Filtrona is committed to ensuring that its business is conducted in all respects according to rigorous ethical, professional and legal standards. Adherence to applicable local laws and regulations, Filtrona policy, and the application of common sense, logic and the basic standards of behaviour expected in the society in which the Company participates, should guide each employee in determining the correct course of action that supports these standards in their daily working lives.

This policy provides employees with guidance on personal conduct. Whilst it is impractical to try to cover every potential circumstance, the following descriptions of the Standards are intended to assist employees. A guiding principle should be that neither Filtrona's overall integrity nor its local reputation would be damaged if full details of the business practice or transaction were publicly disclosed.

Employees should ensure that third parties working with or on behalf of Filtrona are aware of the Code and, where possible, that they undertake contractually to act consistently with the Code when working with or on behalf of Filtrona.

Standards

1.      Conflicts of interest

All directors, officers and employees should act in the best interest of Filtrona and endeavour to avoid situations where personal interests could conflict, or appear to conflict, with the interests of Filtrona companies. Filtrona’s reputation depends not only on high quality services and products but also on the manner in which relationships with suppliers, government officials, organisations and others outside Filtrona are conducted. Each employee must ensure that any conduct does not provide, or give the appearance of providing, personal gain at the expense of the Company or any external business contact.

Employees must not seek or accept from any person, company or organisation, or offer to any person, company or organisation, any gift, service, hospitality or favour that goes beyond reasonable accepted practice or common courtesies consistent with the local ethical business standards or where the acceptance or offering of such gift, service, hospitality or favour may be construed as seeking to influence a business decision or procure an improper advantage.

Gifts and entertainment may not be accepted without prior authorisation of an employees’ line manager.  

Conflicts of interest can arise in many different ways. The following is a non-exhaustive list

• Working in any capacity for another individual or entity whilst employed by a Filtrona company which may materially impact the employee’s ability to carry out his job function
• Competing (directly or indirectly) with Filtrona for the purchase or sale of property, services or other interests
• Having an interest in a transaction involving Filtrona, a customer, supplier, vendor or lender
• Receiving a loan or guarantee of an obligation as a result of directing Filtrona business to a supplier owned or managed by, or which employs, a close relative or friend
• Investments by employees and their close relatives in competitors, vendors, suppliers or customers unless they are publicly quoted companies
• Taking (or directing a third party to take) an advantage of a business opportunity through the use of corporate property, information or position

Conflicts of interest are applicable to all Filtrona employees and their connected persons (which includes family members such as spouse or civil partner, anyone living as a partner in ‘an enduring family relationship’, children and step children and parents).

Each employee must declare in writing to their supervisor or manager any potential conflicts of interest.

A conflict of interest can also arise where a line manager is in a personal relationship with a subordinate in their chain of command. The senior person in the relationship should disclose any such relationship to their immediate line manager. Should the relationship be between work colleagues of different departments the employees concerned should consider whether there are any conflict circumstances and if so disclose the relationship to their line manager.

Disclosure should also be made before accepting a promotion or transfer that would create such a conflict.

2.      Compliance with laws, rules and regulations

In conducting business affairs, Filtrona companies and their employees must observe the applicable laws, rules and regulations of each country in which they operate. Guidance and specific legal advice should be sought as appropriate.

Employees who are involved in the preparation of any information that will be included in any public communication to shareholders or investors or in any document or report that will be filed with the London Stock Exchanges or the UK Listing Authority must ensure that such information is full, fair and timely.

3.      Bribery and Corruption

Most countries have laws that prohibit corruption and bribery. Increasingly these laws will extend to payments to foreign entities or individuals outside these countries’ own borders. The taint of bribery and corruption could do incalculable damage to Filtrona’s reputation.

Therefore, the making or receiving of illegal payments or inducements, such as bribes or any other form of corruption, are contrary to the policy of Filtrona and any such act will be viewed as gross misconduct which may lead to the dismissal employees involved. The funds and resources of Filtrona shall not be used directly or indirectly for any purpose in connection with bribery or corruption.

Any suspicion of bribery or corruption must be reported and will be thoroughly investigated.

4.      Protection of confidential information

No employee shall, without proper authority, access, modify, disclose (internally or externally) or make use of any trade secrets, confidential, commercial or personal information for any purpose other than in the legitimate execution of their duties. The obligation of confidentiality extends after employees cease working for Filtrona and covers disclosure to other parties.

5.      Protection and proper use of company assets

Company assets provide the foundation upon which to provide services and products worldwide. Employees are responsible for the protection and wise stewardship of these assets. This includes being responsible for the establishment of, and adherence to, procedures that ensure assets are not put in jeopardy or used wastefully.

6.      Relationships with customers and suppliers

Directors, officers and employees should endeavour to deal fairly with customers and suppliers and in so doing have a responsibility to ensure that every aspect of business operations is supportive of the delivery of the highest standard and quality of service and product.

No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information or misrepresentation of material facts and the treatment of customers and suppliers should be in accordance with ethical business practices at all times.

Directors, officers and employees shall ensure, as far as is reasonably practicable, that suppliers are not engaged in the employment of children contrary to UN Conventions.

7.      Health, Safety and Environment

Filtrona is committed to conducting its business in compliance with all applicable environment and workplace health and safety laws and regulations. It is the responsibility of all directors, officers and employees to ensure, as far as is reasonably practicable, a safe and healthy work environment which avoids adversely impacting and causing injury to the environment and to the communities in which Filtrona operates.

These aims are more fully described in the Filtrona plc Environmental Policy and the Health and Safety Policy.

8.      Our employees

Employees should be treated, and treat each other, with respect, courtesy and decency. Disparagement or harassment of fellow employees or business contacts is inconsistent with these Filtrona Standards.

Throughout its worldwide operations Filtrona supports human rights as set down by the UN Declaration and its applicable International Labour Organisation conventions. This includes a mandatory requirement on Filtrona sites to avoid the employment of children.

Filtrona is committed to offering equal opportunities to all people without discrimination as to race, sex, nationality, ethnic or national origin, language, age, marital status, sexual orientation, religion or disability. The Company will not tolerate harassment in the workplace in any form and will remunerate fairly with respect to skills, performance, competitors and local market conditions.

9.         Political Contributions and Activities

No political donations shall be made by or on behalf of Filtrona plc or any other Filtrona group company. This applies solely to the assets of Filtrona and is not intended to discourage any personal political activities by employees.

If an employee believes that the terms and standards of the Code of Business Ethics Policy are not being correctly adhered to then they should seek to raise any concerns with their line manager or in accordance with the terms of the Filtrona’s Whistleblowing Policy.

Failure of employees to observe the terms of this Code of Business Ethics Policy may constitute a serious disciplinary offence and involve the termination of their employment.