codeofconduct

KOCH Code of Conduct

PrefacePrefaceDear fellow employee,The long-term success of your business depends on many factors, butnone is more important than your commitment to our core values andMBM® Guiding Principles. It is your responsibility to know and live bythese Principles.We want to maintain absolute integrity and 10,000 percent compliancewhile achieving safety and environmental excellence (Principles 1, 2and 3). All three of these Guiding Principles are necessary for achievinglong-term business survival and success. Without them, we cannotcreate — or share in — real, long-term value.This Code of Conduct is an important tool to help you meet the needfor compliance and ethical decision-making. It answers manycommonly asked questions and tells you how to find further informationand help. It also emphasizes placing the highest priority on risks thatcould cause the most serious harm to people, the environment or thebusiness. Our goal is to go beyond systems and processes. We want everyemployee to take ownership of his or her performance by living ourGuiding Principles and actively applying MBM. Whether you have beenwith Koch for days or decades, developing and maintaining our Market-Based Management® culture is your responsibility. It’s what we expectof everyone at Koch and what you should expect of your leaders.  Doing so requires a true challenge culture. By that, I mean you must bewilling to speak up about any behavior that might violate our Principles— even if it involves your supervisor. This requires courage. Without itwe cannot act with integrity. Not only must we be open to challenges,we must solicit them, so that we create the conditions for innovationand long-term success.As this Code of Conduct makes clear, it is critical that you live by ourPrinciples, regardless of your role or experience. We must always obeythe law, act with integrity and strive for EHS excellence. You owe it toyour family, your coworkers, your business, your customers, yourcommunity and yourself. Our future depends on it. Charles KochChairman and CEOKoch Industries, Inc.

MBM Guiding PrinciplesMBM® Guiding PrinciplesOur MBM® Guiding Principles articulate our rules of just conduct alongwith our shared values and beliefs. Every one of us must internalizethese core values and exemplify them in all we do. 1 Integrity – Conduct all affairs with integrity, for which courage is thefoundation.2 Compliance – Strive for 10,000% compliance with all laws andregulations, which requires 100% of employees fully complying 100%of the time. Stop, think and ask.3 Value Creation – Create long-term value by the economic means forcustomers, the company and society. Apply MBM® to achieve superiorresults by making better decisions, pursuing safety and environmentalexcellence, eliminating waste, optimizing and innovating.4 Principled Entrepreneurship™ – Apply the judgment, responsibility,initiative, economic and critical thinking skills, and sense of urgencynecessary to generate the greatest contribution, consistent with thecompany’s risk philosophy.5 Customer Focus – Understand and develop relationships withcustomers to profitably anticipate and satisfy their needs.6 Knowledge – Seek and use the best knowledge and proactivelyshare your knowledge while embracing a challenge process. Developmeasures that lead to profitable action.7 Change – Anticipate and embrace change. Envision what could be,challenge the status quo and drive creative destruction throughexperimental discovery.8 Humility – Exemplify humility and intellectual honesty. Constantlyseek to understand and constructively deal with reality to create valueand achieve personal improvement. Hold yourself and othersaccountable.9 Respect – Treat others with honesty, dignity, respect and sensitivity.Appreciate the value of diversity. Encourage and practice teamwork.10 Fulfillment – Find fulfillment and meaning in your work by fullydeveloping your capabilities to produce results that create the greatestvalue.

Introduction\"Our MBM® Guiding Principles articulate our rules of just conductalong with our shared values and beliefs. Enforcing these generalprinciples enables employees to challenge the particulars.\" —CharlesKochIntroductionOur company is committed to conducting all affairs lawfully and alwaysacting with integrity. This commitment extends throughout our globalorganization, no matter where in the world we do business. Ouremployees have a responsibility and are expected to hold themselvesto the highest legal and ethical standards. This commitment to integrityand lawfulness requires sound judgment, critical thinking and thecourage to do the right thing, even if that means the loss of a businessopportunity. Our company measures itself not only by the results we achieve, but byhow we achieve them. Following procedures, which are important andnecessary, is not the end goal. Rather, we must always focus onimproving our compliance results. Therefore, integrity must be a part ofevery decision we make, and the decisions we make must reflect acommitment to compliance with applicable laws and regulations.All employees, directors and officers are expected to be familiar withthis Code of Conduct (Code) and adhere to it. Except where applicableprovisions of this Code are superseded by local laws or legalobligations, a violation of the Code may constitute just cause fordisciplinary action, up to and including termination. Employees whoviolate this Code may also be subject to civil and/or criminal action,pursuant to any local, state or federal laws of any country in which thecompany conducts business.This version of the Code supersedes all prior versions. It is anexpectation of employment with the company that you are familiar withand adhere to this updated Code.Tag_Set_G

How the Code AppliesHow the Code AppliesThis Code is intended to be consistent with all applicable laws andlegal obligations, including those under collective bargaining (tradeunion) agreements. In the event of any inconsistency between thisCode and any applicable law or collective bargaining agreementprovision, we will comply first with the law or agreement.For business locations outside the United States (U.S.), we will adhereto U.S. laws that have extraterritorial application and all laws of the hostcountry. If you believe there are any inconsistencies between the Codeand the laws of any host country, consult with Legal.In addition to this Code, it is your responsibility to seek furtherinformation regarding the laws, standards, policies, procedures,practices, guidelines and work rules that may be applicable to yourrole.This Code does not constitute a contract of employment or anassurance of continued employment for any individual.Tag_Set_L

Responsibilities as EmployeesResponsibilities as EmployeesThis Code is an important part of our company’s overall complianceand ethics program. It is a foundational tool for when you havequestions or face dilemmas and where the right choice is not clear.However, the Code cannot cover every possible situation, nor can itspecifically address all of the applicable laws at each of our locations.We expect and welcome questions about this Code, its interpretation orthe law.  You are never authorized to act illegally or unethically, even when doingso may seem to be in the best interest of the company or if asupervisor or any other employee has directed you to do so.Every employee has the responsibility to: Always act in accordance with applicable laws, this Code, our Guiding Principles and other company standards, policies, procedures, practices, guidelines and work rules. Avoid any activity that might have the appearance of being illegal or unethical. Seek a full understanding of compliance requirements, risks and key controls that apply to your role. No one is expected to know every policy or standard word for word, but you should understand the policies and standards that apply to your role. When you have questions, seek assistance from the many resources that are available to you. Promptly report potential or actual violations of a law, company policy or standard, or any request to violate a law, company policy or standard. Promptly report any issue that you believe has not been appropriately resolved, even if it means raising it with another available resource. Cooperate completely and honestly with company investigations.Retaliation, retribution or harassment against any employee who,in good faith, asks any question or raises any concern regardingethical behavior or compliance responsibilities is against companypolicy and is prohibited.  Tag_Set_E

Responsibilities as LeadersResponsibilities as LeadersLeaders have additional responsibilities to: Lead by example and behave as a model for all employees. Provide education and tools that promote employee understanding and compliance. Create an ethical culture that promotes compliance, encourages employees to raise their questions and concerns, and prohibits retaliation. Promptly address employee concerns of wrongdoing. Evaluate and, as appropriate, recognize and reward employees who adhere to and promote legal compliance and ethical behavior.Tag_Set_E

Chapter 1\"Our challenge process depends on a willingness to respectfullyengage in open, honest and objective debate. Each of us mustchallenge the status quo and humbly consider any challenges to ourown beliefs, proposals and actions. This applies as much tochallengers as those being challenged.\" —Charles KochAsking Questions, Raising Concerns andGetting GuidanceWe have a clear responsibility and must have the courage to askquestions and raise concerns about compliance or ethical behavior.When you know of, or suspect, a possible violation, you have aresponsibility to report, in good faith, that information to yoursupervisor. If, for any reason, you feel uncomfortable reporting issues toyour supervisor, or if you believe your supervisor has not appropriatelyaddressed an issue, you have other options. If you are uncertainwhether your own conduct is proper, ask for help from any of theoptions available to you.

Chapter 1.1Options for Asking Questions, RaisingConcerns and Getting Guidance Your immediate supervisor Any member of management Any local or corporate human resources leader Any compliance and ethics resource Any lawyer in Legal Contacting the GuideLineYou may report your concern online by visitingwww.mykochguideline.com. International toll-free phone numbers aredisplayed once you have selected your Koch company and countrylocation, if you prefer to contact the GuideLine by phone. Posters withinternational toll-free GuideLine numbers may also be posted in yourworkplace.The GuideLine is operated confidentially by an independent third-party.It is available 24 hours a day, 7 days a week, to respond to yourquestions and concerns (anonymously, if you choose and as allowedby local law). It also offers multilingual services. The GuideLinespecialists notify the Compliance & Ethics department, which willassess and determine appropriate action.The GuideLine appropriately addresses the use, retention, transfer,disclosure and protection of any personally identifiable informationcontained within, including responsible and lawful collection anddisposal.

QA1Does management really expect adherence to the Code if that wouldmean losing business or reducing profitability?Yes. Compliance always takes precedence over profitability. That iswhy Integrity and Compliance are the first two Guiding Principles.

QA2What should I do if my supervisor asks me to do something that I thinkviolates the Code or a company policy, or may be illegal?Regardless of who asks you, never do anything illegal. If you believesomething you have been asked to do violates the Code or companypolicy, you must “stop, think and ask” before you act. If your concern isnot appropriately addressed, you must report your concern to one ofthe many options available to you.

Chapter 1.2No-retaliation PolicyRetaliation, retribution or harassment against any employee who,in good faith, asks any question or raises any concern regardingethical behavior or compliance responsibilities is against companypolicy and is prohibited. “Good faith” does not mean that a reportedconcern must be correct, but it does require that you believe you areproviding complete and truthful information when you report a concernor ask a question.Tag_Set_B

QA1Will I get into trouble if I call the GuideLine or inform managementabout an ethics issue and it turns out to be wrong?No. As long as you honestly have a good faith concern, our policyprohibits you from being retaliated against for simply raising yourconcern. Retaliation in any form is a violation of our policy. We expectyou to voice concerns and questions about compliance and ethicsissues using the many options available to you.All employees should practice respect and integrity at all times,whether they are reporting someone else or are the subject of a reportthemselves. If you feel you are being retaliated against, you mustcontact one of the options available to you.

QA2I reported an ethics issue and a short time after reporting the issue Iwas reassigned to a new work area. I believe I am being retaliatedagainst. What should I do?If you believe you are being retaliated against, you must report it to yoursupervisor or report your concern to one of the many options availableto you.

Chapter 1.3Internal Investigation of ReportsThe company is committed to identifying and correcting wrongdoingwherever it may occur. All reported concerns will be promptly assessedand a determination made regarding the appropriate level ofinvestigation and response. All employees are expected to cooperatefully with investigative efforts. This includes always giving truthful,accurate and complete answers, even if those answers areuncomfortable or create more questions. Investigations must beconducted by a resource suited to investigate the concern,appropriately considering the need for independence and impartiality.To the extent possible, the company will maintain confidentialityconsistent with our legal and ethical responsibilities.Tag_Set_B

Chapter 1.4Corrective Action and Employee DisciplineAny employee who violates the law, the Code, or other companypolicies, standards or work rules will be subject to appropriatedisciplinary action, up to and including termination, consistent with anyapplicable law, employment contract or bargaining agreement.The specific disciplinary action will depend on a number of factors,including, but not limited to: The nature, severity and frequency of the violation. The degree of knowledge and responsibility regarding the violation and the effect of the behavior on others, both inside and outside the company. An employee’s degree of direct involvement. An employee’s voluntary self-reporting of a violation and acceptance of their responsibility. An employee’s history, including performance-related factors.Tag_Set_L

Chapter 1.5Making Decisions with IntegrityIt is not always easy to determine the ethical or “right” thing to do in aparticular business or work situation. Sometimes a law or policy clearlydictates the outcome, but often a situation will require interpretation todecide a fair and reasonable course of action.Thinking through a situation alone may not result in the same quality ofdecision-making as when we seek the knowledge of others. Theengagement of other knowledgeable resources in the decision-makingprocess increases the likelihood that all the facts and alternatives areconsidered.When making decisions, ask: Are there other resources that could contribute? Is it consistent with this Code and our Guiding Principles?  Is it the right thing to do?There are resources available to you to assist in resolving issues. Youcan ask your supervisor, any member of management, any local orcorporate human resources leader, any compliance and ethicsresource, or any lawyer in Legal.Tag_Set_G

QA1How do I know when I need to get help?Remember to “stop, think and ask.” Consider the following: Are youractions making you feel uneasy? Is your information correct andcurrent? Are you rationalizing your actions? Are you saying to yourself,“Everybody does it”? How would your actions be perceived by others?Any discomfort should cause you to stop, step back, consider whatyou are doing, get advice and, if appropriate, redirect your actions soyou are sure that you are doing the right thing.

Chapter 1.6Seven Element Risk Management SystemThe company has implemented systematic programs to help ensurethat business activities are conducted lawfully and with integrity.These programs typically address the following elements: Leadership and management commitment Employee ownership Compliance and risk assessment Compliance and risk management Communications and training Change management Continuous improvementThere may also be Koch company specific standards, policies,procedures, practices, guidelines, work rules and other tools to governyour behavior and particular types of activities. If you have questionsabout them, contact your supervisor or your compliance and ethicsresource for more information regarding the risk management systemand other programs or tools that have been implemented in your Kochcompany.Tag_Set_E

Chapter 1.7Audit and AssuranceThe company is committed to assuring proactive compliance with thelaw, our Guiding Principles, the Code, company standards, policies,procedures, practices, guidelines and work rules. Audits andassessments are used to verify compliance, improve overall riskmanagement, identify opportunities for improvement and educateemployees. All of us must fully embrace audit activities and takeappropriate corrective action. We are expected to give accurate andcomplete answers, even if those answers make us feel uncomfortableor create more questions.Tag_Set_E

Chapter 2\"For businesses to make the greatest contribution to society, we musttreat others with honesty, dignity, respect and sensitivity, andappreciate the value of diversity. Giving honest feedback is critical,because not giving it usually leads to a bad outcome for the individual,thus failing the test of respect. Unlawful and illegitimate discriminationand harassment are violations of all these requirements and will not betolerated.\" —Charles KochRespect for OthersOur success requires us to utilize everyone’s skills and knowledge tothe fullest, without unlawful discrimination or harassment. Consistentwith our Guiding Principles, we are committed to providing a respectfulworkplace where all are treated with dignity, respect, honesty andsensitivity. The company appreciates the value of diversity. To denysomeone’s contribution to the company because of unlawfuldiscrimination or harassment would be an injustice not only to theindividual, but to the company as well, and will not be tolerated.In some countries where we operate, local law establishes specificrequirements for policies that prohibit discrimination and harassment.Contact your local human resources leader with any questionsregarding specific policies that apply to you.

Chapter 2.1Non-discriminationConsistent with our Guiding Principles, it is good business and soundphilosophy to recognize and treat employees with fairness, impartiality,awareness and sensitivity. We will grant equal opportunity in all aspectsof employment to all persons without unlawful discrimination.Unlawful discrimination will not be tolerated.The company prohibits unlawful discrimination on any protected basisunder applicable law, including, but not limited to: color, race, religion,gender or gender identity, sexual orientation, national origin,citizenship, ethnicity, age, disability, pregnancy, veteran status, geneticinformation, or other legally protected factors.If you believe you have been discriminated against, have observedunlawful discrimination, have knowledge or someone confides in youthat a coworker believes that he or she has been discriminated against,you must contact any of the following: your immediate supervisor,any member of management, any local or corporate human resourcesleader, any compliance and ethics resource, any lawyer in Legal or theGuideLine.  Tag_Set_B

Chapter 2.2Prohibited HarassmentUnlawful harassment will not be tolerated.The company is committed to providing a work environment free ofunlawful harassment. Company policy prohibits harassment based oncolor, race, religion, gender or gender identity, sexual orientation,national origin, citizenship, ethnicity, age, disability, pregnancy, veteranstatus, genetic information, or other legally protected factors.Harassment includes any verbal or other conduct that is offensive,bullying, intimidating or disparaging to any individual or group and isbased on that individual’s inclusion in a legally protected group. Thecompany also prohibits unlawful harassment based on the perceptionthat an individual is a member of such a group, or is associated with anindividual who is or is perceived to be a member of a protected group.All such harassment is unlawful. The company’s policy prohibitingharassment applies to all persons involved in the operation of thecompany and prohibits unlawful harassment, whether directed toemployees, applicants for employment, or other people we do businesswith, such as outside vendors, contractors or customers.Conduct that is prohibited includes, but is not limited to, thefollowing behaviors: Verbal conduct such as epithets; slurs; derogatory and/or sexually-oriented jokes or comments; discussion or inquiries about one’s own or someone else’s sexual activities; or unwelcome sexual advances, propositions, flirtations, invitations or comments. Visual displays such as derogatory and/or sexually-oriented posters, photographs, pornographic displays, cartoons, drawings or symbols. Dissemination of derogatory and/or sexually-oriented voice mail, email, graphics, downloaded material or websites. Unwelcome touching of a sexual nature, gestures, intentional blocking of normal movement or interfering with work, or other conduct directed toward a person due to their gender, race or any other protected basis. Threats or demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favors.The use of any media, including phones, email, instant messaging orthe Internet, for the purpose of unlawful harassment, will not betolerated.Tag_Set_B

Chapter 2.3Expectations of EmployeesEvery employee is required to abide by our policy against unlawfuldiscrimination and prohibited harassment and to bring to thecompany’s attention any action that does not comply with that policy orour commitment to equal employment opportunity. Supervisors andmanagers must be watchful for any signs that our policy is not beingfollowed and must report any possible violations even if there has beenno complaint. The company will investigate and respond to all reportsof unlawful discrimination or prohibited harassment.If you believe you have been subjected to discriminatory or harassingbehavior, you observe such conduct, have knowledge or someoneconfides in you that he or she believes they have been subjected tosuch behavior, you must contact any of the following: your immediatesupervisor, any member of management, any local or corporate humanresources leader, any compliance and ethics resource, any lawyer inLegal or the GuideLine. Retaliation against anyone for reportingunlawful discrimination or prohibited harassment in good faith isagainst company policy and is prohibited.Tag_Set_B

QA1One of my coworkers has a habit of telling jokes that offend me andothers. Another coworker is sending inappropriate email. How can I getthis to stop?The company promotes a respectful workplace. Principle 9, Respect,states that all company employees are to treat others with honesty,dignity, respect and sensitivity.If a coworker is engaging in conduct that may be offensive or causesothers discomfort, you should approach the employee directly and askhim or her to stop. If you do not feel comfortable addressing this issuewith the particular individual, you must report this behavior using one ofthe many options available to you.

QA2I have noticed some offensive graffiti in my work area and sometimesoverhear some of my coworkers using racial slurs. Their conduct is notdirected at me, but I feel like I should say something. I’m afraid they willtake it out on me if I say anything. What should I do?You are obligated under our Non-discrimination and ProhibitedHarassment policy to report what you have seen and heard, even if youare not the target or victim. If you are uncomfortable speaking toanyone locally, contact one of the many options available to you.

QA3A supervisor at my location tends to criticize her employee’sperformance in public settings. Her behavior often includes yelling at orbelittling the employee in front of others. I find it offensive and it seemsmy coworker is quite embarrassed, but what business is it of mine?Guiding Principle 9, Respect, states that all company employees are totreat others with honesty, dignity, respect and sensitivity. No employeeshould be subjected to disrespectful or belittling behavior such asyelling, screaming or using profanity. While this may not be illegal orunlawful, this behavior is inconsistent with our Guiding Principles. If anemployee is engaging in conduct that is disrespectful or belittling youshould approach the employee directly, if you feel comfortable doingso, and ask him or her to stop. If you do not feel comfortableaddressing the issue directly with the individual, you must report thisbehavior using one of the many options available to you.

Chapter 2.4Commitment to Lawful EmploymentPracticesOur companies strive to make people’s lives better through theproducts we make, support for the communities in which we live andwork, maintaining quality work environments, and sourcing responsibly.We are committed to adhering to applicable employment and laborlaws everywhere we operate. This includes observing those laws thatpertain to child labor, forced labor, human trafficking, wages and workhours and freedom of association. In addition to other expectationscontained in this Code, our commitment to social responsibilityspecifically includes the following: Child LaborThe company will not employ underage individuals as defined byapplicable child labor laws. Employees will not be permitted to work ina position where they are younger than the minimum legal age foremployment in that job.Forced LaborThe company does not support the use of forced labor or involuntaryprison labor. Recruiting and selection activities are conducted incompliance with applicable law and any applicable collectivebargaining obligations.Wages and Work HoursThe company is committed to meeting all minimum wage obligationsand collective bargaining agreements regarding maximum hours,minimum wage, overtime work and the payment of overtimecompensation.The company: Recognizes an employee’s right to breaks and meal periods required by applicable law or collective bargaining agreement and the company will pay for those breaks wherever required by law. Will provide to employees all periods of leave to which they are entitled under applicable law.   Will provide employees with all benefits to which they are entitled under applicable law.Freedom of AssociationThe company complies with applicable laws related to an employee’schoice to join, or refrain from joining, any legally sanctioned associationor organization.

Chapter 2.5Prohibited SubstancesWe are committed to providing a safe workplace that is free from theuse of prohibited substances, including drugs and alcohol. The abuseof alcohol, the use of illegal drugs or the misuse of prescription drugsor other controlled substances has the potential to affect our safety,attendance, productivity, attitude, reliability and much more.We strictly enforce, consistent with local law and collectivebargaining agreement provisions, the following: You may not be under the influence of alcohol, illegal drugs or misuse prescription drugs while performing your work responsibilities. You may not unlawfully manufacture, distribute, sell or possess alcohol, drugs or other controlled substances while performing your work responsibilities. If you are employed in a safety-sensitive role or are required to operate machinery or a motorized vehicle (including a rental car) in the course of your employment, you must notify the company of an alcohol or drug conviction no later than five days after conviction. In some locations where we operate, such reporting may be prohibited by local law. Contact your local human resources leader if you have any questions regarding the applicability of this provision at your location. Alcohol may not be consumed on property owned, leased or occupied by the company. Exceptions may be appropriate in limited circumstances and are permitted only when the pre- approval requirements of your Koch company have been met. The company will exercise appropriate steps to ensure compliance withthis policy, including testing of applicants and employees as allowed byapplicable law and collective bargaining agreement provisions.Tag_Set_H

QA1Is it acceptable to consume alcoholic beverages when on companybusiness, such as entertaining a customer at a business dinner orparticipating in a company-sponsored event?Use good judgment and obey all relevant laws. These laws include notdriving while under the influence and not serving alcohol to minors.Please consider, however, that if you consume alcoholic beverages andreturn to your workplace and the company has reasonable suspicionthat you are under the influence of alcohol, you may be asked to submitto testing and may be subject to disciplinary action, up to and includingtermination.

Chapter 2.6Workplace Non-violenceWe are committed to an environment free from violence, intimidationand other disruptive behavior. Bullying, violence, threats, harassment,intimidation and other disruptive behavior will not be tolerated. Suchbehavior can include oral or written statements, gestures orexpressions that communicate a direct or indirect threat of physicalharm.Your cooperation is essential to effectively maintain this policy and tohelp maintain a safe working environment. Do not ignore violent,threatening, harassing, intimidating or other disruptive behavior.All reports of such incidents are taken seriously, assessed and dealtwith appropriately. If you observe or experience such behavior byanyone — whether an employee, contractor, customer or visitor — onpremises owned, leased or occupied by the company, report itimmediately to one of the many resources available to you.Threats or assaults requiring immediate attention should bereported to your supervisor, human resources or security contactor to the police.Tag_Set_B, Tag_Set_I

Chapter 2.7Prohibition of WeaponsThe company prohibits employees from bringing any firearm or otherweapon, to include, but not limited to ammunition and explosives, onany property owned, leased or occupied by the company. You are alsoprohibited from personally carrying or transporting any weapon in yourown vehicle while on company business or when using company paidtransportation, such as company-owned or leased vehicles.Exceptions to this policy will be permitted only with the prior writtenapproval of your business leader and compliance and ethics resourceor as allowed by applicable laws. Authorized weapons must beappropriately secured from theft, misuse and accidental discharge, andmust be handled in compliance with applicable laws.This policy does not apply to law enforcement officers, government ormilitary authorities or their agents acting in their official capacities.Instruments such as knives or other cutting instruments required,approved, or provided by the company in accordance with jobassignments do not apply to this policy.Tag_Set_I

QA1Are mace and pepper spray considered weapons?Mace and pepper spray are primarily defensive devices and are notprohibited by the company. If you feel unsafe at the workplace, you areobligated to raise the concern through one of the many optionsavailable to you.

Chapter 2.8SearchesThe company maintains the right, to the extent allowed by local law, tocarry out searches and examine persons or their property when onproperty owned, leased or occupied by the company. Such searchesmay be performed without notice. This right includes, but is not limitedto, the right to search and examine all equipment, offices, furniture,computers, lockers, personal items, vehicles, containers, briefcases,backpacks, purses and pockets. Any illegal, unauthorized,misappropriated or prohibited items may be seized by the company, ifallowed by applicable law and/or reported to the proper authorities.Tag_Set_F, Tag_Set_H, Tag_Set_I

Chapter 2.9Privacy and Data ProtectionThe company is committed to compliance with all applicable privacyand data protection laws in all countries in which we operate. Thiscommitment reflects the importance we place on earning and keepingthe trust of our employees, customers, suppliers, consumers and otherindividuals when we are in the possession of their personal data. The definition of personal data varies by jurisdiction. Information or acombination of data that identifies a unique individual, such as name,personnel number, address, date of birth or other identifiers may bepersonal data. Personal data must be safeguarded from loss or theftand inappropriate use or collection. If you manage personal data as apart of your role for the company, make sure you take steps toappropriately secure it and limit access to such information only tothose who have a legitimate business need. Your Koch company’s Privacy Policy and Employee Privacy Noticeprovide further information regarding our practices to protect personaldata, such as notice, use, access, retention, choice, collection, transfer,security and data integrity of personal data. If you suspect thatpersonal data has been used, altered or disclosed inappropriately, orthat a breach of personal data may have occurred, you must reportyour concern to one of the many options available to you.  Tag_Set_J

Chapter 3\"Someone once asked how much I was paid in royalties for my book,'The Science of Success.' I explained that, since the book was writtenon company time using company assets and resources, all royaltieswere paid to the company, not me. No one is exempt from our rules inthis regard.\" —Charles KochProper Use of Assets and Ideas

Chapter 3.1Careful CommunicationAll communications must be prepared responsibly and withconsideration for the intended business purpose. Communicationsmust also be in full accord with our Guiding Principles and this Code.In all communications, it is important to tell the truth and to avoidexaggeration, speculation, inappropriate language and derogatoryremarks or characterizations. This applies to communications of allkinds, whether written or verbal, and includes phone conversations,emails, instant messages, voice mail, daily planner notes and other“informal” notes or memos.Consider the following: Determine the best method to communicate. Would a phone call or in-person meeting be better? Clearly state the purpose of the communication. Stick to the point. Is the content factual? Do not include language or present information in a manner that may be perceived as offensive, inflammatory, harassing or otherwise inappropriate. Do not speculate on outcomes, conclusions or scenarios unless there is a clear business need to do so. Do not make legal conclusions unless you are qualified to do so. Assert attorney-client privilege only as directed by an attorney or when seeking an attorney’s legal advice. Speak on behalf of the company only when authorized and without representation of personal opinion. If you are personally supporting or endorsing our company products, brands or services in a public forum, you must disclose your affiliation with the company and make it clear in your personal post that you are speaking on your own behalf. Consider how the message may sound if taken out of context. Provide information on a need-to-know basis. Mark communications confidential as appropriate. Think before you send. Use good judgment in what and how you say things.Tag_Set_C

QA1There is a blog site where other individuals that have the same type ofrole as I do exchange information. I’ve noticed that some individuals’responses include their workplace auto signature that reflects theirname, title and company information. Is it acceptable for me to utilizeblogs?You should stick to the facts when seeking or giving information andkeep in mind company confidentiality and careful communicationpractices. Information posted on external blogs or other discussionforums is available to the general public and may be archived for longperiods of time. In addition, the inclusion of your auto signature couldbe misinterpreted as a representation of the company when in fact, it isnot. You must not do anything that may be understood as arepresentation on behalf of the company.

Chapter 3.2Privacy ExpectationsElectronic communication tools used for company business are subjectto monitoring by the company to the extent allowed by law. Thecompany has the right to access these tools and use the content forany lawful purpose.In some countries where we operate, local law requires more specificnotifications and policies regarding the privacy of electroniccommunication tools used for company business. If these are requiredat your location, they will be provided to you separately from this Code.The company does not make any guarantees about the reliability ofcompany-provided electronic communication tools for personal use. Ifyou have a need to transmit personal, sensitive information, you shouldconsider using a communication method other than company-providedelectronic communication tools.Tag_Set_J

Chapter 3.3Acceptable Electronic UsageThe company provides a number of electronic communication toolsthat its employees use every day. These tools enhance our competitiveadvantage in the marketplace. Constant technological changes willincrease the number and type of company-approved communicationtools available to employees.Regardless of which company-approved communication tools you use,you are expected to use them in an acceptable manner, for properpurposes. This policy applies to all communications related to companybusiness or involving company employees.  Appropriate and acceptable uses of company-approvedcommunication tools include: Internal (with other company employees) and external (with customers, suppliers and business partners) business communications. Access to information for appropriate business, technical and research purposes. Limited personal use that does not distract from your regular job duties, is not excessive and does not result in inappropriate or unapproved costs. Employees and supervisors should discuss what constitutes unacceptable costs and whether reimbursement to the company is appropriate based on the employee’s roles and responsibilities, and the situation.Inappropriate and unacceptable uses include: Revealing the company’s proprietary or confidential information without the appropriate authorization or agreements in place, whether this is done inadvertently or intentionally, and whether inside or outside of the company. Accessing, distributing or storing materials that could be considered unethical, inappropriate, offensive, disrespectful, harassing or abusive to others. Conducting outside business. Transmitting legally privileged information without permission from Legal. Misrepresenting oneself as another individual or company. Conducting illegal activities. Sending, receiving, forwarding or copying information in violation of copyright laws. Overloading the company network, such as engaging in excessive streaming of music and videos.Tag_Set_J

QA1I am in the process of buying a home and must immediately send adocument to my agent. May I use company equipment or must I leavethe office to do this?Use good judgment and use company equipment. Depending on thecircumstances, insubstantial and infrequent personal use of companyassets may be acceptable. If you have questions about such situations,discuss them with your supervisor.

QA2I am going on vacation with my family. Is it acceptable to use theInternet to make reservations?Yes. Personal use that is brief, infrequent and appropriate isacceptable.

QA3May I use my company mobile phone to make personal calls?Limited personal use of communication tools by employees that doesnot result in inappropriate or unapproved costs, such as long distanceor other usage charges is acceptable.

Chapter 3.4Offensive or Harassing CommunicationsIt is unacceptable to view, access, transmit or forward inappropriatecontent, such as potentially offensive jokes, images or other materialsdepicting or pertaining to nudity, sex, or a person’s color, race, religion,gender or gender identity, sexual orientation, national origin,citizenship, ethnicity, age, disability, pregnancy, veteran status, geneticinformation, or other legally protected factors.If you receive an email containing inappropriate content, delete itimmediately. Do not forward the content to an internal or external emailaddress. As a further precaution, if the sender is known to you, notifythe sender not to send such items to your business address. If suchmaterial is received from an unknown source, you generally should notcontact the sender, but you should contact an IT support resource oryour supervisor.Tag_Set_B

QA1I use email and instant messaging to conduct business and sometimessend jokes to my friends or coworkers. Is this acceptable?While humor is important to our work and our lives, remember that theemail and instant messaging systems are business communicationtools. Inappropriate jokes or comments that may be offensive to othersdo not belong in the workplace.

Chapter 3.5Electronic Data and System SecurityExpectationsInformation systems and electronic data are vital assets which supportbusiness operations and decision making across the company.Each employee has an important role in the overall security of ourinformation systems and electronic data including: Adhere to your Koch company’s policies and practices related to the security of company information systems and data. Protect passwords and only share them in limited circumstances, with good business justification. Take precautions to protect computer workstations and mobile devices from theft or loss. Ensure appropriate information access controls are applied and periodically reviewed, based on the level of sensitivity and confidentiality of the information. Do not attempt to alter, circumvent or break company information security protections or processes. Ensure the use of any third-party information systems that will exchange, store, process or manage company data undergoes the information technology risk assessment applicable at your Koch company.   Practice safe computing. Have a heightened awareness of the ways in which fraudulent attempts could occur to obtain or gain access to the company’s electronic data. Report any suspected or known system security incidents to one of the many options available to you.Contact your IT support resource if you are unsure how to fulfill theseresponsibilities.Tag_Set_F, Tag_Set_K

QA1I travel on business and need to transport personal data of others, suchas company employees, customers, suppliers, vendors and jobapplicants, on my laptop. What should I do to protect the data?Consider carefully whether you need to store and transport personaldata on any mobile device. If you must do so to perform your jobduties, limit the amount of personal data that you transport and ensurecompany-provided information technology security precautions, suchas encryption, are taken.

QA2What should I do if my mobile device is lost or stolen?The loss or theft of any mobile device, such as a laptop or smartphone,which stores or has the ability to access information relating tocompany business, must be reported to the appropriate resources atyour Koch company.  

Chapter 3.6Use of Non-company-provided TechnologyUse of non-company-provided communication tools for businesspurposes can pose an increased risk for the exposure of companyinformation, loss or theft of information, unauthorized access toinformation and failure to meet requirements for managing companyinformation. You must follow your Koch company’s approval process and anyadditional requirements imposed by your Koch company for the use ofnon-company-provided technology to conduct company business.When approved to use non-company-provided technology, take allappropriate precautions and move business records to an approvedlocation as soon as possible.Tag_Set_C

Chapter 3.7Security and Proper Use of CompanyPropertyIt is the shared responsibility of all employees to protect our people andproperty. In doing so, employees must manage assets with integrityand avoid misuse, fraud, theft, embezzlement or other improper orillegal means of diverting corporate assets. This includes the misuse ofa company-issued credit card or submission of a fraudulentreimbursement request. Report any attempted or actual violations ofaccess or financial controls to one of the many reporting optionsavailable to you.Securing equipment, supplies and materials against theft orunauthorized use can limit losses. Reporting suspicious persons oractivity to your manager, security personnel or your compliance andethics resource can further prevent a security incident. Tag_Set_F