Argent Code of Conduct and Whistleblowing Procedure

Argent is committed to acting responsibly in the conduct of our business.  We have a reputation for dealing fairly and acting with integrity.  Our employees are held to a Code of Conduct and we will only do business with those suppliers and business partners who look to uphold the same ethics and standards as Argent themselves.

Our principles are as follows:

·        All employees and business partners manage activities in such a way that aims to bring no harm to individuals or the environment.

·        We take a zero tolerance approach to bribery, fraud and corruption.

·        Argent is committed to complying with all applicable competition and anti-trust legislation.

·        We apply a fair selection process to appoint suppliers of goods and services.

·        To maintain integrity in relationships with third parties, strict rules apply to the exchange of gifts and hospitality.

·        Where a conflict of interest occurs, individuals should declare the conflict to a trusted senior manager and appropriate steps will be put in place to avoid undue commercial influence.

·        Argent applies respect in the workplace and promotes an inclusive working environment.

·        We expect that our business partners oppose slavery and human trafficking, respecting human rights across the globe.

·        Social media should not be used to bring the company into disrepute.

Business partners may report concerns and instances of suspected or actual non-compliance related to an employee or any associated third  party acting on behalf of Argent.  Business partners in this context include contractors, partners, suppliers and customers.

Confidential reports can be made to the group internal audit department (GIAD) of John Swire & Sons using an independent whistleblowing email address:

Ia@jssldn.co.uk

All reports will be independently investigated as a matter of urgency.  The anonymity of the reporting party will be safeguarded if desired.  No retaliation will be taken against people who report in good faith, even if the investigation is closed without action.