Operating with Integrity in All we Do

The way we conduct our business is as important as the results we achieve. Integrity is the cornerstone expectation that shareholders, consumers, employees and the public demand of corporations. We require everyone associated with the company - directors, officers, employees and suppliers acting on our behalf - to observe the highest ethical standards.

Our ethics policy is clear-cut, straightforward, and applied without exception. Its guiding principles are directed at meeting our commitments to shareholders, customers, employees and the communities with which we interact. Our Standards of Business Conduct incorporate these principles, have existed for nearly forty years, and are continually reemphasised.

The Standards of Business Conduct address a wide variety of subjects that pertain to the manner in which our business is pursued.

The strength of any policy is how well it is implemented. Our System of Management Controls is direct, proven, and tested for effectiveness. Like everything else we do, it is subjected to a continuous improvement process which seeks nothing less than operational excellence.

Our approach includes:

• A substantial majority of the Board of Directors are non-employees
• The Board Audit Committee is empowered to investigate any matters brought to its attention and has 100% non-employee membership.
• An independent Internal Audit staff assesses compliance with policies and procedures, and evaluates control effectiveness in about 300 audits conducted annually around all business units.
• Steps are taken to assure the independence of both internal and external auditors.
• Employees regularly review and discuss expectations and are encouraged to raise questions or concerns.