CODE OF CONDUCT

CODE OF CONDUCT

Mogul is establishing a sustainable business system, which means considering economic, environmental as well as social issues regarding business activities equally.

To be a trusted international company, we must establish high standards and follow them in our actions. Our code is a commitment to do the right things in an ethical way. Our Code applies to all Mogul employees, officers, and members of the Board. Business partners can have a direct impact on our reputation through their behavior. For this reason, we want to work with business partners who share our commitment to safety, ethics and compliance. In case of deviations between national legislation and the provisions of this code, the higher standard is always to be considered as the applicable requirement.

Mogul’s responsibilities

• We are committed to safety, protecting the environment and respecting the communities in which we operate.
• Our health, safety, security and environment (HSE) goals are: no accidents, no harm to people and no damage to the environment.
• We value the unique contribution that each person brings to Mogul. We encourage a business environment where different talents and ideas work together and where everyone can contribute and make full use of their talents. We treat all employees with respect and are respectful to cultural differences. We are committed to maintain a corporate culture based on respect and fairness.
• We base our work-related decisions on merit – not on race, colour, national origin, religion, gender, age, sexual orientation, gender identity, marital status, disability, or any other characteristic protected by applicable laws.
• We do not tolerate any form of abuse or harassment. This includes actions that can reasonably be considered as offensive, intimidating or discriminatory, as well as any form of sexual harassment.
• We seek to conduct our business in a manner that respects the human rights and dignity of all people. Each of us can play a role in the elimination of human rights abuses such as child labour, human trafficking and forced labour.
• We respect local minimum wages and weekly working times as governed by local and regional law.
• Competition and Antitrust Laws: In all our business dealings, our companies strive to be honest and fair. We will vigorously compete, but do so fairly, complying with all laws protecting competition and the integrity of the marketplace. Our companies strictly adhere to what are called “competition” laws in many countries and “antitrust” laws in the U.S. — laws that protect markets around the world from anticompetitive behavior. Competition laws prohibit anticompetitive agreements and efforts to unfairly eliminate competitors.
• Money Laundering and Contraband: Products traded in violation of customs or fiscal laws have different names like “contraband,” or “smuggled goods”. Law enforcement officials around the world are increasingly concerned about contraband trade and its connection with another criminal activity — “money laundering.” The policy for MOGUL is clear: We will not condone, facilitate, or support contraband or money laundering.
• Accurate Books and Records, And Financial Disclosure: A company’s credibility is judged in many ways — one very important way is the integrity of its books, records and accounting. MOGUL is committed to providing relevant parties with full, accurate, timely and understandable information, in all material respects, about the company’s financial condition and results of operations. In meeting this commitment, MOGUL is required by the laws to report financial information in accordance with generally accepted accounting principles in the U.S., and to maintain books and records that accurately and fairly reflect all transactions.
• Records Management: It is essential that MOGUL manages records and other recorded information properly and in accordance with business needs, company policies and legal requirements.
• Government Inquiries or Investigations: If circumstances arise involving contact with Government officials with respect to your duties, any information provided must be completely honest and truthful.
• Privacy of Customer Information: MOGUL has a responsibility to protect the privacy and security of information that customers entrust to them.
• Mogul believes in respecting the confidentiality of our employees’ personal information. This means that access to personal records should be limited to company personnel who have appropriate authorization and a clear business need for that information.
• Product Quality: Maintaining the high quality of products is critical to the success of MOGUL — because it is what customers have come to expect from each of our outstanding businesses. So that MOGUL consistently meets these expectations, and meets or exceeds all Governmental safety and company quality standards for products produced, employees must act in accordance with these company quality and safety commitments.
• Environmental Compliance: MOGUL expects full and complete compliance with all applicable environmental laws and regulations wherever we do business, but this is only the starting point of MOGUL’s environmental commitment. MOGUL is also committed to reducing the environmental impact of our activities and promoting the sustainability of the natural resources on which we depend, while providing quality products that meet the needs of our customers. This commitment requires the participation of everyone working for MOGUL.

Employee responsibilities

• Read and be familiar with the information in our Code and align to act in accordance with our Code.
• Act in a manner that is safe, ethical, and consistent with applicable laws and regulations, Mogul requirements, Mogul values and behaviours and our HSE goals.
• Raise questions and concerns to your immediate manager if you become aware of possible violations of laws, regulations, our Code or Mogul Requirements. Raise unresolved concerns to the highest level of the Mogul management until the concerns is addressed.
• Co-operate fully when responding to an investigation or audit.
• Avoid acts of retaliation as they are considered to be misconduct by Mogul and not tolerated.
• Stop work, your own or warn the others, if you consider it unsafe.
• Play your part in protecting the environment – make it a personal priority.
• Be sure that your performance is not impaired; for example by a lack of sleep, alcohol, or any drugs – including prescription or over the counter medication. Work requires clear thinking and often the ability to react quickly — the safety of employees and customers depends on it. Being under the influence of alcohol or drugs, or improperly using medication, diminishes an employee’s ability to perform at his or her best. This is why the rules of MOGUL strictly forbid abuse of drugs and alcohol. Violations of these rules are taken very seriously.
• Treat everyone with respect and be respectful to cultural differences.
• Offensive messages, derogatory remarks and inappropriate jokes are never acceptable.
• We do not tolerate any form of abuse or harassment. This includes actions that can reasonably be considered as offensive, intimidating or discriminatory, as well as any form of sexual harassment. Help create a work environment free of all forms of harassment.
• All employees have many activities in their lives outside the company. A “conflict of interest” arises when an employee’s personal, social, financial or political activities may interfere with his or her loyalty or objectivity to the company. The obligation of employee to conduct the company’s business in an honest and ethical manner includes the appropriate handling of actual and apparent conflicts of interest. No outside affiliations with competitors, customers or suppliers are permitted.
• Do not accept or provide gifts or entertainment in return for any business, services or confidential information, or if the intent is to bias a decision.
• Do not offer or accept bribes, kickbacks or any other kind of improper payment including facilitation payments.
• Be conscientious and act appropriately to ensure company assets are not damaged, misused, or lost.
• Protect Mogul information. When handling confidential and secret information be especially careful by encrypting it when required and sharing it only with authorized parties. Do not share Mogul confidential information in public forums or on social media. Employees who have access to personal information must treat it appropriately and confidentially. Never provide personal employee information to anyone outside of MOGUL without proper authorization. Employees of MOGUL are prohibited from using MOGUL’s property or information, or their position within a company, for personal gain, such as by taking for themselves business opportunities that they learn about through their work at MOGUL.
• Protect Customer information.Employees who do not have a business reason to access this information should never seek to do so, and those who do have legitimate access should take steps to protect against the unauthorized release or use of private customer information.
• Computer Use and Network Security: Computer technology — hardware, software, networks and the information that runs on them — is critical to business success. And everyone who uses a computer must help ensure that these resources operate as they should. This means all employees must protect the security of computer systems, and use company computers responsibly and primarily for legitimate MOGUL’s business purposes — any personal uses should be reasonable and kept to a minimum.

Suppliers and Business Partner’s responsibilities

We work with our business partners in an honest, respectful and responsible way and try to build and maintain strong and long term relationships with suppliers and business partners. We seek to work with suppliers who share our commitments to safety and ethics and compliance. Suppliers who do have legitimate access to Mogul’s customer information should take steps to protect against the unauthorized release or use of private customer information.