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Ethical Code of Conduct

Santa Fe Group supports a number of international codes:

UN Universal Declaration of Human Rights, UN Global Compact, Global Business Coalition on HIV/AIDS, Global Sullivan Principles, OECD Guidelines for Multinational Enterprises, Equator Principles

Based on these and other standards, Santa Fe Group has developed a Supplier Code of Conduct that is applicable throughout our organization and we expect everyone with whom Santa Fe Group has commercial dealings to support these basic principles:

The supplier shall comply with all laws applicable to its business. This especially applies to:

Improper Payments/Bribery: The supplier will apply a zero-tolerance approach with respect to corruption, extortion and bribery in accordance with principle 10 of the UN Global Compact.

The supplier shall comply with international anti-bribery standards as stated in the United Nations Global Compact www.unglobalcompact.org as well as local anti-corruption and bribery laws. In particular, the supplier may not offer services, gifts or benefits to Santa Fe employees in order to influence employee conduct in representing Santa Fe.

Santa Fe Group does not tolerate and will not participate in any bribery directly or through intermediaries. The supplier must report incidents, risks and issues which deviate from the policy occurring on any service provided to Santa Fe Group.

Child and Forced Labor: The supplier must not employ children under the age of 15. If national laws or regulations allow children between the ages of 13 and 15 to perform light work, such work is not permitted in any case if it would hinder a minor from the completion of compulsory schooling or training, or if the employment would be harmful to their health or development. The supplier shall make no use of forced or compulsory labor.

Compensation and Working Hours: The supplier shall comply with the respective national laws and regulations regarding working hours, wages and benefits.

Discrimination: The supplier does not discriminate on the basis of race, religion, disability, age, sexual orientation or gender.

Health & Safety: We expect our suppliers to strive to implement the standards of occupational health and safety at a high level.

Environment: The supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment. We also expect our suppliers to take environmental protection into account in their own operations by setting protection goals for themselves and achieving them

Business Partner Dialogue: The supplier shall communicate the principles stated in the Code of Conduct and detailed above to its subcontractors and other business partners who are involved in supplying the products and services described in the main contract.

Compliance with the Supplier Code of Conduct: Santa Fe reserves the right, upon reasonable notice to check compliance with the requirements of the Supplier Code of Conduct. Santa Fe encourages its suppliers to implement their own binding guidelines for ethical behavior.

Any breach of the obligations stipulated in this Supplier Code of Conduct is considered a material breach of contract by the supplier.