Code of Conduct

The Sniffers believes that high business standards, as well as conducting business in an ethical and responsible manner, play a significant role in ensuring our continued growth and success. This Code of Conduct takes into account the latest economic, social and environmental challenges that impact our business. The Sniffers Code of Conduct prescribes the expected moral and ethical standards of conduct for all employees. It governs what we stand for as a company and how every employee and any person that represents The Sniffers engages with customers, colleagues, partners, and the community.

Directors, managers, and employees are expected to adhere to the Code in dealings on behalf of the company. Each of us is responsible for preserving and enhancing our reputation and thereby to contribute to the overall success of The Sniffers.

Bart Wauterickx
CEO The Sniffers

1 Our Ethical Commitment

Laws and Ethical Standards

The Sniffers complies with laws applicable to its business in all countries. We will make any reasonable effort to become familiar with the laws to ensure that all employees are aware of the laws, rules, and regulations. We will not tolerate willful or negligent violations of these laws rules and regulations. The Sniffers will be guided by the principles of the United Nations’ Global Compact[1]. We respect human rights within our sphere of influence.

Transparency

We conduct our business in an open and transparent matter. Transparency and honesty shall be the guiding principles in all our communication activities, internally and externally.

Accounting and Reporting Standards

All business transactions must be reflected accurately in our accounts in accordance with established procedures and auditing standards. We are all responsible for ensuring that the financial reports and submissions we file are complete, accurate, timely and, understandable. In addition, our books and records must reflect accurately and completely all business transactions in which we have engaged. Accounting records will reflect and describe the nature of the underlying transactions. Falsification of asset records or misrepresentation of facts may constitute fraud and can result in civil and criminal liability for both individuals and the company.

Money Laundering

We will comply fully with all anti-money laundering and anti-terrorism laws throughout the world. The Sniffers will conduct business only with reputable customers involved in legitimate business activities, with funds derived from legitimate sources.

2 Our Standards of Working Together

Diversity and Discrimination

We will not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin, or any other characteristic protected under law. The Company has zero tolerance for workplace discrimination and harassment. All employees must be committed to preventing an inhospitable work environment. Each employee is required to contribute to an environment of respect that precludes any kind of harassment. While legal definitions may vary from one location to the next, “harassment” at The Sniffers includes any form of unwelcome conduct towards another person, whether verbal, physical, or visual.

Health Management

Our employees deserve to work in a safe and healthy environment. We are therefore committed to the workplace health and safety regulations expressed in our health and safety policies. We strive to foster the physical and psychological “well-being” of our employees. Our goals are both fewer illnesses and a lower accident rate. We promote health care as a key element of our sustained productivity and the quality of our services. Our health and safety policies, active in all locations throughout the world, include a ban of alcohol and drugs in the workplace. We prohibit any kind of violence and assault at the workplace, including threatening and intimidating behavior.

Company Property

The use of company property, including labor, supplies, IT, equipment, buildings, or other assets for personal benefit is prohibited where not explicitly allowed by agreement. Each employee has a responsibility to safeguard and make proper use of The Sniffers property. Intellectual property is a valuable asset and must be protected from unauthorized use or disclosure. Such property includes trade secrets, confidential information, copyrights, trademarks, logos, but also customer lists, business opportunities, marketing, and sales data, whether owned by The Sniffers or affiliated companies or business partners.

3 Our Business Integrity

Shareholders’ Trust

We recognize the necessity of sound and transparent corporate management to maintain the trust of our shareholders and investors. We are committed to increasing shareholder value.

Business Partnership

We are committed to dialogue and partnership with our business partners in many communities. We share principles of ethical behavior, social engagement, and respect for the environment with our suppliers, subcontractors, agents, and consultants. We will communicate our principles to our business partners and motivate them to adhere to the same standards we do.

We encourage interactive discussion on social media and network activities while exercising caution to not expose The Sniffers’ confidential information or pose risk to The Sniffers’ reputation.

Conflicts of Interest

We require all directors, managers, and employees to maintain high ethical standards in handling conflicts of interest. They should disclose any relationship with persons or firms with whom we do business (‘Business Partners’), which might give rise to a conflict of interest. Such relations include in particular a relationship by blood or marriage or partnership, participation or investment in Business Partners or Shareholders.

Impartiality

Undue commercial, financial or other pressures that would adversely affect employee’s work and/or interfere with the standard procedures in order to obtain a specific outcome, threatens the independence of The Sniffers. This involves influences on quality of work, confidentiality, continuity of information, propriety rights, and so on. This requires prompt reporting by the individuals who experience or are aware of occurrences of undue influence.

Fair Trade

We are committed to engaging in fair and vigorous competition, in compliance with all antitrust and competition laws and regulations globally including export and/or import restrictions.

Fair Competition

We are committed to free enterprise and fair competition. Company business must be conducted solely on the basis of merit and open competition. We will hire suppliers, agents, or other intermediaries only by fair assessment. We are legally bound to make business decisions in the best interests of the company, independent of any understanding or agreement with a competitor. As a result, the company and its employees will avoid any conduct that violates or might appear to violate antitrust laws and competition laws.

Bribery and Corruption

We will deal with all our customers, suppliers, and government agencies in a straightforward manner with honesty and integrity. We are compliant with international anti-bribery standards as stated in anti-bribery laws. We do not give or receive bribes. We value our reputation for conducting business with honesty and integrity. We do not pay bribes in furtherance of our business and do not expect anyone to do so on our behalf. We have a zero-tolerance approach towards bribery. A bribe is anything of value that is offered, promised, given, or received to influence a decision or to gain an improper or unfair advantage.

Gifts and Benefits

Employees are not allowed to solicit services, gifts, or benefits from customers or suppliers that influence or appear to influence the employee’s conduct in representing the company. Gifts and entertainment may be exchanged at a level that does not exceed customary local courtesies extended in accordance with ethical business practices and applicable law. Any gift should not exceed 35€.

Confidentiality and Data Protection

Our employees shall not disclose information that is not known to the general public for personal gain or the benefit of anyone other than the company. Such information includes technical data, financial data, operating data, customer information, memoranda, or other information regarding the company’s business and operational activities, and future plans. Employees will adhere to relevant laws and company regulations with respect to personal data, which require employees to protect personal data of legal and individual natural persons, including employees, shareholders, and customers.

4 Our Social Responsibility

Environment

We are committed to improving our environmental track record through precautionary measures and the use of environment-friendly technology. We regularly assess and monitor our impact on the environment. We strive to support the constant improvement of our environmental performance and the increase of efficiency in our resources. This includes environmental audits and risk management. We want to measure our processes and services against the highest quality standards. National and international environmental standards – such as the ISO 14000 standard series – shall be our guiding principles.

5 Compliance Procedures, Waivers & Changes

Statement of Compliance

All employees must comply with the Code of Conduct. Each employee and any other person representing The Sniffers will be provided with a copy of the Code of Conduct and will be expected to sign an acknowledgment.

Contacts

We recognize that you may need help in understanding company policies, making difficult decisions, or helping the company live up to our Code of Conduct. The most important thing to remember when dealing with any matter that may be caught under the terms and provisions of the Code is that if you have any doubt you should ask for assistance: Consult your manager/supervisor or contact the HR Director.

Reports and Complaints

Should you become aware of a potential issue in compliance with this Code of Conduct, we expect you to turn to the above-mentioned contacts. All reports of a breach in the Code will be kept confidential.

Disciplinary Action for Code Violations

All employees are responsible for fully understanding and complying with the Code of Conduct. In case of non-compliance, the company will take action. Employees who fail to adhere to this Code of Conduct can be subject to appropriate disciplinary action in accordance with the local laws and regulations and the relevant HR policies.

Addendum

United Nations Global Compact

https://www.unglobalcompact.org/what-is-gc/mission/principles

Corporate sustainability starts with a company’s value system and a principled approach to doing business. This means operating in ways that, at a minimum, meet fundamental responsibilities in the areas of human rights, labor, environment, and anti-corruption. Responsible businesses enact the same values and principles wherever they have a presence, and know that good practices in one area do not offset harm in another. By incorporating the Global Compact principles into strategies, policies, and procedures, and establishing a culture of integrity, companies are not only upholding their basic responsibilities to people and planet but also setting the stage for long-term success.

The UN Global Compact’s Ten Principles are derived from:

Human Rights

Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2: make sure that they are not complicit in human rights abuses.

Labour

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labor;

Principle 5: the effective abolition of child labor; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

Principle 7: Businesses should support a precautionary approach to environmental challenges;

Principle 8: undertake initiatives to promote greater environmental responsibility; and

Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

[1] See Addendum