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Key principles of Code of Conduct

Our entities implement local employee codes of conduct. These codes are intended for all employees to help them develop their activities while respecting the Group’s ethical principles. In compliance with local uses and regulations, they are based on 10 fundamental themes.

Respect for laws and regulations

The Group upholds the highest standards in how it runs its activities, notably by respecting human rights, labor laws and the environment.

In their professional activities, each Air Liquide employee must demonstrate integrity and abide by applicable laws and regulations under all circumstances.

Respect for people

Safety and health in the workplace, Prevention of discriminatory actions and Respect for third parties.

Safety and health in the workplace

Safety of employees is one of the Group's priorities, and safety will never be compromised for the sake of efficiency. Each employee has the right to work in safe and healthy conditions, and has a duty to ensure this by behaving responsibly in the workplace; Safety policy extends to all employees, subcontractors and service providers. Each employee must exercise their professional activities by abiding with the safety, hygiene and health rules applicable in his or her workplace, and by participating in appropriate training sessions that might be planned in these areas.

Prevention of discriminatory actions

The Group is determined to offer personnel equal opportunities for recognition and career advancement, regardless of their ethnic origins, gender, beliefs, sexual orientation or physical condition and will not tolerate any form of discrimination, or harassment.

Respect for third parties

It is forbidden for any employee to discuss or agree with a competitor an arrangement which prevents, restricts or distort fair competition. Agreements, for example, to fix prices, exchange price information, share markets or limit productions are strictly prohibited.

It is up to each Air Liquide employee to respect competition law, as breach can cause the company, its employees and its shareholders serious legal and financial risks.

 

Respect for competition law regulations

Competition law is applicable to every aspect of a company’s commercial activity: negotiations with customers and suppliers, contacts with competitors, marketing and sales promotion.

The following, in particular, are prohibited: any agreement or even discussion with competitors concerning price-setting or other transaction conditions, production limitations and the sharing of customers or commercial territories.

It is up to each Air Liquide employee to respect the competition law as violating rules can cause the company, its employees and its shareholders to incur serious risks. The law stipulates penalties that can be very significant for private individuals or extremely damaging to legal entities and may seriously undermine a company’s reputation.

Respect for rules on insider trading

Any employee with information, if made public, could influence the Stock Exchange price of the Air Liquide share.

Any employee holding sensitive information could influence the Stock Exchange price of Air Liquide's shares if it is made public. The employee must keep this information confidential and must not undertake, or recommend that a third party undertake or have undertaken, any operations on Air Liquide shares. The employee concerned must abide by the measures in the memorandum on the prevention of insider trading issued by the Air Liquide S.A. Legal Department.

Prevention of conflicts of interest

Includes links to a competitor, customer or supplier, respect for rules on corruption, payments, gifts and advantages

Links to a competitor, customer or supplier

Each employee must commit to avoiding any situation that involves a conflict between their personal interests and those of Air Liquide.
For example, a case where an employee may work simultaneously for a customer, supplier or competitor or holds a major interest in these latter, either directly or indirectly. Any employee who could potentially be in a conflict of interest is encouraged to inform his or her immediate supervisor of this situation.

Respect for rules on corruption

It is prohibited to pay for, offer or grant unwarranted advantages, in any form whatsoever, directly or through an intermediary, to a private party or a representative of the public authorities in any country, with the purpose of obtaining favorable treatment or influencing the outcome of a negotiation in which Air Liquide is involved.

Protection of Air Liquide activities

Each employee must properly protect and keep confidential any strategic, financial, technical or commercial data or documents that are not public and whose disclosure to third parties could be harmful to the interests of Air Liquide.

Protection of information

Likewise, professional and private information concerning a named person is confidential and must be subject to all the precautions needed to prevent inaccurate or inappropriate modification or disclosure.

The duty to maintain confidentiality also applies to information provided by Air Liquide’s partners and customers. It is up to each Air Liquide employee to respect these rules on the protection of information.

This duty on confidentiality continues even after the departure of an Air Liquide employee.

Protection of property and resources

Each employee must properly protect and keep confidential Group property and resources such as intellectual property (patents, trademarks, and copyrights), installations, equipment and financial resources or cash. These resources and property must be used in accordance with their professional purpose and in the established framework.

They may not be used for personal ends except if explicit authorization has been granted by a duly authorized individual in the framework of established procedures.

Lastly, it is the responsibility of each employee to protect the property and resources of the Group against any damage, inappropriate alteration, fraud, loss or theft.

Transparency and integrity of information

Transparency and Integrity of Information

Each employee who takes part in the production, analysis, filing or communication of this information must carry out these operations honestly and transparently.

Internal control and audit

Internal control systems set up within the Group (respect for laws, regulations, policies or procedures, asset protection and reliable financial information) help control its activities, operational efficiency and the efficient use of its resources.

Each Air Liquide employee must contribute to the efficiency of the internal control systems and cooperate with the internal or external audits (that are involved in the evaluation of these systems), especially by showing diligence and transparency in satisfying any requests for information.

Implementation of the Code of Conduct

If there is any doubt about the interpretation or application, in a given situation, of the rules presented in this document.

Each Air Liquide employee has the right to inform his or her immediate supervisor, or his or her unit's Human Resources Department, the E&C Legal Department or Corporate Governance Officer, the Air Liquide Group Personnel Department or the Group Ethics Officer about it

In addition, an employee who has, in good faith, pointed out a breach in the rules pointed out in this document will not be subject to any disciplinary measures.