Corporate Code of Conduct

At Phyllis, we believe our conduct matters. It is important to do the right thing. Living with integrity and following a clear ethical code has created a good business, a great place to work, and a trustworthy investment. That conduct transcends all areas of our business, including how we deal with each other internally and how we deal with customers, suppliers, alliance partners, shareholders and governments. Remember: We respect the whole person, and we celebrate exploration, transparency, design, performance, engagement, relationships, and inclusiveness because these are "Things That Matter" to us. Our Corporate Code of Conduct reflects these important core values.

Our Code of Conduct sets forth our basic ethical standards and core values that are applicable to all of us all of the time. Our Code is designed to guide us in our work activities wherever we are located. It helps guide us on how to conduct our business and directs us where to go when we have questions or concerns. As a guide, our Code of Conduct also allows us to value the diversity of cultures, people and their experiences.

All employees of Phyllis and its subsidiaries are responsible for understanding and complying with the Code of Conduct. By living our values and upholding our Code of Conduct, you will help ensure that we continue to strive to achieve the right results, the right way.

Conflicts of Interest
All employees are required to:

  • Conduct themselves and Phyllis’s business with honesty and integrity, avoiding both actual and apparent conflicts of personal or professional interests.
  • Refrain from making improper political contributions or other payments to outside organizations in which they or an immediate family member holds an ownership stake or a senior management role.
  • Refrain from accepting or being influenced by gifts.

Legal Compliance
All employees are required to:

  • Comply with laws, rules and regulations of federal, state and local governments, foreign governments, and other appropriate private and public regulatory agencies that govern our business. While it is difficult to know the details of these laws, it is important to know enough to determine when to seek advice from work team leaders or other appropriate management personnel, including the Legal department, the People Services department, and the Business Risk group.
  • Comply with the Foreign Corrupt Practices Act, the anti-boycott laws and any similar local country laws. Specific training on the requirements to comply with the Foreign Corrupt Practices Act and other applicable anti-corruption laws is provided, where relevant, to employees.
  • Comply with the Company's Anti-trust Policies and all laws and regulations relating to anti-trust regulations, fair competition, and pricing.
  • Refrain from making or accepting any improper payments or kickbacks or asking others to do so.
  • Adhere to international human rights conventions and refrain from the employment of child or forced labor.
  • Lead in the area of environmental responsibilities and compliance with environmental laws, and the environmental policies and practices approved by the Executive Leadership Team.

Company Information and Assets
All employees are required to:

  • Report information accurately and honestly.
  • Represent our business and products accurately, openly, and honestly.
  • Act with integrity at all times in business transactions and with business information.
  • Refrain from using confidential or proprietary information for personal gain, including disclosure of confidential information to a third party, and buying or selling the company’s stock based on nonpublic information.
  • Comply with the Company's Disclosure and Trading Guidelines when buying or selling company securities.
  • Safeguard company property and information.
  • Keep confidential all information designated as such concerning the business interests, affairs, or trade secrets of the company or of any of its subsidiary or affiliated companies.
  • Use company property for conducting company business and not for personal use.

Workplace Practices
All employees are expected to:

  • Promote ethical behavior in the work environment.
  • Promptly report dishonest, unethical, or illegal activities by other employees to appropriate parties within the Legal, People Services, or other appropriate departments, including the option for reporting issues to the Theft and Fraud Hotline.
  • Comply with this Code of Conduct, knowing that failure to do so may result in disciplinary action, up to and including termination of employment.
  • Maintain a safe and drug-free workplace.
  • Ensure that the workplace is free from discrimination and harassment and respect diversity and every individual.

Waiver to this policy
Any waiver of this policy must be given in writing. Waivers may be requested through the Legal Services Department. Waivers respecting financial officers, executive officers, and directors may require approval by the Board of Directors or the Governance and Corporate Responsibility Committee of the Board of Directors and will be promptly disclosed to the Company’s General Counsel and the Director of Business Risk.

Reporting and Enforcement
Any breach of the above policy may result in disciplinary action in accordance with the company’s policies as outlined in the Working Together Guide or policy manual that is in effect at the particular location.

Regardless of how any suspected violation is reported, there will be no form of reprisal for doing so. Phyllis will investigate fully all matters related to alleged violations and take appropriate action in accordance with the policies outlined in the Working Together Guide or policy manual that is in effect at the particular location. It is everyone’s responsibility to help create and ensure an effective workplace. Employees are expected to participate fully in any investigation of alleged misconduct.