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CONTENTS

CONTENTS 1 Revised January 2018 Revised January 2018 CONTENTS 2 Introduction Page Message from Dominic Blakemore 3 Code of Business Conduct 4 Getting Help and Advice 5 Speak Up 6 Visions and Values 7 The Compass Way Food Safety 8 Responsible Supply Chain 9 Personal Integrity Conflicts of Interest 10-11 Insider Trading 11 Gifts and Hospitality 12-14 Commercial Integrity Competition and Anti-Trust 15-16 Money Laundering 16 Bribery and Corruption 17-18 New Territories, New Sectors, Agents and Consultants 18 Reporting and Accounting 19 Data Privacy 20 Employment Health and Safety 21-22 Fair Treatment and Equal Opportunities 23 Worki ng Without Harassment/Bullying 24 Company Assets Brand Protection 25 Confidentiality 26 Physical Assets 26 Information Security 27 External Activity Dealing with Government and Public Regulatory Bodies 28 Community and Charitable Activity 29 Political Activity 30 External Communications 31 Environment 32 Reference Policies and Further Information 33 Contacts 34 February 2011 (updated to take account of new contact details and role descriptions, February 2016) (updated to take account of new Group Chief Executive, contact detai)

Business Conduct and to conduct our business in a professi onal, safe, ethical and respons ible mann er. This is without exception or compromise. The Code of Business Conduct brings together our policies on compliance and ethical issues and is to be followed by all employee s …

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