. if required.
department for
further advice
and guidance.

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NETWORK COLLABORATION GUIDELINES
The "Network Collaboration Guidelines" define
how the different ARaymond companies
manage their operations and work together
to serve customers and our objectives of
sustainable growth.
ARaymond companies should strive to respect
the guidelines, requirements and incident
escalation processes and procedures.

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 Human and
environmental
principles

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HUMAN RIGHTS AND RIGHTS AT WORK We hire, compensate and promote Employees
on the basis of their qualifications, performance
ARaymond respects and supports the
and commitment to working to promote the
protection of internationally proclaimed human
ARaymond values.
rights in line with the Universal Declaration of
Human Rights. Moreover, ARaymond provides a work
environment free from harassment or
We respect the principles laid down in the
discrimination on the basis of race, color,
Declaration on Fundamental Principles and
religion, gender, sexual orientation, national
Rights at Work of the International Labour
origin, age, disability, height, weight, marital
Organization. By adhering in 2003, to Global
status, veterans status or genetic information.
Compact, ARaymond furthermore undertook to
fully respect the Human Rights in all its activities ARaymond requires that all Employees shall
and in all countries where ARaymond operates, work together in an open and respectful
and to ensure the promotion of the said Global manner. Any behaviour or action infringing
Compact. We do not tolerate any form of forced upon these rights is not accepted.
labour neither in ARaymond nor for any of our
business partners.
HEALTH AND SAFETY
We acknowledge and promote the freedom
of association and the right of workers to ARaymond commits itself to providing a
collective bargaining within the limits of safe and healthy work environment for all
applicable laws and statutes and ensure that its Employees, and to strive for continuously
union representatives are not discriminated. improvement in this domain. This applies
whether the Employees are working on an
We do not allow excessive working hours or ARaymond facility or traveling within their
working without adequate rest periods as per professional activities for ARaymond.
applicable local legislation and comply with all
local regulations regarding payment of work. Moreover, ARaymond also requires that all
This includes any regulations for payment during service providers and subcontractors work
sick leave and any minimum wage regulations. towards this objective.
We observe all regulations in the relevant In the same way, ARaymond is committed to
countries providing for equal employment ensuring that the operations make their best
opportunities and do not tolerate any efforts not to create any health and safety risks
discriminatory treatment of Employees, unless for its neighbours and seek to permanently
national law expressly provides for selection reduce any potential related impacts on the
according to specific criteria. neighbourhood.

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ARaymond therefore requires its Employees to
be aware and follow all trainings and Internal
Rules regarding health and safety issues and
to conduct their operations in a manner which
protects their own health and safety and the
health and safety of the other Employees.
This also applies to any traveling that the
Employee may be asked to do for the company.
ARaymond expects all Employees to prepare
and inform him/herself about the destination
via the travel assistance service provided and
complete the relative training programs as may
be organised on that subject.
As each Employee is the key actor of his/her own
personal safety and those traveling with him/her,
he/she should always apply the relevant
prevention measures provided by ARaymond.
Health and safety measures and reporting of
accidents or incidents will be reviewed at least
annually by each ARaymond Company and
ARaymond Network Management.

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DATA SECURITY AND ARaymond strives to conduct its operations
PROTECTION OF PERSONAL DATA in a manner that is safe for the environment
and continually improves environmental
For the operation of its business, ARaymond relies
performance.
on the use of electronic data processing systems
and the worldwide exchange of electronic data.
We respect all applicable data protection laws
and secure personal data of our Employees,
customers and other business partners.

PROTECTION OF THE ENVIRONMENT

ARaymond strives to be recognised as an
environmentally responsible company that
respects the environment while conducting
its business activities. The protection of the
environment and the conservation of natural
resources are high priorities for ARaymond.
ARaymond operates in compliance with all
applicable environmental laws and regulations.

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Business principles

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PRODUCT SAFETY AND QUALITY In order to secure this, all supervisors are
requested to promote the compliance program
It is of utmost importance for ARaymond and
with their Employees and to secure that all
its long-term success that the products of
Employees follow the training modules provided.
ARaymond are safe and of a high quality.
The objective is that every Employee is familiar
ARaymond strives to provide flawless reliability
with the rules applicable in countries where he
and quality in all products and systems.
or she works.
ARaymond therefore expects that all Employees
shall be committed to achieve total product
quality, from design to distribution.
ANTI-CORRUPTION LAWS
ARaymond is committed to compete for
business by the quality and price of its products
ANTI-TRUST LAWS
and services, but not by offering inappropriate
ARaymond believes in free markets and fair advantages or benefits to others.
competition. Therefore, we are committed to
We will not, directly or indirectly, offer or grant
lawful and free competition and to competing
any benefit to any person in order to gain an
on the merits of our products and services. unfair business advantage. ARaymond will
We respect and observe all applicable anti-trust not induce or reward a person for improper or
and competition laws in the countries in which inappropriate performance of his/her duties.
we operate.
Therefore, we expect that our Employees or
We expect that no Employee or business partner anyone acting on our behalf, do not offer, grant
is engaged in any kind of understanding (written or accept any benefits that could be considered
or verbal) with competitors on pricing, market as inappropriate or could result in improper
allocation or any other matter that might restrict performance of the person’s professional duties.
competition and/or distort the market.
We commit ourselves to political neutrality and
Anti-trust infringements can be punished with will not make any political contributions nor
huge penalty fines of up to 10% of Global sales will we accept that anyone provide any such
turnover as well as indemnity and damages to be financial or in-kind support to any political
paid to the customers concerned. The potential organisation on behalf of ARaymond.
cost of such an incident could jeopardise the
To secure compliance with these regulations we
sustainability of ARaymond. have published an Anti-Corruption Guideline
We therefore expect that our Employees know defining processes and we expect that all
the competition and anti-trust rules. Employees are aware of this guideline and
respect it.

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INTERNATIONAL TRADE,
EXPORT ISSUES AND "BLACKLISTS"
ARaymond observes all applicable laws
regarding International trade restrictions.
All companies within ARaymond must also
observe restrictions on dealings with certain
parties in connection with combating terrorism,
categorised by State agencies in various lists.
We expect that if an Employee has any
doubts about doing business with a specific
customer or country that is or may be subject
to restrictions or penalties; he/she should
seek legal advice from the ARaymond Legal
department before starting any trade and/or
business relation. This applies at all stages of the
business relation.

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CONFLICT OF INTEREST and report such potential conflict. A Conflict
of Interest Guideline is available to provide
ARaymond expects all Employees to act loyally
Employees with more information about
towards ARaymond and to make business
potential conflicts of interest and defining a
decisions only in the best interest of ARaymond,
process of reporting such issues.
not based on his/her real or potential personal
and/or professional benefits. This also includes
undue influence or favouritism.
A conflict of interest is a situation in which an
Employee or members of his/her family or
his/her friends are involved in multiple interests,
financial or otherwise, while one of these
could possibly be, to corrupt the motivation or
decision-making of the ARaymond Employee to
the detriment of ARaymond.
We expect that each Employee takes the
necessary actions to avoid any conflict of
interest, and even any potential appearance of a
conflict of interest.
However, if a situation occurs in which
Employees may have a potential conflict of
interest, we expect those Employees to be open

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CONFIDENTIALITY
The confidential proprietary information as
well as commercial, technical and other know-
how of ARaymond are essential for the long-
term success of the organization. Therefore,
ARaymond expects that its Employees shall
not disclose confidential information and
know-how to third parties. The only exception
is where such a disclosure is required by the
business interest of ARaymond and the third
party is bound by appropriate confidentiality
and non-use obligations.
ARaymond respects confidential proprietary
information and commercial, technical and
other know-how of our Business Partners.
ARaymond guarantees effective protection of
personal data and will not request, process, or
use such data as far as it is not necessary for a
clearly defined purpose and will comply with all
applicable local data protection laws.
ARaymond expects from all of its Employees
that they will not discuss with, or disclose to,
any third party, financial data unless required
for legal purposes or where the information
has been officially released by the Local finance
manager or the ARaymond Network CFO.

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INTEGRITY, RECORDS The documentation must be immediately
AND FINANCIAL INFORMATION forwarded to the local Finance Department.
ARaymond expects absolute integrity Every amount payable or receivable must
from all Employees and will not tolerate match with a material item, an actual service
any inappropriate behaviour, irrespective or actual expenses. Any amounts payable
of whether it concerns the company or its as reimbursement of expenditure must be
Employees, any customers, suppliers or other substantiated by accounting or supporting
intermediaries, banks and other providers of documentation.
financial resources, or public institutions. All payments must be made to the party
directly. The bank account of the party shall
designate the name of the corresponding
BASIC RULES FOR MAKING PAYMENTS
beneficiary. Employees shall not make any
Each payment by or on behalf of ARaymond transfers to any numbered accounts or third-
must be made only on the basis of appropriate party accounts unless validated by local Finance
(written or electronic) documentation, which Manager. Even if the payment is made to the
clearly reflects the reason of the payment and beneficiary directly, it shall be made only to an
that the payment is due. account of such beneficiary in a country where
Each payment by or on behalf of ARaymond the beneficiary has its seat or corresponding
must be approved by at least two authorised place of business. Any exceptions require the
persons. Any exception to this practice must be prior written approval of local Finance Manager
validated by the ARaymond Network CFO. or ARaymond Network CFO.
In order to ensure transparency, to the
extent possible, payments by or on behalf of
ARaymond shall be made by wire transfer.
Cheque and cash payments shall be avoided to
the extent possible and are permitted only for
out-of-pocket expenses (such as payment of
business meals, taxi rides, stamps).
If a cash payment cannot be avoided, we expect
our Employees to document the relevant
payment and specify the names of the payer
and person having approved the cash payment,
the name and address of the recipient, the
amount, date and purpose of payment.
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MONEY LAUNDERING
ARaymond is committed to conducting
business only with reputable suppliers,
customers and other business partners who
conduct their business in a lawful manner
and whose funds are derived from legitimate
sources. Therefore, all Employees must observe
the relevant internal company procedures
designed to detect and deter suspicious forms
of payments.
Any major cash payments by customers and
other persons to ARaymond and any payments
from third party accounts shall be accepted only
after having reviewed the legitimacy and the
legality of the business transaction.

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INTEGRITY AND PROMOTION
OF BEST BUSINESS PRACTICES
ARaymond will only do business with partners
who at least share the basic principles and
values laid down in this Code of Conduct &
Ethics. If an Employee discovers any behaviour
of a business partner of ARaymond which is not
in line with our basic principles or values he/she
shall report this to the Compliance Department.

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 Application
and governance

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REPORTING PROCEDURE good reason to believe had occurred (whistle-
AND COMPLIANCE AUDITS blower) shall not be subject to retaliation or
adversely treated because of such report. The
Reporting procedure identity of the Employee who makes the report
and the information shared will be kept strictly
ARaymond is committed to promoting an
open, responsible and safe culture wherever it confidential.
operates. ARaymond wants all of its Employees Compliance audits
to feel that they can raise legitimate concerns
about actual or alleged wrongdoing, securely ARaymond will, at regular intervals, conduct
and without fear of recrimination, and to know compliance audits of selected matters to ensure
that their confidentiality will be respected. compliance with the Code of Conduct & Ethics,
the Anti-Corruption Guidelines, but also with
Employees who know or have good reason the applicable laws and regulations. The results
to believe that a case of non-compliance with of such audits will be reported to the Presidency
any laws or regulations, this Code of Conduct & and the Risk & Compliance Committee.
Ethics or any other compliance guidelines has
occurred, are encouraged to bring this matter to
the attention of ARaymond.
Employees may raise a concern with their
line manager, other senior manager or with
HR. However, if this is difficult for any reason,
they can raise their concern directly with our
Professional Whistleblower Service provider,
SAFECALL.
SAFECALL will pass their concern on to our
Compliance Department for investigation.
SAFECALL can be contacted 24/7 via phone,
secure web portal or email.
All contact details for SAFECALL can be found
on your company’s intranet or via shARe.

Protection of whistle-blowers
An Employee who reports a case of non-
compliance of which he/she was aware or had

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DISCIPLINARY MEASURES
ARaymond will not tolerate any violation of
the Code of Conduct & Ethics or of applicable
laws and regulations and any infringement may
result in disciplinary actions, including dismissal,
in line with applicable local laws and the
provisions of the internal rules and regulations
of each entity of ARaymond.
The procedural guarantees and rights of the
Employees in the scope of a disciplinary action
are those provided for in the internal rules and
regulations of the entities of ARaymond.
Moreover, Employees must be aware that the
violation of certain laws and regulations, in
particular anti-corruption, may trigger criminal
penalties (fines, imprisonment) and damage
claims against the relevant Employee.

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LOCAL LAWS AND REGULATIONS; If an Employee has questions about the Code
LOCAL POLICIES AND GUIDELINES of Conduct & Ethics or the applicable laws and
regulations or if he/she is not sure in a specific
To the extent that the rules provided in the situation what to do, he/she is encouraged to
Code of Conduct & Ethics of ARaymond do contact his/her supervisor, the local HR and or
not comply with any compulsory local laws or Legal or the Compliance department.
regulations, such compulsory local laws and
regulations shall prevail, and the Managing If an Employee is unsure whether his/her action
Director of the relevant ARaymond Company is legal or in line with the Code of Conduct &
shall inform the Compliance Department. Ethics, he/she should follow the principle:
Ask first, act later.
The internal guidelines of individual ARaymond
companies may provide for stricter rules than
those provided in this Code of Conduct & Ethics.
Local requirements will not provide for rules
that are less strict, unless explicitly approved
beforehand by the Compliance Department.

CONCERNS AND QUESTIONS

If an Employee has concerns and/or questions
about the Code of Conduct & Ethics or the
overall compliance programme, he/she should
contact the Compliance Officer.

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EFFECTIVE DATE
The Code of Conduct & Ethics shall become
effective on 1st July 2018, following the
information and consultation procedure of staff
representatives and the performance of filing
and publication requirements.
ARaymond shall bring, through any means
whatsoever, this Code of Conduct & Ethics to
the attention of the people entitled to access
the workplaces or recruitment premises.

AMENDMENTS TO THE CODE

OF CONDUCT & ETHICS
Any subsequent amendment to the Code of
Conduct & Ethics (addition, removal, etc.) shall be
subject to the same implementation procedures
as this Code of Conduct & Ethics (in particular,
prior information and consultation procedure
of staff representatives, filing and publication
requirements), in accordance with applicable
legal, conventional and/or regulatory provisions.
It is reminded that any provisions of this Code
of Conduct & Ethics that would be contrary
to applicable law, as a result of a legal and/or
regulatory development, will automatically
become null and void.

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Published by the ARaymond Risk & Compliance Manager 1st July 2018 © ARaymond. All right reserved.
This document and all its content, including images, logo, information, are the sole property of ARaymond. No part of this publication
may be reproduced or transmitted to a third party in any form, or by any means, without the express written permission of ARaymond.
Intellectual property rights shall not be granted by the delivery of this publication or the disclosure of its content.
© ARaymond 38000 Grenoble, France, 2018. All rights reserved. ARaymond, its logo and the product names are registered trademarks.