Our Code Of Business Conduct. - Tesco PLC

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Our Code ofBusiness Conduct.

Our Code setsout our mostimportant policies.It is designed tokeep us and ourbusiness safe.ContentsIntroduction2Trading fairly30Looking after our customers12Protecting our reputation42Working together20Protector Line and otheruseful contacts62 A message from Dave Lewis, Group CEO What is The Code of Business Conduct? Raising your concerns How can I speak up? The Code & our leadership skills Clear prices & marketing Food & product standards Protecting customer & colleague data Health & safety Equal opportunity, inclusion & diversity Unacceptable behaviour Human rightsKeeping the business safe Competition laws Trade restrictions & sanctions Ethical trading Laws that protect suppliers Brands & intellectual property Fraud Bribery Gifts & entertainment Conflicts of interest Insider dealing & market abuse Engaging in political activity Accurate accounting & money laundering Keeping our information secure Social media & external communications3

‘ As colleagues, weare responsible forfollowing the Code.Wherever we workand whatever our role.’Our Code of Business Conduct is designedto help and protect us as we go about ourwork for Tesco. In a competitive, fast-movingand increasingly regulated marketplace, it isimportant that each of us understands therules that we must follow and the conduct thatis expected of us in order to do a great job forcustomers and help Tesco to play a valuablerole in society.The Code describes our most important legalobligations and the policies that must guideour conduct. As colleagues, we are responsiblefor following the Code. Wherever we work andwhatever our role, the Code is there to helpkeep us safe and protect the reputation ofour business among customers, colleagues,suppliers, shareholders and other stakeholders.Whether we are new to Tesco or have workedfor our business for some time, it is importantthat we take time to understand how the Codeapplies to us.A message fromDave Lewis Group CEO4Code of Business ConductOur Code means more than just following thelaw and our policies. It’s about using our Valuesand Leadership Skills to guide our conduct anddecision-making so that we are always doing theright thing at work and working in a fair, openand honest way.If you ever have concerns about your ownconduct or that of another person, you mustspeak up straight away and talk to someoneyou trust, starting with your line manager.Alternatively, speak to your Personnel Manageror the Legal team. Or, if you feel the need toraise your concern anonymously, you can callProtector Line in complete confidence.I want everyone who works for Tesco to beproud of our business and of our achievementsfor customers and the communities of whichwe are a part. Knowing our policies, applyinggood judgement, being honest and speakingup are just some of the ways that we canbuild pride in Tesco and help build a strongerbusiness for the future.Dave Lewis,Group CEOKeeping the business safe5

What is the Code ofBusiness Conduct?Our Code of Business Conduct sets downour minimum expectations for all colleagues,wherever we are based and whichever Tescobusiness we work for. It provides guidance oneach key risk area that may arise in our role.There are 21 of these and for each issue theCode tells us who to contact if we need helpor more information.Our Code brings together three elementswhich keep us safe. At the heart of our Codeis the simple principle that we always followthe law. The trust of our customers dependson our reputation as a law-abiding business.How we keepourselves safeTo make sure we follow the law, we havedeveloped policies and blueprints on each keyrisk issue. These provide us with a protectivelayer of training, guidance and support toensure that we know how the rules apply to us.Beyond the law and our policies, we mustalways be guided by our Tesco Values.Our Values can guide us when we makedifficult decisions. They ensure that we“do the right thing”, often going furtherthan the letter of the law and our policies.1. The lawWe must always follow the law. It sits at the heart of customertrust in Tesco.2. Our policies & blueprintsThese provide a protective layer of procedures, training,and support to ensure we don’t break the law.3. Our ValuesThese ensure that we always “do the right thing” for our customers,colleagues, shareholders and communities – often going furtherfor them than just complying with the law and our policies.Our ValuesHow to use our CodeOur Values guide us when we have difficultdecisions to make. By following our Values,we can be sure to do the right thing.As colleagues we: Make sure we are familiar with the Code andknow how to access it. Understand the Code and be ablethe Code applies to our role. Ensure all new starters are trained on Follow the law and our policies and know howNo-one triesharder forcustomers6We treatpeople howthey want tobe treatedEvery littlehelp makesa big differenceCode of Business ConductAnd if you are a peoplemanager, you also:to communicate its key messages.the Code and understand it. Always attend training on Code-related issues.responsibly if a team member tells you Use our Values to help us “do the right thing”. Actthey think the Code has been breached. Speak up if we think the Code or the law has Speak up if you think others are breachingbeen breached in any way.our policies or are not demonstrating theTesco Values. Ask questions if we are ever unsure.Keeping the business safe7

Recognising concernsHow can I speak up?Ask yourself:Who should I speak to? In everything we do, it’s important always to1. Could that be dangerous? This means that your line manager is theProtector Line allows you to raise yourconcerns regarding misconduct at work.If you do not feel able to speak to your manageror your Personnel Manager, you can callProtector Line to: If you cannot speak to your line manager,you think might be unlawful, that breachesthe Code or is against company policy.have an open and honest relationship withyour line manager.2. Should he have done that?person you should speak to first – unless youthink they have breached the Code.3. Should I tell someoneabout that?you can speak to your Personnel Manager,your local Legal Director or your local LossPrevention & Security Director.4. Isn’t that against the law? Alternatively, you could escalate your5. Is that right?About our Protector Lineconcerns within your own businessfunction if your line manager has notresolved your concern. If you need to raise your concern in completeconfidence, you can contact your localProtector Line. Raise any concerns about something at work Report anything you think is a danger tocolleagues, customers or the general public. Share any concerns you have thatinformation about these things is beingdeliberately concealed.Protector Line is completely confidential andrun by an independent company for Tesco.You don’t have to give your name when youcall although if you do, the Protector Line willbe able to update you on the outcome of anyinvestigation and will also be able to contactyou for additional information if necessary.As a business we support the UK PublicInterest Disclosure Act 1998 (and its foreign lawequivalents) which protects the confidentialityof complaints. This means that as long asyou’re acting in good faith and your concernsare genuine, you are legally protected fromvictimisation and will not be at risk of any formof retribution, including losing your job, as aconsequence of raising a concern – even if youare mistaken.8Code of Business ConductKeeping the business safe9

The Code & ourleadership skillsCollaborationWorking together across the businessto achieve shared success. By workingcollaboratively with our colleagues andsuppliers, we provide our customers with highquality products that are sourced responsibly.EmpathyBuilding strong relationships with customersand colleagues. We work to build strong andenduring relationships with all those we dobusiness with so that we get the very best fromour customers, suppliers and each other.ResponsivenessBeing agile in the way you think, makedecisions and handle change. We listen whencolleagues or suppliers raise their concernsabout breaches of the code and take actionright away.Resilience‘ Our Tesco Leadership Skills supportus in doing the right thing for ourcustomers, colleagues, shareholdersand communities.’10Code of Business ConductKeeping the business safeKnowing your own sources of energy andkeeping yourself fit for life. We understandthe Code and ensure we follow it, even if it issometimes hard to do. We speak up if we thinkthe Code is being breached.InnovationKeeping your eyes open so you can lead thebusiness for the future. We look for new waysto ensure the code is understood and followedby colleagues.11

Our value “No one tries harderfor customers” is central to oursuccess and encourages us tounderstand our customers anddeliver for them every day.This section of the Code covers issues relatingto giving customers clear price messages andprotecting their data.Clear prices & marketing14Food & product standards16 Protecting customer18& colleague data1. Lookingafter ourcustomersKeeping the business safe13

Clear prices & marketingQuestions & answersWhy does it matter?QQ I am planning a Chilean wine promotionand will be using a vineyard picture for theposters. We have a great shot in the photolibrary of an Argentinean vineyard that we’venever used. Can I use that in my campaign?Advertising and marketing are amongthe most powerful ways we talk to ourcustomers. Customers tell us that clearcommunications about our products andprices are important to them. Whether throughtelevision advertising, Clubcard mailings, onlinemessages or at the point of sale, our messagesinfluence our customers’ decisions as to where,how and why they choose to shop with us.If we get our messages wrong, we upsetcustomers and may attract the attention ofthe media. Advertising standards are regulatedin many of the markets in which we operateand if we are found to mislead customers, wemay face penalties and lose customer trust. Soeverything we say about our products must betrue - and, if we say we’re offering a great price,it must be just that. Getting our messages rightdirectly influences the trust that customersplace in us.What does it mean for me? If you are involved in any marketing activity,ensure that all messages are honest,accurate and fair. Keep promotions and pricing simple: avoidcomplex price promotions and frequentprice changes. Ensure that all messages are responsible;no customer should ever be offended byour advertising. When comparing our prices or productswith those of competitors, always useaccurate comparison data – compare likewith like and keep comparisons up to date. Ensure that your advertising matches yourproducts - validate all images so you arecertain that they are genuine and relate tothe products being sold. Make sure your advertising is appropriateand responsible – especially for alcohol. Never make untruthful marketing claimsabout any third party, such as a supplieror a competitor.AA No. Your images must accuratelyreflect the product you are advertising.You would need to source a photographof a Chilean vineyard that produces thewine you are promoting.QQ Our product is cheaper than the price ourcompetitor is selling at. Can I include this inmy POS material?AA Yes you can. However, it’s really importantthat you collect accurate and currentdata to support the claim you’re making.Remember, to monitor the competitor’sprices and update your point of saleadvertising to reflect changes in the pricedifference as they occur.QQ What rules apply to web-based advertising?AA The same as for any other advertising.Messages must be accurate, clear and mustnot be misleading.QQ I’ve noticed that the price of some productshas been increasing just before they go onpromotion. Is this allowed?AA In many markets there are strict rules whichhave to be followed whenever productsare sold on promotion. Your local Legal orTrading Law teams can advise you on howthese rules apply in your market.QQ There’s an Express store next to my child’sprimary school and they have put a posterup to advertise the launch of a new violentmartial arts X-Box game. Surely, it’s wrong tobe advertising violence where lots of smallchildren will see it?AA We would never want to place advertisingwhere it is likely to cause offence or whereit could be construed as being harmful tochildren. You should speak up and shareyour concern with your line manager,Trading Law or Legal.Where can I findout more? UK Legal— Customer team14Code of Business Conduct15

Food & product standardsQuestions & answersWhy does it matter?QQ I am concerned that a supplier of processedmeat products is using inferior quality meatin Tesco products. What should I do?QQ Where can I learn more about the processeswe have to manage product quality, safetyand legality?AA You should raise your concerns immediatelywith your line manager and your localTrading Law or Loss Prevention teamswho will investigate the issue. Even if theconcern turns out to be unfounded, it’simportant that you speak up.AA The Tesco Product Quality Rules are abasic guide to the principles by whichour products are made. This is availablefrom the Group Quality team or yourtechnical manager.Our customers expect us to only sell productsmade to the highest quality and they trustus to ensure that all our products are safeand comply with all applicable laws andregulations. We are committed to ensuring thesafety and quality of all our products from themoment we take delivery until the time ourcustomers buy them.We are committed to using our scale for good.We have simplified our supply chain to helpbuild better relationships with our farmers andsuppliers and ensure that all the products wesource are safe, legal and meet our exactingquality standards.We have a well-established and comprehensivefood safety management system within ourstores and distribution centres. Every daywe monitor and check the quality and safetyof our food to make sure our standardsare maintained. Such checks include thetemperature of our products, personal hygiene,cleanliness of our stores and equipment,protecting foods from contamination andmanaging the rotation of our food products.What does it mean for me? Ensure that our suppliers meet our productsafety and quality standards and complywith our policies about maintaining productsafety, quality and legality. Report any instances or suspicions of fraud inour supply chain. Protect our reputation and preserve theconfidence of our customers that ourproducts are safe and sourced responsibly. Know who we buy from and carefully evaluateeach and every product we sell so we can becertain our products can be fully traced inour supply chain. If you are a store or distribution colleague,ensure you complete all food safety andhygiene training and refresher training andtake action if you identify unsafe productson sale.QQ I’m looking to list a new supplier for anew own brand product. What standardsare our suppliers required to meet forproduct quality safety and legality beforethey supply us?AA We have clearly defined Tescomanufacturing and sourcing standardsthat set out the requirements we wantour suppliers to work to when theymake products for Tesco brands.We visit the sites before manufactureto verify that these standards have beenmet. Talk to your local Trading Law teamfor more information.QQ I am developing a new work routine that willchange the way we handle frozen food instore. Who should I contact?AA You should contact your local OperationalRisk or Trading Law team at an early stage.They can advise you on how to devise thenew routine so that it meets food safetybest practice and legal compliance.Where can I findout more? Quality team Loss Prevention& Security team16Code of Business ConductKeeping the business safe17

Protecting customerand colleague dataQuestions & answersWhy does it matter?QQ What is customer data?Data is at the heart of our business. We collect,process and use data every time we makecontact with our customers. For example, dataon shopping habits allows us to give customersgreat deals on the products they love to buy.We also hold and use information about ourcolleagues, so that we can contact them andensure they are paid on time.Whether the data we hold belongs to ourcolleagues or our customers it must beused carefully. We must always respect ourcustomers’ and colleagues’ preferences for howtheir data is used, including whether customerswant to receive marketing communicationsfrom us.So whenever we collect, process or usedata we must always follow our CustomerData Principles:Protected: We keep our customers’ datasecure and make sure it doesn’t fall into thewrong hands.What does it mean for me? If you are collecting information aboutour customers, always be clear withthose customers what you will do withthat information. Never share customer or colleague datawith other people or companies in any formunless the customer or colleague has givenyou permission to do so. Make sure colleague and customer data issecurely stored at all times and can onlybe accessed by colleagues who have beentrained on using data appropriately. Never use colleague or customer data forpersonal benefit. If you believe that any type of data mighthave been misused, lost or be the subjectof an unauthorised disclosure, you mustinform your line manager immediately.AA Any data relating to our customers ortheir activities in Tesco. This could includenames, addresses and contact details,transaction data, invoices, mobile phonerecords, mobile application data, bankingdata, Clubcard data and correspondencecustomers have sent to Tesco.QQ Can I send marketing e-mails to customersof our local Tesco Mobile business?AA Normally, our privacy policies allow forcustomer data to be shared within theGroup for marketing purposes but you mustcheck the exact local privacy policies to seeif this is permitted. Even if it is, you mustalways respect the marketing preferencesof the customers concerned and mustensure that any data is transferred securely.Appropriate: We only use customer data inways that customers consider appropriateand responsible.QQ Can I access our Payroll system to createa list of birthdays in our team?AA No. You are not allowed to access Payrolldata unless you are authorised to do so andit relates to a work matter, such as makingchanges to their salary or their personaldetails such as their name and address. Abetter solution would be to ask your teamto provide you with this information again.QQ I’m working on a new marketing campaignin my business area. Can I contactcustomers who have already providedtheir e-mail address?AA We can only use our customers’ personaldata for the reason it was provided.Customers must have agreed to receivemarketing communications from us at thetime of providing their details in order forus to use that information to contact them.We must also consider the customers’marketing preferences: if they have optedout of marketing contact from us, then wemust respect their choicesOpen: We are clear with customers abouthow we use personal data.Choice: We provide customers with choicesover how we use their data.Where can I findout more?Customer benefit: We make sure customersget as much benefit from their data as we do. Group LegalData Privacy team18Code of Business ConductKeeping the business safe19

Our success depends onour people. The Tesco Value“Treat everyone how they liketo be treated” ensures thatwe get the most from ourteams and helps colleaguesrealise their ambitions.This section of the Code coversthe key issues relating to people.Health & safety22Equal opportunity,24inclusion & diversityUnacceptable behaviour26Human rights282. WorkingtogetherKeeping the business safe21

Health & safetyWhy does it matter?We are all responsible for making Tesco a safeplace to work and shop. Everyone shouldbe able to do their job in a safe workingenvironment. Our customers rightly expectour stores to be safe so that they can enjoyshopping with us. Each of the countries in whichwe operate has safety laws and regulations withwhich we comply. Our own standards exceedbasic legal requirements to ensure that no-oneis exposed to injury or harm.Accidents and injuries can cause distress tocolleagues and customers, and in some casescan have very serious consequences. As wellas the personal impact that an injury can haveon individuals and others’ lives, the disruptionto the business caused through absencefrom work and costs from investigation,medical treatment and compensation canbe substantial. Failure to deliver on ourresponsibilities could also lead to legal actionbeing taken against us, damaging our reputationand the trust our customers and colleagueshave in us.Questions & answersWhat does it mean for me? Follow and understand safety instructionsand guidance and the Health and Safetypolicies and procedures that apply toyour role. If you are a manager, you must set anexample of safety leadership and create aworkplace where people follow your exampleof doing the right thing. Ensure risks are understood and have properplans to minimise potential harm from them. Safety is everyone’s responsibility –if you seesomething that you think is unsafe or couldcause an accident, take action to deal with itor tell someone immediately. If you see a colleague working in a way thatcould harm them or others, step in andremind them of the safe way to work. Never agree to do anything if you don’t havethe appropriate knowledge or training to doit safely.QQ I have just joined Tesco and colleagues havetold me that safety training takes a while tocomplete and is just “common sense”.Do I really need to do the training?AA Yes. All new colleagues must be familiarwith safety precautions necessary intheir workplace and know what to do inan emergency. Not all workplaces are thesame and we all have different levels ofexperience. Our safety training makes surethat we all work together to stay safe.QQ I’m worried about the safety of a new pieceof equipment. What should I do?AA If no instructions or training havebeen provided, it should not be used.You should check with the provider whoshould have supplied a risk assessmentand designed the right controls. If thereare instructions and you’re still concerned,contact your local Health and Safetyspecialist – you’ll find their details onyour local safety noticeboard.QQ Who are our Health & Safety specialists?AA Every business unit employs specialists inHealth & Safety who can deal with technicalquestions and manage the process of riskassessment. These colleagues all possesssafety qualifications and considerableexperience that together make themcompetent in their own field. Their detailsshould be listed on the colleague or safetynotice board.QQ How can I report a safetyconcern confidentially?AA In the first instance, talk to your linemanager or Personnel Manager. TheProtector Line is also there for colleaguesto report safety concerns. It can be usedcompletely confidentially and everyreport is investigated independently.Where can I findout more? Group PeopleSafety team22Code of Business ConductKeeping the business safe23

Equal opportunity,inclusion & diversityQuestions & answersWhy does it matter?What does it mean for me?We aim to employ people who reflect thediverse nature of society and we value thecontribution made by every colleague,irrespective of age, sex, disability, sexualorientation, race, colour, religion, ethnicorigin or political belief. At our stores, in ourdistribution centres and in our offices, wemake employment decisions solely on thebasis of job-related skills, achievements andperformance, using clearly defined andfair criteria.We strive to create an environment of equalityand inclusion where you feel your contributionis valued, you are treated well and you areencouraged to fulfil your potential.QQ I am a store manager and need to make apromotion decision between two colleagues.Since one colleague is 50 and nearingretirement age and the other only 30, shouldI promote the younger colleague since theymay work for us for many more years?We also try and make sure everyone can workin a way that suits their circumstances – wesupport flexible working, offering part-timeroles and encouraging job-sharing opportunitiesand shift swapping where this is possible.We must all: Demonstrate respect for our fellowcolleagues, and others that we come intocontact with, whether they are customers,suppliers or other parties, regardless of anysocial or cultural differences. Create an environment of openness andcollaboration so we can draw from thediversity, knowledge and experience ofour colleagues. Voice our views and concerns through therelevant channels so that we can all worktogether to make Tesco a great place to work. Make the right employment decisions,for example recruiting new colleaguesand reviewing those who already work inyour team, based on merit and businessconsiderations alone.AA No. We only make employment decisionsbased on job-related skills, achievementsand performance. We never make decisionsbased on age or any other non-job relatedcharacteristics.QQ My personal circumstances have recentlychanged. Am I able to reduce my weeklyworking hours?QQ A colleague is recruiting a new teammember. They have made a number ofremarks that I am concerned mean they maybe discriminating against certain candidates.What should I do?AA You should always raise your concern inthe manner you feel most comfortablewith, as we will not tolerate any formof discrimination. This could be in aconfidential manner through your linemanager, your Personnel Manager or viaProtector Line.AA We will always try and accommodate anychange you would like to make to your workarrangements, and in the first instancewe ask you to discuss this with your lineand Personnel Managers. They will want tounderstand your request, the impact onyour job role, and talk through the optionsfor covering the work. Understand employment and equalopportunities laws and local culture that mayhave an impact on workplace decisions andways of working.Where can I findout more? Support initiatives to improve employmentlevels and skills where this is needed. People team24Code of Business ConductKeeping the business safe25

Unacceptable behaviourQuestions & answersWhy does it matter?QQ My line manager can be very intimidating andoften abusive to the colleagues in our team.We know he is a perfectionist, but it makesour work unenjoyable and difficult. I worrythat if I speak up, he might become worse.What should I do?QQ I know a colleague has been having somedifficult times at home. Lately, they havebeen turning up to work very late andsometimes appear intoxicated. They are stillgetting their work done so I am not sure if Ishould say something. Should I speak up?AA Abusive or bullying behaviour is neveracceptable no matter who is doing it. Ourculture is one of respect and inclusionand any such actions should be reportedimmediately via our confidential ProtectorLine. You will always be supported in raisingany legitimate concerns.AA Yes. For the good of your colleagueyou should always raise your concernsif you believe that they are engaging inbehaviours that might be dangerous tothemselves or others. This includes theuse of drugs or alcohol. If you can’ttalk to them directly, speak to yourPersonnel Manager or line manager.We are proud to work for a company that valueseveryone and treats them the right way. We donot tolerate abuse or unacceptable behaviourin the workplace in any form, whether towardsour customers, other colleagues, suppliers oranyone else. We all share in the responsibilityfor making sure that Tesco offers a safe andopen environment for colleagues to work.We should be sensitive to actions or behavioursthat may be acceptable in one culture butnot in another. Some of these behaviours mayeven be illegal in other countries where weoperate. Colleagues found to have engagedin unacceptable behaviour can face seriousconsequences such as disciplinary action,including dismissal, and potentially legal action.What does it mean for me? Create a welcoming and inclusive workenvironment, and encourage those who youwork with to do so by treating everyone asyou would like to be treated. Don’t engage in behaviour that wouldbe considered by anyone in the teamas creating a hostile or intimidatingwork environment, including makinginappropriate jokes or comments. Don’t spread malicious rumours or gossipthat might be considered derogatory,defamatory, harassing, pornographic orotherwise offensive. Take responsibility for your performanceby never using drugs or alcohol in theworkplace. Such abuses are illegal, dangerousto yourself and others, and pose safety risksthat will not be tolerated. Make sure that your conduct when you areat off-site events is as it would be at work.Company-organised events include socialevents such as Christmas parties, teamevents and social outings.QQ A friend sent me an email with some rudejokes I think are very funny. Can I email themto my team of colleagues?AA No. We treat all colleagues with dignityand respect and what you consider funnymight be considered abusive or offensive byothers. Always ask yourself whetheryour actions might be offensive, abusiveor intimidating to others. This includesviewing any inappropriate material whileyou are at work.Where can I findout more? People team26Code of Business ConductKeeping the business safe27

Human rightsWhy does it matter?We are a global company and interact withmillions of people around the world every day.We have a responsibility to respect the humanrights of our colleagues, our customers, thosewho work throughout the supply chain andpeople in the communitie

concerns within your own business function if your line manager has not resolved your concern. If you need to raise your concern in complete confidence, you can contact your local Protector Line. About our Protector Line Protector Line allows you to raise your concerns regarding misconduct at work. If you do not feel able to speak to your .

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