Code of Ethics and Business Conduct

CODE of Ethics and Business Conduct

Purpose

Armstrong’s Code of Ethics and Business Conduct (“Code”) seeks to build transparency and provide granularity in the practice of our Corporate Values as it relates to ourselves and others outside our community. Our community is only as strong as each person's commitment, to promote with integrity the highest ethical standards in all aspects of our business.

Armstrong's code of Ethics and Business conduct can never be all inclusive, however the following document assists in clearly describing critical expectations of each person and is meant to demonstrate our commitment to:

• Building and fostering a corporate culture of integrity;
• Creating appropriate awareness of our values and this Code at all levels of the organization;
• Setting up measures to prevent, detect and respond to unethical or non-compliant behaviour
• Providing globally available support, information and resources to assist in the application of our values and this Code; and
• Continually improving our corporate governance standards.

Scope

This policy applies to all employees (temporary, contractual, full- and part-time), consultants, agents, representatives, officers and members of the Management Board and Leadership Board of Armstrong Fluid Technology (hereinafter referred to as “our people”, “we”, “us”).

Complying with our Code and its underlying policies and standard operating procedures is part of the terms and conditions of our relationship with Armstrong. On a regular basis, we will be required to complete a certification process to ensure that our Code is understood and properly applied to our daily activities.

We expect any third party we do business with to respect our values and high ethical standards of conduct. We will make all reasonable efforts to make them aware of our expectations under our Code and encourage them to adopt principles and practices that are comparable with our own.

Our Code is not meant to be a collection of all rules and cannot cover every situation. It is designed to help us use our judgement and common sense to make the right decisions. When in doubt, we should always seek guidance on the proper course of action from Organizational Capability, Finance or Leadership Board members.

Our Code is continuously updated to reflect changes in laws, policies and best practice.

Policy Statement

Operating globally, we are subject to laws and regulations of multiple jurisdictions. Accordingly, all our business activities must be conducted in full compliance with all such laws and regulations in force in the jurisdictions we operate. Unlawful conduct is strictly prohibited. Should local legislation or regulations allow behaviour that is not compliant with our Code, our Code prevails. Should there be a conflict, or should we be uncertain about the application or interpretation of a law or regulation, we must consult the Chief Financial Officer or Chief Executive Officer before any decision is made or action taken.

Mutual Respect in the Workplace

At Armstrong, we consistently demonstrate respect for all our stakeholders. Our day-to-day activities require us to interact with individuals of various ethnic backgrounds, cultures, religions, political convictions, ages, genders, disabilities, and sexual orientations. We are all entitled to personal dignity, privacy, and the preservation of our rights. Consistent with our Community Value, we respect others and prohibit any behaviour or actions that amount to discrimination, harassment, or violence.

If we are victims of, or witness to, discrimination, harassment, or violence in our workplace, we must either immediately report it to our manager or supervisor, or the local Organizational Capability representative.

Health and Safety

The safety of our people is of paramount importance in all aspects of every undertaking we engage in. Armstrong is committed to providing safe and healthy work environments in each of our facilities. Armstrong ensures that the applicable workplace health and safety legislation is treated as a minimum standard in all areas where we conduct business.

We are fully committed to promoting the health, safety and physical well-being of our people, and of those who come into contact with Armstrong people, facilities, products and services through hazard recognition, risk assessment, and the elimination of hazards in the workplace.

We must all work together to reduce the frequency and severity of incidents and injuries by identifying, reporting and eliminating unsafe or hazardous conditions in the workplace. We want an injury free work environment and this is only possible if we are one another’s guardians.

Drugs and Alcohol

Consumption of drugs or alcohol adversely affects job performance, the work environment and the safety of our people, third parties and the general public.

Individuals must never be impaired by drugs or alcohol while on duty. Furthermore, we are strictly prohibited from consuming, selling, purchasing or possession of illegal drugs.

Moreover, except with authorization from the Leadership Board, and always in accordance with applicable laws, we are prohibited from consuming, selling, purchasing, or serving alcoholic beverages on Armstrong premises. Specific guidance on this topic is provided in our policies and standard operating procedures on health and safety.

Security

We are committed to protecting our people, assets, and information wherever we operate. Our goal is to ensure that security risks are identified and mitigated in order to provide a safe and secure work environment for our people. We are all expected to be alert to potential security threats and react in accordance with applicable security plans, protocols, or procedures.

We will not knowingly engage in any business activity encompassing any security risk that cannot be properly managed and reasonably mitigated.

We are all accountable for following Armstrong’s security policy.

Personal and Private Information

Armstrong is committed to respecting individual privacy laws and has implemented the necessary safeguards to ensure data accuracy and security. We are all expected to exercise due care and discretion with respect to personal information. Generally, Armstrong will ensure that consent is obtained prior to disclosing personal information.

Any personal information disclosed to or collected by Armstrong within the course of our activities will only be used for the purpose for which it was disclosed or collected (for example, Armstrong may disclose to its clients, personal information contained within an employee’s resume or curriculum vitae for the purpose of submitting a bid or proposal).

There may be other situations where the disclosure of personal information to third parties is required or otherwise permitted by law. Disclosure may also be required for the purposes of the administration of a program by a third party (for example, in the case of an insurance program administered by a third party provider). In such cases, Armstrong will ensure that the third party abides by the same rules. Personal information may also be shared with third parties for auditing purposes, or where required by the law, with local authorities.

AVOIDING CONFLICTS OF INTEREST

Throughout the course of our activities with Armstrong, we must ensure that we always act in the best interests of Armstrong. We must therefore avoid any conflicts of interest, whether actual, potential or perceived, in the performance of our duties.

An actual conflict of interest exists when the judgment, objectivity, or independence of a person is affected by a potential clash between the person’s self-interest and their professional, business or public duties. A potential clash of interest exists when there is a reasonable possibility of a conflict of interest arising in the future. A perceived conflict of interest exists when an observer could reasonably conclude that a conflict of interest exists, even if it does not.

Any situation of actual, potential or perceived conflict of interest must be declared through the local Organizational Capability department in each location.

The assessment of whether or not the disclosed situation amounts to an actual, potential or perceived conflict of interest will be conducted by the Global Director, Organizational Capability and, if necessary, in consultation with the Leadership Board. Where an actual, potential or perceived conflict of interest is deemed to exist, management will outline the measures that must be taken to remedy the situation. The information disclosed will be treated as confidential and only made available to individuals directly involved in assessing the conflict of interest.

The following subsections provide examples of conflicts of interest. We must however, always remain alert to, and be able to identify, other situations in which we might be in a position of potential, perceived or actual conflict of interest. Should we have the slightest doubt as to whether or not we are in a situation of actual, potential or perceived conflict of interest, we must consult the Global Director, Organizational Capability, or the local Organizational Capability representative.

Secondary employment and incompatible activities

We must declare any actual or contemplated secondary employment relationships with another business or any directorship in another organization.

We must refrain for performing or being involved in activities that are incompatible with our work at Armstrong.

The following situations are examples of actual, potential or perceived conflicts of interest related to secondary employment and conflicting or incompatible activities:

• Performing activities or tasks that conflict or are otherwise incompatible with one another in the course of our work at Armstrong, for example the person requisitioning the purchase of goods and services is also approving the procurement transaction;
• Engaging in secondary employment relationships that restrict our ability to fulfill our duties at Armstrong;
• Accepting a directorship of a third-party organization without first declaring to and obtaining the consent of the Global Director, Organizational Capability;
• Owning (whether directly or indirectly) a significant financial interest in an outside entity which does, or seeks to do, business with or is a competitor of Armstrong;
• Participating (whether directly or indirectly) in outside business or financial activities that compete or may potentially compete with Armstrong;
• Participating (whether directly or indirectly) in an outside business that supplies services to or has business dealings with Armstrong. This is especially relevant where there is the possibility of preferential treating being received by virtue of our position within Armstrong; and
• Conducting business on behalf of Armstrong with a member of our family, or a business organization with which we or a member of our family has an association, unless such business dealings have been fully declared to our manager and the Global Director, Organizational Capability, or, as the case may be, to the Leadership Board prior to any arrangement. In such cases, a specific non-objection decision must be provided.

Personal Relationships in the Workplace

Armstrong permits the employment of individuals from the same family or who have personal relationship with another employee, provided that there is no actual potential or perceived conflict of interest.

In this context, some examples of situations constituting actual, potential or perceived conflict of interest are:

• Reporting directly or indirectly to a family member or someone with whom we have a personal relationship;
• Exerting influence on another employee for the benefit or detriment of a family member or someone with whom we have a personal relationship;
• Acting as a direct or indirect supervisor of a family member or someone with whom we have a personal relationship;
• Using our position to exert influence where a family member or someone with whom we have a personal relationship works.

Should we have any doubt as to whether our relationship with another employee could constitute an actual, potential or perceived conflict of interest, we should contact the local Organization Capability representative for further guidance.

In any case where a family or personal relationship may give rise to actual, potential or perceived conflict of interest, it is our responsibility to declare such conflicts. Self-declaration of personal relationships to Organizational Capability will be treated with the utmost discretion and confidentiality.

ADOPTING APPROPRIATE BUSINESS PRACTICES

While we are vigorously competitive in all our markets, all our business practices must be conducted fairly and in full compliance with all applicable laws and regulations.

Unlawful conduct is strictly prohibited. Should there be any uncertainty about the interpretation of any law or regulation or face a situation which may constitute a breach of such legislation or may create any doubt about the correct legal or ethical action, guidance must be sought from the local Country Leader, Finance leader, the Chief Financial Officer, or the Chief Executive Officer.

Anti-Trust and Competition

At Armstrong, we must all engage in fair competitive business practices which are compliant with all anti-trust and competition legislation that applies in all the jurisdiction that we operate in. While these laws and regulations may vary from jurisdiction to jurisdiction, they are generally designed to uphold free and open competition in the marketplace.

Behaviour that is prohibited under such legislation includes discussions, collusion or agreements with competitors to, among other things:

• Fix or control prices, terms or conditions;
• Restrict competition or dealings with suppliers or customers;
• Divide or allocate customers, markets or territories between Armstrong and our competitors;
• Influence the resale prices charged by those who buy our products or services; or
• Not submit a bid, withdraw a bid or submit an artificial or losing bid.

We must not engage in any activities that could reasonably be construed as being anti-competitive, abusive or unfair. We must not seek to obtain competitive intelligence through unlawful practices such as industrial espionage, bribery, theft, or electronic eavesdropping, and must refrain from making false or misleading statements about our competitors and/or their products and services. We want industrial intelligence that is legal.

Any competitor, customer or other third party who requests any Armstrong employee to even consider any of the above activities OR any employee who hears about or discovers any competitor using such practices against Armstrong must be immediately reported to the Organizational Capability office and Chief Executive Officer.

Anti-Bribery and Anti-Corruption

Armstrong is committed to conducting business with integrity and therefore strictly prohibits corruption and bribery in all its forms. We must not, directly or indirectly, accept, offer, promise, grant or authorize the giving of any bribe, kickback, payment or anything can be construed as such (gifts, entertainment, employment, contracts, or benefits of any kind) to any third party in order to influence or appear to influence action, inaction or decision, with the intent to obtain an improper advantage or to retain business.

We are all responsible for educating ourselves on how to recognized corrupt activities and ensure that we are not involved in any such type of activities, whether directly or indirectly.

Facilitation Payments

Making facilitation payments is strictly prohibited.

If, however, in order to prevent an imminent and serious threat to our health, safety or welfare, or that of a family member, we have no alternative but to provide a payment, then it would not be considered a facilitation payment. This would be considered an extortion payment and would therefore be permissible under duress.

Any such payments made under these exceptional circumstances must be accurately reported to your manager/supervisor, the Chief Financial Officer and the Chief Executive Officer to ensure accurate recording of such transactions and proper disclosure to the relevant authorities.

Gifts and Hospitality

We are not prohibited for offering or accepting occasional gifts, meals or entertainment that are unsolicited, reasonable in value and complaint with the law, our Code and its underlying policies and standard operating procedures.

However, we must not offer, accept or exchange gifts, meals or entertainment if:

• They take the form of cash or cash equivalent, such as gift cards, certificates, coupons, vouchers, loans, stock, or stock options;
• They are lavish and extravagant and beyond our regular expenditure in everyday life;
• They are offensive, in poor taste or otherwise violate our commitment to mutual respect;
• They violate any law, regulation or rule or contravene the standards or policies of the recipient’s organization;
• Doing so may be interpreted as a way to influence an active procurement process or affect a pending business decision;
• Doing so could be construed as a bribe or a kickback;
• They are part of an agreement (whether formal or implied) to do or receive something in return;
• Doing so might reasonably be interpreted as a reward for preferential treatment, whether actual or perceived, or as creating an obligation on the part of the recipient;
• Doing so could influence the recipient or the recipient’s organization in any business dealings; or
• Doing so happens on a regular basis.

We must exercise particular care when offering any business courtesy to government officials, as they are subject to stricter rules, regulations and laws. Refer to section on Government Officials below for more details.

We must not use our own funds or per diem money to offer gifts, meals or entertainment to third parties if such courtesies would be prohibited using Armstrong’s resources. All gifts and hospitality offered to third parties by Armstrong employees must be recorded completely and accurately in Armstrong’s books and records.

In any event, we must refer to the policies and standard operating procedures on gifts and hospitality prior to offering or receiving gifts, meals or entertainment to third parties. For further guidance contact your local Finance department.

Third Parties

Third parties in our industry usually include:

• Customers
• Competitors
• Suppliers
• Government officials
• Business partners (described more fully under “Business Partners”)

We strive to deal honestly and accurately with third parties. We want to work with third parties who share our values and culture of high integrity. We therefore expect these third parties to embrace and implement practices that are consistent with our Code and to:

• Comply with all applicable laws and regulations;
• Refrain from engaging in bribes, kickback, and other forms of corruption;
• Refrain from any involvement in money laundering and terrorism financing activities;
• Take responsibility for the health and safety of their employees;
• Respect the human rights of their employees, including abstaining from child and slave labour practices;
• Seek to promote sustainable local development;
• Seek to ensure that their business activities are conducted in an environmentally responsible manner; and
• Promote and mirror our commitment to the quality of our work.

We should terminate any business relationship with a third party that we deem to be acting in a way that is inconsistent with our values and practices. For guidance and more information, contact your local Finance department.

Business Partners

We define a “business partner” as any third party who, as the context may require, acts on behalf of, or is partnered with, Armstrong for the purpose of undertaking a specific task.

Actions performed by others when assisting Armstrong in our business activities have a direct impact on us. Legally we may be held liable for the actions of our business partners as if we had performed them ourselves. Therefore, we need to ensure that individual and/or organizations acting on our behalf behave and conduct themselves in the same manner we are expected to.

It is every employee’s responsibility to ensure that a compliance due diligence is performed and duly approved for each of the business partners we deal with. Our obligation begins with the diligent selection of our business partners by making sure we assess their values and adherence to acceptable business principles. Throughout the business relationship, we will continuously and properly monitor our business partners to prevent misconduct.

Government Officials

Given the nature of our business, we regularly interact with government officials all around the world, both directly and indirectly.

Employees who are in contact with government officials are responsible for knowing and strictly adhering to the laws, regulations and/or rules that apply to interacting with such government officials or government contracting entities. In any event, we must:

• Interact honestly, accurately, and transparently with any government official;
• Never offer anything to a government official unless it is clearly permissible under applicable laws and regulations and fully compliant with our Code and its underlying policies and standard operating procedures;
• Refrain from giving anything of value to an individual if we have reason to believe it will be passed on to a government official; and
• Never enter into a potential employment opportunity with a current or former government official or a member of his/her immediate family without having consulted with your local Organizational Capability representative or the Global Director, Organizational Capability.

Activities that may be acceptable when dealing with private-sector company employees could be inappropriate or illegal when dealing with government officials. Therefore, we are all expected to exercise caution when interacting with government officials.

Political Contributions

Subject to the constraints of the applicable legislation or regulations and unless formal pre-approval is obtained from the Management Board, we are prohibited from making political contributions on behalf of Armstrong to political candidates, parties, organizations or any other political entity, at all levels of government. Armstrong will not reimburse, whether directly or indirectly, any political contribution unless pre-approved by the Management Board.

We may engage in personal political activities in our individual capacities provided we do not make use of Armstrong’s time, funds, property, resources, employee lists, or solicit our people for political contributions while on duty.

Lobbying

While lobbying is a legitimate means of access to legislative, government and municipal institutions, many jurisdictions have enacted laws and regulations that require various levels of disclosure of lobbying activities.

It is in the nature of Armstrong’s business that we may engage in lobbying activities, via telephone calls, written communication or meetings with holders of public office. As lobbying rules vary by jurisdiction, we must be aware of the applicable rules and ensure that we are fully compliance.

Being in involved in communications with a government official or legislator may, in some cases, be considered to be “engaging in lobbying activities”. As a result, we must ensure that we are fully compliant with all registration or notification requirements and promptly notify the Chief Financial Officer that we have fulfilled such requirements.

Contact your local Finance department for further guidance.

Money Laundering

Money laundering is a global problem with devastating economic and social consequences. We are all expected to abide by anti-money laundering laws and regulations. We must act diligently to prevent Armstrong from being involved or used in money laundering or any other criminal activities. We must therefore apply the appropriate level of due diligence/check list prior to entering into relationships with clients or other third parties. We are required to recognize and monitor potential warning signals that could help detect unusual or suspicious activity. We must immediately report any doubtful activity that may involve money laundering or other criminal activity to our manager/supervisor, your local Finance leader or the Chief Financial Officer.

Trade Compliance, Controls and Boycotts

It is critical that Armstrong’s activities be fully compliant with the export controls, customs and anti-boycott laws and regulations of all the jurisdictions where we do business.

Export control legislation restricts the transfer of goods, services, hardware, software or technology across certain international borders without the requisite permits pursuant to applicable export control regulations.

Moreover, we must ensure that we follow the applicable guidelines for countries on which economic sanctions have been imposed. Laws governing trade are complex, and if we fail to comply with them, we risk being fined by relevant authorities and/or being debarred for doing business in certain countries.

We must also avoid the inclusion of any clause within a contract that would have the effect of illegally boycotting trade with a country. Any request for the inclusion of such clauses must be reported to the Chief Financial Officer even if Armstrong does not bid on the project or conclude the contract/agreement.

Armstrong and its third parties may be subject to serious penalties if we are in violation of these laws and regulations. Consequences include significant fines and the withdrawal of simplified import and export procedures in certain countries where we do business.

Insider Trading

In the course of business, we may come across “inside information” that is not yet known to the public and that, if publicly known, would have an impact on the price of publicly traded securities of our customers, suppliers or joint venture partners that are traded on financial markets.

Inside information may include non-public financial information, sales and earnings figures, plans for dividend changes or new financing, acquisitions, major new contracts or other financial matters.

Participating in transactions of financial products related to any of our customers, suppliers or joint venture partners – or advising others to do so – while being in possession of inside information regarding such companies is not only prohibited by our Code, but is also illegal and may constitute a serious criminal offense.

In addition, we may not acquire assets such as real estate or securities of a company that we know to be the object of potential acquisition by Armstrong.

Should we possess such inside information, we may not use this information to acquire any nearby property for speculation or investment without the prior approval of the Chief Financial Officer and the Chief Executive Officer.

Guidance on the appropriate procedures with respect to what may constitute inside information or insider trading is available from the Chief Financial Officer.

Accounting Practices and Record Maintenance

Accurate, complete and reliable records are crucial to our business as they guide decision-making and strategic planning. They are the basis of our financial reports and are necessary to fulfill Armstrong’s obligation to provide full and truthful disclosures to stakeholders and regulatory authorities.
Accordingly, all our records must be complete, accurate, reliable, and prepared in accordance with applicable laws and regulations, as well as Armstrong’s accounting and reporting policies and standard operating procedures.

Armstrong is committed to the following with respect to our books and records, regardless of the purpose for which the information is used:

• Business records, expense reports, invoices, vouchers, payrolls, employee records and other reports are prepared with care and honesty and in a timely fashion;
• All transactions are conducted at the level of authority required by our policies and standard operating procedures and in compliance with applicable laws, rules, standards and regulations;
• No transaction, asset, liability, or other financial information is concealed from management, Finance, or from Armstrong’s internal and external auditors;
• All efforts are made to resolve all issues and concerns raised by internal and external audit reports;
• Any unrecorded funds or assets, suspect accounting, or false or artificial entries in our books and records are immediately reported to the Director of Organizational Capability and the Chief Executive Officer;
• Any known inaccuracies, misrepresentations or omissions are disclosed to relevant stakeholders and promptly corrected through credits, refunds or other mutually acceptable means;
• All documents issued and signed are, to the best of our knowledge, accurate and truthful;
• No secret or unrecorded cash funds or other assets are established or maintained for any purpose; and
• Access to sensitive or confidential information is restricted through approved system permissions and physical safeguarding to ensure that it is not accidentally or intentionally disclosed, modified, misused, or destroyed.

The use of Armstrong funds or other assets for any unlawful or improper purposes is strictly prohibited, as are false or misleading entries and unrecorded bank accounts created for any purpose, whether regarding sales, purchases, or other activity, and improper or unusual financial arrangements with a third parties, such as over invoicing or under invoicing. Managers and officers, as well as those responsible for accounting and record keeping functions are expected to be vigilant, not only in ensuring enforcement of this prohibition, but also in having oversight of the proper use of Armstrong’s assets.

Engaging in Corporate Social Responsibility

Human Rights
We believe that all human beings should be treated with dignity, fairness and respect. Armstrong is committed to supporting the protection and preservation of human rights throughout its global operations and to ensuring that it is not involved in human rights abuses.

We must not engage in activities that encourage human rights abuses, that support trafficking in persons or the use of child labour or forced labour. Moreover, we must not do business with anyone who does not adhere to our principles regarding human rights or who is implicated in any cases of human rights abuse or child labour.

Community Engagement
Armstrong is committed to strengthening sustainable benefits to local communities in which we love and work around the world.

Being attentive to community needs and expectations, and by respecting each community’s uniqueness, we build strong and sustainable relationships.

Donations and Sponsorships
Armstrong is committed to corporate responsibility donations and sponsorships to a diverse range of organizations that are carefully selected within the areas where we can make the most difference. Armstrong gives priority to requests for donations or sponsorships that align with its corporate values and its role as a good corporate citizen, and that reflect Armstrong’s commitment to the creation of an ethical business environment.

Donations or sponsorships should only be made when they are aligned with Armstrong’s priority areas and strategy and in full compliance with our Code and its underlying policies and standard operating procedures.

Armstrong employees are to be aware that donations and sponsorships may present corruption risks and could be perceived as a way to seek or obtain an improper advantage. Should there be any doubt regarding the appropriateness of making a donation or sponsorship, the Chief Financial Officer should be contacted.

Protection of the Environment
Armstrong is committed to protecting the environment and undertakes to do business in an environmentally responsible and sustainable manner.

Such goals can only be achieved with the full support and participation of all Armstrong employees, including effective managerial leadership. We must always abide by and comply with the applicable laws and the standards and practices adopted by Armstrong relating to the protection of the environment.

PROTECTING OUR ASSETS

Armstrong employees share a personal responsibility and legal duty to protect Armstrong’s assets and ensure they are not damaged, misused, misappropriated (stolen), or wasted. Armstrong assets are not to be used for any unlawful, unethical or improper purpose, or for personal or third party benefit or gain. We must always comply with applicable laws, regulations, internal requirements, policies and standard operating procedures regarding the use of Armstrong’s assets.

Electronic Resources

Armstrong provides electronic resources required for conducting business. All work related electronic communications must be done through the corporate email address. The usage of non-corporate email addresses to send or receive work related communication is strictly forbidden.

While moderate personal use of Armstrong electronic resources is permitted if it does not interfere with work duties, abuse of this privilege is regarded as misconduct.

The electronic resources provided to us by Armstrong remain the exclusive property of Armstrong and must be used responsibly, appropriately, and ethically. We are never to use Armstrong’s electronic resources for the exchange, storage, or processing of content that:

• Is prohibited by law, such as the illegal downloading of material protected by copyright laws;
• Promotes or engages in harassment;
• Could be perceived as being racist, defamatory, discriminatory, violent, heinous, sexist, or pornographic; or
• May tarnish Armstrong’s reputation.

In any event when using electronic resources, appropriate precautionary measures must be taken to avoid compromising the integrity of Armstrong equipment and/or business systems, or disclosing private and/or confidential information.

Armstrong may exercise its surveillance rights surrounding the use of its electronic resources and reserves the right to monitor and review any content exchanged, stored, or processed on Armstrong electronic resources, as permitted by law.

It is understood that in the course of our work and business activities with Armstrong and to the extent permissible by law, we waive any right to privacy we may have with respect to information that is exchanged, stored or processed using Armstrong electronic resources. We understand that this information may also be subject to disclosure to law enforcement authorities.

For further guidance on the permitted usage of Armstrong electronic resources, consult our Global Information Technology and Business Systems policies and standard operating procedures, or the Director, Information Technology and Business Systems.

Confidentiality of Information

During the course of our work and business activities with Armstrong, we may be in contact with confidential information (see also section on Insider Trading). Confidential information belonging to Armstrong includes, but is not limited to:

• Details relating to our organization, employees (part-time, full-time and contractor), customers, suppliers, prices, markets, equipment, new product development, sales, profits, internal reporting figures, and other matters relating to our business;
• Information regarding research and development;
• Technical information regarding our products, services and processes;
• Detailed relating to current and potential mergers, acquisitions, or asset sales or purchases; and
• Information regarding employees and human resources.
• All digital files.

We must prevent inappropriate and unauthorized access to, or disclosure of, any such confidential information belonging to Armstrong or entrusted to us by third parties. Our obligation to safeguard the confidentiality of information applies both during the course and after completion of our work and business activities with Armstrong. These obligations continue even after the termination of our employment relationship with Armstrong.

Similarly, we must never accept and access confidential information belonging to clients, competitors, business partners, and other third parties, for the purpose of obtaining an unfair advantage.

Intellectual Property

Copyrights, trademarks, patents, designs, names, logos, inventions, improvements, photos, videos, discoveries, and any other form of intellectual property, such as protocols, procedures, technical processes, and research methods, created or modified during the course of our work and business activities with Armstrong remain the exclusive property of Armstrong.

In addition, intellectual property developed outside of the relationship with Armstrong belongs to Armstrong if its development arises as a result of the use of confidential information acquired in the course of our work and business activities with Armstrong.

We have a duty to protect Armstrong’s intellectual property just as we must respect that of others. The copying, taking, or destruction of any Armstrong intellectual property at any time including upon the cessation of our relationship with Armstrong is unlawful. Although we may believe that contribution to such work during our employment allows us to benefit from it, this work is the exclusive property of Armstrong and must not be used by us for other purposes or for the benefit of another employer. Moreover, Armstrong strictly forbids the unauthorized use, theft, or misappropriation of intellectual property belonging to third parties, including information drawn from the internet.

External Communications

Opinions or information sought from Armstrong regarding its business activities by outside groups or organizations must be channeled through Marketing and Communications.

Marketing and Communications is the official contact for any member of the media seeking an interview, an opinion, a comment, or a suggestion about any subject that may affect Armstrong’ business. Any request received from the media, even if framed as a request for a personal comment or perspective must be referred to the Director of Marketing and Communications.

Unless specifically requested or coordinated by Brand and Communications, any contact with the media must be done as a private citizen.

Any participation requesting Armstrong as a speaker at a conference, panel, or any form of media – such as television, radio, online, social medium, and print – as a representative of Armstrong, must be authorized by our manager/supervisor and the Director, Sales Enablement. Notification must be provided to Brand and Communications in advance wherever possible. When any such participation happens without pre-planning, Brand and Communications must be informed immediately thereafter.

All presentation material must be approved by Marketing and Communications prior to the presentation.

When giving opinions to outside interests on matters not related to the affairs of Armstrong, we are expected to be cautious and ensure that our comments remain strictly personal and do not commit, misrepresent, or otherwise involve Armstrong.

When using social media or other means of communications, we must not use Armstrong’s brand and identity or disclose any confidential information to which we may be privy. We must respect all conditions outlined in the sections:

• Mutual respect in the workplace
• Personal and private information
• Confidentiality of information

For further guidance regarding all aspects of external communications, contact the Marketing and Communications team.

REPORTING VIOLATIONS AND COMPLAINTS

Duty to Report

Great communities exist because everyone contributes to the desire and discipline of engagement with that community. It is every person that makes a difference.

It is the responsible of every Armstrong employee to ensure that we all live by the values of Armstrong and our Code. We all have an important duty and responsibility to report in good faith any known or suspected violation of our Code and its underlying policies and standard operating procedures, as well as any violation of applicable laws, rules or regulations, or any observed instances of misconduct or pressure to compromise our ethical standards. Subject to local laws, failure to report such instances may result in disciplinary measures, including termination of employment.

If we are involved in a situation or become aware of something that is or may be in breach of our Code or its underlying policies, we must promptly report it via any of the following resources:

• Our direct manager/supervisor;
• Local Organizational Capability representative
• Global Director, Organization Capability
• Local Finance Director
• The Chief Financial Officer
• Office of the Chief Executive Officer
• Office of the Chairman

Any concern raised or report filed will be treated with confidentiality and the originator who has reported the matter in good faith will be shielded from any form of reprisal, discrimination, or retaliation. Armstrong is committed to creating an environment in which every person affected by our Code feels free to report suspected and/or actual violations of our Code or its underlying policies and standard operating procedures, or to ask whether an activity or incident constitutes a violation. Armstrong strictly forbids retaliations against any individual who, in good faith, reports a violation, whether actual or suspected, of our Code or its underlying policies and standard operating procedures as well as any violation of applicable laws, rules or regulations.

If we believe we have experienced retaliation, we are expected to report it just as any other violation would be reported. If we have concerns about our duty to report and/or retaliation, we are to contact the Global Director, Organizational Capability or the office of the Chief Executive Officer.

False reporting is a serious offense which threatens the openness and trust of community.

Internal Investigations

Armstrong takes all reports of misconduct very seriously and assumes that all concerns and reports filed are done so in good faith and are legitimate.

Investigations into allegations of potentially unethical or illegal conduct are conducted exclusively by Organizational Capability using recognized investigation techniques in accordance with our internal practices and protocols. This ensure that the quality and integrity of the investigation process is maintained. Investigations are conducted with the utmost respect, discretion, and privacy, and will be kept confidential, subject to Armstrong’s need to fully investigate the matter to the extent permitted by the law. If the investigation discovers criminal or otherwise improper activity (or gross misconduct), Armstrong may be required to report such activity to the appropriate government, law enforcement, or regulatory authorities.

We are all expected to fully, truthfully and transparently cooperate with Organizational Capability by providing all requested documents and information. We must not in any way obstruct, hinder or delay any internal investigation. Failure to cooperate with investigations may lead to disciplinary measures, including termination of employment.

Making the Right Decision

Some decisions are easy to make. However, whenever we are unsure of any work-related actions or decisions, we must ask ourselves the following questions:

• Are my actions and/or decisions legal?
• Do my actions and/or decisions comply with Armstrong values and with our Code, its underlying policies and standard operating procedures?
• Are my actions and/or decisions fair, ethical and morally acceptable? What is my “gut feeling” telling me?
• How would it look if these actions and/or decision were reported on the news or in another public forum? Would my reputation or Armstrong’s reputation be negatively affected?
• Could someone perceive my actions and/or decisions as a conflict of interest?
• Could my actions and/or decisions (or inaction) put someone’s health, safety or well-being at risk?

If the answer to any of the above questions is not clear and obvious, or we are uncomfortable with the answer, guidance must be sought from the available resources listed in the section below entitled Contacts.

Contacts

When we have a question or would like to raise a concern, we should begin by consulting the person who best understands our work and area of responsibility: our manager/supervisor and/or appropriate Leadership Board member.

We may also communicate with pre-established contact within our corporate function or business unit.

A detailed list can be obtained from our local Organizational Capability representative.

Definitions

Responsibilities

This policy applies to all employees (temporary, contractual, full- and part-time), consultants, officers and members of the Management Board and Leadership Board of Armstrong Fluid Technology. This policy also applies to all individuals Armstrong does business with including customers, suppliers, and contractors.

• We all must exercise leadership and be individually committed to and responsible for;
• Complying with the provisions of our Code and completing the annual certification process;
• Being aware of and respecting the laws and regulations applicable in any and all of the jurisdictions in which we work;
• Making sure we understand and apply the policies and standard operating procedures relevant to our individual scope of work;
• Immediately seeking help and/or guidance from available resources when in doubt;
• Reporting any breach or suspected breach of our Code or its underlying policies and standard operating procedures;
• Cooperating fully with internal investigations when required; and
• Acting with integrity at all times, so as to maintain and promote our reputation in all our activities, everywhere.

Our managers have additional responsibilities under our Code. Managers are responsible for promoting a culture of compliance and integrity, as well as ensuring a positive working environment in which people are treated with dignity and respect.

As leaders, we must achieve this goal by:

• Leading by example and living up to Company values and the standards of our Code at all times;
• Helping those we lead to understand and follow the values and standards set forth in our Code, policies and standard operating procedures, as well as enabling and encouraging their participation in related training and certification;
• Supporting and protecting individuals who, in good faith, raise a concern or report a potential unethical or non-compliant behaviour, even if doing so would require such individuals to divert from the chain of command. This includes never taking or allowing retaliatory action against anyone who reports such concerns in good faith; and
• Following up when we hear about or suspect potential misconduct, and never ignoring any suspicious behaviour.

Failure to comply with our Code of Ethics or its underlying policies and standard operating procedures may result in disciplinary actions, up to and including employment termination, contract termination or non-renewal.

If the breach to the Code of Ethics includes a violation of the law, the matter may be referred to the appropriate law enforcement authorities, which may subject the individuals involved to civil and/or criminal penalties and sanctions.

In addition, Armstrong reserves the right to take any additional action, including legal proceedings, against individuals who have engaged in and/or benefited from activities that are illegal and/or contrary to our Code in order to recover any damages incurred by Armstrong and any amount or benefit that was wrongly paid or received.