Table of Contents

1. Ethics and code of conduct objectives
2. Ethical Principles
3. Honesty and Integrity
4. Fairness of commercial practices
5. Data confidentiality
6. Professional behaviour
7. Professional skills and added value
8. Social respect
9. Environmental care

• This code allows HP TECHNOLOGIES GROUP LIMITED to share its ethical principles with agents, business partners & third parties.
• The purpose is to raise awareness about ethical values and make sure that business practices are always ethical.
• We ask HP TECHNOLOGIES GROUP LIMITED agents, business partners & third parties to comply with the group's ethical and organisational values and uphold these through their own behaviour and decision-making when working with HP TECHNOLOGIES GROUP LIMITED entities. This document further explains the 7 Ethical Principles shared across with our agents, business partners & third parties. We request your company to apply those principles so that we can do business together.
• Agents, business partners & third parties engaging in unethical or illegal behaviour when making business linked to HP TECHNOLOGIES GROUP LIMITED will be subject to termination. HP TECHNOLOGIES GROUP LIMITED will refer cases to government authorities when appropriate.

• HP TECHNOLOGIES GROUP LIMITED agents, business partners & third parties must adhere to the highest standards of ethical conduct at all times.

1. Honesty and Integrity
2. Fairness of commercial practices
3. Data confidentiality
4. Professional behaviour
5. Professional skills and added value
6. Social respect
7. Environmental care

1. Honesty and Integrity

• Compliance with rules and regulations
• Agents, business partners & third parties must be aware of the rules and regulations applicable and make sure to comply with them. This is to avoid financial penalties or criminal prosecutions and to maintain our reputation.
• It is sometimes a challenge to understand the local laws and how the laws of the United States or Europe may extend to our operations. However, there is no excuse not to comply with them.
• Honesty, Integrity, and Loyalty in the day to day operations and in the means to conduct business
• Beyond simply obeying the law, we also ask each agent, business partners & third parties to conduct business with honesty, integrity, and loyalty. Honesty must be a focus in all our business affairs. Information provided to our business partners or shared by them must always be truthful and never misleading.

• Corruption, bribery, money laundering, embezzlement strictly prohibited
• Any improper payment to gain an advantage in any situation is never acceptable, whatever the context of the geographic area.
• HP TECHNOLOGIES GROUP LIMITED must comply with the FCPA (Foreign Corrupt Practice Act) which highlight the following main rules applicable to all employees and to partners of HP TECHNOLOGIES GROUP LIMITED (including agents, business partners & third parties):
• It is strictly prohibited to authorise, offer or provide anything of value (cash, cash equivalents, gifts, charitable contributions, grants, sponsorship, trips, investments, entertainment, accommodations, commitments to invest in businesses that are unrelated to the agreement with a third party, and anything else of tangible or intangible value) to a Foreign or National Government Official for the purpose of obtaining or retaining business, securing a business advantage, or redirecting business to anyone;
• No cash payments should be made to any Foreign or National Government Official;
• Any payment, gift, or benefit is given to a private person (non-government official), directly or indirectly, must be reasonable and customary, not lavish or excessive;
• Corruption, bribery, money laundering, embezzlement, unlawful or improper means to conduct business, securing improper advantage are strictly prohibited. In case of any doubt on the adequacy of business practice, employees are requested to address the issue to the hierarchy and/or Top Management.
• Further to these rules, the company has a Gifts and Entertainment Policy that provides guidelines to HP TECHNOLOGIES GROUP LIMITED Employees for the business-related gifts and entertainment given or received by our company and those acting on its behalf. In no circumstances, our agents, business partners & third parties must be used to make gifts on behalf of HP TECHNOLOGIES GROUP LIMITED subsidiaries.
• On the other hand, HP TECHNOLOGIES GROUP LIMITED employees are requested not accepting gifts or favours from business partners/ third parties except business meals paid by the business partner (as long as the business partner is present during the meal and that the meals are not frequent), accept invitations to partners seminars or events, except demo products provided without charges by vendors and accept gifts with a value lower than 50 dollars received only once a year and related to a very particular event (end of year chocolates or bottle of wine for example). Our agents, business partners & third parties must never be used to change a gift to something that appears to be a service.
• Declaration of any potential conflict of interests to the hierarchy
• A conflict of interest appears when your personal interest or one of our employees may drive to make a decision that is not in the best interest of the company. It is required to alert HP TECHNOLOGIES GROUP LIMITED in case there is any doubt on a potential conflict of interest or on the potential appearance of a conflict of interest.
• Commercial documents to be made with the highest ethical standards
• It is never acceptable to make any false, inaccurate or misleading commercial documents or business documents. Commercial documents (such as invoices, delivery notes, credit notes, purchase orders…) must be made with the highest ethical standards.
• The products or services sold must be described on the invoices and the description must be in line with the items shipped or the real service rendered by agents, business partners & third parties.
• HP TECHNOLOGIES GROUP LIMITED can sell only items for which the company is a “certified distributor” or has an agreement with the vendor.
• Compliance with Import and Export regulations
• We do have international trading activities that are subject to regulatory restrictions. Specific authorisations from local or US authorities may be requested before importing or exporting goods (tangible or intangible). Agents, business partners or third parties used for importing or exporting products distributed by HP TECHNOLOGIES GROUP LIMITED are responsible for complying with all international trade control laws (ITC) and with any export/import regulations applicable to the transaction.

• No unauthorised disclosure of confidential information
• Agents, business partners & third parties must work safeguarding HP TECHNOLOGIES GROUP LIMITED intellectual property and confidential information that they may receive for business purposes (for example financial results, plans, pricing, customer or supplier information or lists, sales figures, strategic information, any information that is private to our company).

• Awareness of clients and vendors expectations
• We invest in having long term relationships with our clients and vendors. We value those relationships and always want to keep on top of their expectations and to meet all our commitments. Our agents, business partners & third parties are invited to work with the same values.​
• Fraud or any business crime strictly prohibited
• Agents, business partners & third parties commit to doing business with the highest integrity.

• It is our agents, business partners & third parties’ commitment and duty to provide high-quality service and added value.

• Respect of people
• HP TECHNOLOGIES GROUP LIMITED promotes a culture of respect for people in the workplace as well as in the employment process.
• HP TECHNOLOGIES GROUP LIMITED forbids harassment in any form, intimidation or offensive work environment and expects the same from its agents, business partners & third parties.​
• Promotion of cultural differences
• HP TECHNOLOGIES GROUP LIMITED is an international company and one of our strengths is being multinational. We strive to create an international environment and to promote cultural differences.
• No discrimination of any type is acceptable within the organisation.

• The products we are distributing are often subject to recycling laws but beyond those laws, it is important to have the end-users sensitised about their recycling duties so that the impact of the products we distribute on the environment is minimised. Agents, business partners & third parties who are in contact with end-users or re-sellers are highly encouraged to raise awareness with them about environmental care.