The purpose of this policy is to describe our requirements for conducting business to the highest ethical standards at EUL. Our policy sets out what we expect from every single person that works for us and for the companies and organizations that we partner with. These policies also underline our responsibilities to our people, partners, and shareholders.

Speaking up

We want to enable and encourage our people to feel comfortable reporting any suspected wrongdoing at any level of the business, with business partners, or in our supply chain without fear of reprisal. All concerns raised will be taken seriously and investigated appropriately. Employees can report issues through their line manager, team leaders, or the People team. If this is not possible, employees can ring EUL’s confidential whistleblowing.

Compliance with the law

We operate and function within the applicable laws of the land and respect the rule of law in all of our dealings. We clearly communicate procedures for disciplining those who do not comply with the law or our standards and policies and maintain a system for confidential reporting of breaches of those laws, standards, and policies through line managers and team leaders.

Commitment to human rights

We conduct our business in a manner that respects the human rights and dignity of our people and those we partner with. Each of us can play a role in the elimination of human rights abuses such as child labor, human trafficking, modern slavery, and forced labor. If you believe there may be any breach of human rights taking place in our operations or in those of our business partners then please contact your line manager immediately. For further information please read our Slavery and Human Trafficking Statement

Conflicts of interest

A conflict of interest occurs when personal interests affect your ability to make objective decisions for EUL. Be aware of the many different ways in which conflicts of interest can occur, for example • Outside jobs and affiliations with competitors, customers, or suppliers.

• Working with close relatives, especially those who are government officials.
• Serving as a board member of another organization.

Political activity and donations

As an individual, you have the right to personally participate in the political process, including making personal political contributions. However, you need to make it clear that your personal views and actions are not those of EUL. This includes:

• Not using company funds or resources to support any political candidate or party.
• Obtaining approval before engaging in any lobbying activities.

Gifts and hospitality

We support the reasonable and proportionate giving and receiving of hospitality as part of a normal business relationship. However, we prohibit the giving or receiving of any gifts or hospitality that are excessive or improper. We need to ensure that we are never influenced by, or seek to influence through, the provision of gifts or hospitality. We do not give or receive gifts or hospitality during a tender process.

Bribery and corruption

We take a zero-tolerance approach to bribery and corruption and comply with anti-bribery and corruption laws and regulations. We are committed to implementing and enforcing effective systems to counter bribery and corruption and we encourage our business partners to share our commitment. For more information please read our Anti-bribery and Corruption policy.

Preventing money laundering

Money laundering is the process of hiding illegal funds or making them look as though they are legitimate. It also covers the use of legitimate funds to support crime or terrorism. Always ensure you know who you are doing business with by following our due diligence process for working with partners and suppliers. If you have any concerns please raise these with your line manager or team leader.

Anti-competitive

We believe in fair competition and discourage all forms of anti-competitive practices that could damage our business. Employees should never encourage customers, suppliers, or former employees of competitors to provide confidential information or seek, accept, or discuss confidential information with competitors. Competition and antitrust laws are complex and often very specific, as such if you have concerns please consult your People Manager who can consult the legal team.

Diversity and inclusion

We pursue equality of opportunity and inclusion for all employees through our employment policies and practices. We aim to create an inclusive environment that provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, gender, pregnancy, maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age, or sexual orientation.

Preventing harassment and bullying

EUL will not tolerate harassment or bullying. Harassment and bullying can take many forms and have serious consequences. We must all take responsibility to ensure that such behavior does not happen at EUL. We may instigate disciplinary or legal action against people who harass or bully others. We will treat each other respectfully and challenge any unfair behavior.

Environmental, social, and governance

We believe that a commitment to the principles of environmental, social, and governance (ESG) not only makes good business sense but also complements our business strategy and our corporate values. Our commitment to ESG extends across all our stakeholders from our people to our customers to our communities.

Environmental, social, and governance

We believe that a commitment to the principles of environmental, social, and governance (ESG) not only makes good business sense but also complements our business strategy and our corporate values. Our commitment to ESG extends across all our stakeholders from our people to our customers to our communities. We aim to create an inclusive and supportive environment for our people to flourish and thrive. We take the health, wellbeing, safety, and security of our employees as paramount to our operations, which is why it is one of the five pillars that govern our approach to ESG. This further extends to customers, our partners, and the organizations we work with. We are committed to taking meaningful action to tackle climate change by minimizing our emissions and developing low carbon infrastructure and working to minimize and manage noise, protect air quality, and support the circular economy. For more information please see our ESG Policy

Working in our communities

We aim to be responsible within the local communities that we operate in and work in partnership with our communities at all times. Our aim is to create sustainable, long-term opportunities in our communities to support social and economic development. We set out in our Environment, Social and Governance Framework how we will priorities supporting sustainable communities as one of the five key pillars of our approach to ESG at EUL