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InfiniValue’s Code of Business Conduct and Ethics (Code) is designed to guide the conduct of all our employees, regardless of location, function or position, on ethical issues that are faced during the normal course of business. Acting with integrity requires making decisions based on what is right. The Code, along with our core values and mission, assists us in putting our values into action.

When faced with a decision for which there is no clear course of action, we must ask ourselves: Will my decision reflect our core value of Integrity? How would the decision make customers, co-workers, family, and friends feel about the Company and me? Considering these questions can help us make sure we continue to operate in an ethical and legal manner. Every Director and employee of the Company is accountable for adhering to the Code. All employees are responsible for certifying annually that they have read this Code and agree to act in accordance with the principles of integrity and ethical expectations.


What are the consequences of violating the Code?

A breach of the Code can put the Company at substantial risk. Every employee is accountable for his or her own behavior. Failure to follow the Code will result in appropriate disciplinary action, up to and including termination of employment or relationship with the Company.


How do I report suspected violations?

All employees and Directors are expected to promptly report suspected unethical, illegal or fraudulent activity by anyone working for or on behalf of the Company. Certainty that inappropriate activity has occurred is not required. We have personnel who have the skills and resources to investigate situations and determine if concerns are substantiated. Raising concerns takes courage. But it’s an important part of ensuring we do business with integrity. Prompt reporting may allow the Company to avoid or mitigate serious harm to the Company or others.

Employees are expected to report concerns of unethical, illegal or fraudulent activity. With respect to performance-related issues, such as a co-worker taking long lunches, working overtime without appropriate approval, wearing inappropriate business attire, repeatedly surfing the web or texting on Company time, or generally not being productive, it is more appropriate to report directly to a leader or Human Resources.


What happens after I report a concern?

All reports are taken seriously and are investigated by various areas, including Human Resources and Legal/Compliance, external investigators and others as needed to determine whether the concern is substantiated. Concerns may be reported anonymously through our online reporting form. Anonymous reporters are encouraged to follow up (using the username and password created when they submitted their report) for additional questions investigators may have. We do not tolerate, and take aggressive action against violations of the Code, whether perpetrated by employees or by people outside of the Company. The chief compliance officer oversees investigations and responses to concerns and reports to the Audit Committee of the Board.

How am I protected from retaliation for reporting a concern?

Reported concerns are treated confidentially. The Company will not retaliate against any employee who in good faith reports suspected unethical conduct or violations of law as stated in the Company’s Whistleblower Policy. Retaliation against an employee for reporting an issue in good faith is itself a violation of our Code. If you know or suspect that retaliation has occurred or is occurring, you should report it.


Additional considerations

This Global Code of Business Conduct and Ethics has been approved by senior leadership and the Board. Nothing in the Code prohibits you from providing truthful testimony or accurate information in connection with any investigation being conducted into the business or operations of the Company by any government agency or other regulator that is responsible for enforcing a law on behalf of the government; providing information to the appropriate government regulatory agency or body regarding conduct or action undertaken or omitted to be taken by the Company that you reasonably believe is illegal or in material non-compliance with any financial disclosure or other regulatory requirement applicable to the Company. You are not required to obtain the approval of, or give notice to, the Company or any of its representatives of any such action taken.


Discrimination and Harassment

We believe in treating each other with respect and dignity, and in fostering an atmosphere of open communication, trust and mutual respect. We maintain a work environment that is free of discrimination and harassment. We are committed to the fair treatment of all employees and applicants for employment and make employment decisions based on qualifications, demonstrated skills and achievements. We comply with employment laws in every country where we operate. We do not tolerate verbal or physical conduct by any employee that harasses another employee or creates an intimidating, offensive or hostile work environment. We help each other by speaking out when a co-worker’s conduct makes us uncomfortable.

We must each hold ourselves accountable to the highest professional standards, with mutual respect and fair treatment as the basis of all professional relationships. All employees have a duty to report discriminatory or harassing behavior immediately to your Human Resource contact


Diversity and Inclusion

We promote a diverse and inclusive workplace and rely on diversity to inspire creativity and innovation to help serve customers around the world. We respect the local cultures and traditions in the communities in which we operate, consistent with our fundamental principles of fairness and equality. Employees, applicants for employment, customers, sales persons and suppliers of all different backgrounds are welcomed, respected and valued. We must all work together to promote a culture that respects each other’s diverse backgrounds, experiences and opinions to enable each of us to contribute to our full potential. Privacy and Confidentiality We protect the privacy and confidentiality of employees’ personnel records. We will not compromise an employee’s trust by disclosing confidential information to anyone without a business need for the information.


Workplace Safety

We are committed to protecting the health and safety of employees in the workplace around the globe. Employees are required to follow all safety laws and procedures and to report any unsafe conditions immediately. We do not tolerate, in any manner, any threats, acts or intent to commit a violent act that jeopardizes, or appears to jeopardize, the safety of employees, sales persons, visiting guests or physical assets.


Customer Complaints

Ensuring that customers are treated fairly is the heart of our business. Customer complaints give us valuable information to help improve customer service by alerting us to problems that need attention. Done correctly, complaint handling provides us with an opportunity to rebuild relationships with our customers when something has gone wrong. We must each take steps to help resolve complaints promptly and appropriately. We must do so in accordance with the applicable business area’s complaint-handling procedures to ensure complaints are recorded, resolved and reported in a compliant manner. Fair Dealing with Customers We are proud of our reputation of integrity in the marketplace. We offer our products and services based on accurate and truthful representations. Each of us must deal fairly with customers, suppliers and competitors. We do not misstate facts, provide misleading impressions or make false claims about our capabilities or our competitors to gain an advantage. We do not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, misrepresentation or any other unfair dealing practice.


Privacy and Information Protection

We are committed to protecting the privacy and confidentiality of all sensitive information about our customers, our associates and our Company. It is essential that others know that information entrusted to us is handled with integrity and discretion. We collect only information needed or appropriate for business purposes, and do so only by lawful and fair means. In accordance with the privacy laws applicable in the country of operation, we appropriately safeguard the security and confidentiality of Company records containing personally identifiable information. We must each access and/or use customer information for appropriate business purposes only. Training on appropriate handling of information is provided to those who are entrusted with access to sensitive customer information.


Conflicts of Interest

Business decisions at InfiniValue are made on the basis of sound business judgment, not based on any personal interest or gain. We must all avoid situations that may create, or even appear to create, a conflict between personal interests and the interests of the Company. If you have an actual or potential conflict, you should report it immediately in accordance with the applicable conflicts of interest policy for your location.


Financial Reporting and Accountability

We are committed to transparency in the financial reporting process. Our financial reports and accompanying disclosures are truthful, complete, fairly presented, timely and understandable. We have built and continue to maintain a robust system of controls to help ensure the integrity of our financial reporting processes and financial statements. Each of us involved in creating, transmitting or entering information into Company financial records is responsible for doing so accurately, completely and with appropriate supporting documentation. We are committed to providing timely, orderly, consistent and credible information consistent with legal and regulatory requirements


Gifts and Entertainment

We do not accept or offer gifts or entertainment (including travel and seminars) that might influence or appear to influence the decisions that we or the recipients must make in business transactions involving the Company. Gifts and entertainment activities must be legal and should not be frequent or extravagant. We must take particular care in accepting gifts or entertainment from suppliers. Before accepting or offering any gifts or entertainment, we are each responsible for making sure it is allowed under the applicable corporate and business area policies and in accordance with laws and ethical standards.


Protection and Proper Use of Company Resources

We all have a responsibility to use Company resources honestly and efficiently. All resources should be treated with care and used for legitimate business purposes. Suspected or known loss, theft, damage or misuse of resources should be reported immediately. We are each expected to use our computer and network systems appropriately and in accordance with Company policy at all times. Multiple technology resources are available to help do our jobs. In some cases, we may be able to use personal devices to perform certain work-related functions. It is important to follow Company policy and protect the information stored on or sent through these resources.


Records Retention

We retain and destroy Company records in accordance with all legal, regulatory and business recordkeeping requirements. Each of us must follow procedures for destroying records after termination of the retention period, provided the record is not needed for an imminent or pending legal or regulatory action. We do not alter, conceal or destroy documents or records that are subject to an investigation or which may be used in an official proceeding. Records should be destroyed in a manner designed to protect the confidential information of our customers.


Social Media

Social media activities at or outside of work that affect job performance, the performance of others or the business interests of InfiniValue must follow appropriate ethical business practices and guidelines. Employees who choose to participate in social media need to do so in a way that helps protect themselves, their co-workers, the Company’s reputation and follows the law.


Compliance with Laws

We are committed to conducting business in full compliance with applicable laws and regulations of the countries and communities in which we do business. Our business is highly regulated and is conducted in many jurisdictions. As a result, we are subject to multiple, and sometimes differing, laws and regulations. We must each be familiar with and act in compliance with the laws that affect our jobs. Because laws are often complex, you are encouraged to consult the Law Department or your local legal contact with questions or concerns.


Anti-money Laundering

We are committed to preventing money laundering when conducting our business. We have instituted rigorous policies and procedures to detect, deter and prevent money laundering. We report potential money laundering activity in a timely manner to the proper authorities in accordance with applicable legal requirements. We are each responsible for knowing and following the applicable anti-money laundering policies and procedures for our business area.


Bribery and Corruption

Bribery and corruption are not only against our Company values, they are illegal and can expose both the employee and Company to fines and other penalties, including imprisonment. You are expected to decline any opportunity which would place our ethical principles and reputation at risk or would subject employees or the Company to criminal prosecution. We are committed to supporting international and local efforts to eliminate corruption and financial crime and will not tolerate employee attempts to achieve results or gain favors at the cost of violating the law or acting dishonestly. You may not give, promise or offer cash or anything of value to any customer, government employee or any other person or entity, for the purpose of improperly influencing a decision, securing an advantage, avoiding a disadvantage or obtaining or retaining business.


Competition Laws

We always seek to outperform our competition fairly and honestly. We must comply with competition laws in all countries and localities where we conducts business, including U.S. anti-trust laws. It is not permissible to enter into arrangements, whether formal or informal, with competitors to fix prices, allocate territories or customers, or engage in activities which otherwise result in illegally restraining competition or are in violation of competition laws. Business is to be pursued in a manner that promotes competition in the services marketplace and provides the customer with the best combination of price and quality. InfiniValue, its employees and agents should not be involved with activities that restrict the operation of free and open competition in the marketplace nor seek to gain unfair competitive advantage over our competitors by maligning their qualifications or misrepresenting our own.


Human Rights

We have a zero tolerance approach to human trafficking and we are committed to implementing and enforcing effective systems and controls to ensure human trafficking is not taking place in our business or in our supply chains. We expect our suppliers to share our commitment to human rights by using only voluntary labor, following all applicable wage and benefit laws, not employing under-age individuals in violation of any applicable child labor laws, and providing a work environment that is safe and healthy and free of harassment and unlawful discrimination.


Political Activity

We fully support employee efforts to become engaged in the political process. However, we must each make sure we do not use Company resources for personal political activities since campaign laws are strict concerning the use of corporate resources to support or oppose a candidate. Any use of Company resources, including time, equipment (email*, computers and phones), supplies or facilities for political activities must be approved in advance by the Government Relations Department or your local compliance/legal contact. Company contributions to political campaigns are prohibited.


Intellectual Property

Intellectual property includes copyrights, trademarks and patents. We protect our intellectual property because it is a valuable asset of the Company and respect the intellectual property of others. Our copyright and licensing policies help us to protect Company copyrighted information and avoid infringement on the copyrighted works of others. We must protect and police our trademarks and should refrain from altering or modifying them in any way. If we intend to use a third party’s trademarks, we should ensure that we have permission to do so. We should consider whether our products and processes should be protected with a patent and should work to avoid infringing on the patents of others.

Government officials are often prohibited from accepting any gift or entertainment, regardless of value. Special care needs to be taken in this highly regulated area. Employees and agents of InfiniValue may not provide any gifts or entertainment to government officials without the advance approval of your compliance/legal contact.


Community Involvement

Our strong sense of corporate social responsibility drives us to make a positive contribution to the communities in which we operate. Our commitment at the corporate level is matched by the enthusiasm and commitment of our talented, caring employees who make their communities better places to live and work. Together, we contribute by: • Donating generously to deserving organizations and programs that support health and human services, education, arts and culture, economic development and the environment. • Protecting the environment through responsible building and property management practices, employee education, green investing and purchasing practices, conservation of resources, recycling and transportation programs. • Actively encouraging our employees to care for their communities by volunteering, donating and conserving. • Supporting employee service through strong military benefits and political leave. • Taking care of our employees’ well-being through wellness programs, flexible work arrangements and our family-friendly culture.

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