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Code of Business Conduct and Ethics

To maintain an ethical environment that encourages and promotes professional and ethical conduct of management and staff, we have a Code of Business Conduct and Ethics.

We believe that for this policy to be effective, it should be understood. The Code is therefore written in clear and simple language.

Our Code applies, and is communicated, to all employees of ST Engineering North America and subsidiary companies in which we have management control. All employees are briefed on the Code at least once every two years. Contractors, consultants and agents are required to act consistently with the Code when acting on our behalf.

The Code reflects our expectations of responsible behavior towards our material sustainability issues. It sets out the guiding principles and desired behavior with which our people are expected to operate, and embraces the business practices and standards of behavior that support our commitment to honest and ethical business conduct. Many standards set out in the Code have also been embedded in various policies and procedures.