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Introduction Summary Applying the Code

1

Respect for the Law
Making the Right Decisions

2

Personal Integrity
Criminal Record
Excessive Personal Debt
Gifts and Entertainment
Alcohol and Substance Abuse
Human Rights, Diversity, Inclusion and Violence in the workplace
Use of the Internet, Email, and Electronic and Social Media
Irregular Business Conduct
Anti-Competitive Behaviour
Bribery and Corruption
Commission Sharing
Forgery, Falsifying Accounts, Documents and Records
Theft and Fraud
Reasonable Expenses

3

Conflict of Interests
Introduction to Conflicts of Interest
Conflicts Arising from Personal Benefit
Corporate Opportunities
Relationships in the Workplace
Conflicts Arising from Personal Financial Activities
Bequests, Executorships, Agencies and Powers of Attorney
Personal Borrowing and Lending
Recommending Service Providers to Customers
Disclosing Interest and Abstaining from Participation
Political and Charitable Activity

4

Confidentiality of Information
Protecting Customer Information
Protecting Employee Information
Protecting Transnational Information
Computer Systems Security

5

Disclosure of Transnational information

6

Work Environment
Appearance and Courtesy
Health and Safety

The Code of Conduct and Ethics (Code) establishes the standards that govern the way we deal with each other, our customers, shareholders, government, suppliers, competitors, the media, and the public at large.

Complying with the Code is part of the terms and conditions of our employment with Transnational.