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The Anderson Development Company Code of Conduct states that every employee should act with integrity and responsibility, following the Guidelines described below:

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We will take the initiative in addressing quality, environmental, health, safety, and security issues to preserve the global environment and secure safety as per the Anderson Development Company Sustainability Policy.

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We will supply products and services that meet or exceed the requirements of our customers.

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Anderson Development Managers, Directors and Executives are required to disclose any personal interest they may have on any issue that is being considered by Anderson Development’s Board of Directors. All employees are required to refrain from participating in any activity in which they will profit, directly or indirectly, due to their affiliation in any form with another entity doing business with Anderson Development or which is in competition with Anderson Development.

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Anderson Development expects all employees to use only legitimate practices in commercial operations and in promoting the company’s position on issues before governmental authorities. As stated below, “kickbacks” or “bribes” intended to induce or reward favorable buying decisions and governmental actions are unacceptable and prohibited. Suppliers will be handled on a non-discriminatory basis, without reference to personal relationships, and consistent with federal laws and regulations. No director, officer, or employee shall seek or accept entertainment or gifts exceeding industry standards from suppliers or others with whom the company does business.

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Obeying the law is the foundation on which our ethical standards are built. All employees must respect and obey the laws of the cities, states, and countries in which we operate. Anderson Development holds training sessions to promote compliance with laws and regulations.

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Employees must maintain the confidentiality of confidential information entrusted to them by Anderson Development or its customers, except when disclosure is authorized by the President of the company by executed Non-Disclosure Agreements or required by law or regulation. If there is a question as to the confidentiality of an item of information, it must be referred to senior management for a decision. Any improper disclosure is likely a breach of contract and could lead to liability to the owner of the confidential information as well as serious damage to the company’s reputation. The obligation to preserve confidential information continues even after employment terminates.

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Employees are prohibited from making any false, misleading, or incomplete statements, or providing incomplete or incorrect information to our accountants and auditors in their preparation or audit of Anderson Development’s financial statements. Accounting policy objectives are to standardize the financial reporting to provide adequate internal controls that insure records and reports are in accordance with Generally Accepted Accounting Practices (GAAP).

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We are committed to creating an environment that is diverse and free from discrimination and harassment. We will provide equal opportunity in employment to all employees and applicants for employment. Comments or actions that encourage or create a hostile work environment will not be tolerated.

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Anderson Development Company conducts its business in a way that focuses on the core principles of Compliance, Safety, Sustainability, and Integrity. We expect our business partners to comply in with these same principles. Our business partners include suppliers, distributors, and agents. Anderson Development's Code of Conduct explains these principles and our expectations.

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We expect our business partners to comply with law and regulations when doing business for Anderson Development Company. We expect them to comply with our Code of Conduct. Anderson Development Company may terminate the business relationship if we feel the Code is not being followed.

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Anderson Development Company expects its business partners to conduct business with honesty and with integrity. Our business partners shall not accept or offer bribes of any sorts or engage in any sort of corrupt practice for any business transactions including transactions with an Anderson Development Company employee(s). No employee or supplier is authorized to make an improper payment, including facilitating payments to any employee, official, agent, or instrumentality of any government, commercial entity, or individual in the conduct of our activity or business.

The provision of gifts and entertainment must not be intended to create an improper advantage. Our employees are restricted from receiving gifts or favors which exceed a nominal value or receiving any extravagant or frequent entertainment from individuals, companies or firms who do business, or seek to do business, with us.

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Our business partners will compete fairly and comply with all anti-trust laws. They shall not act in a manner that will restrict competition such as price-fixing.

Our business partners will comply with all trade regulations when providing a product to Anderson Development Company. They will provide all information needed to safely and lawfully import and export products. They understand and manage all trade restrictions or sanctions when applicable.

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If Anderson Development Company provides its business partners with intellectual property or confidential information, this information must not be disclosed or used for any unauthorized purposes. Systems must be put in place to protect any information shared by us.

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We are committed to protecting the personal information of our employees and we expect that our partners adopt adequate safeguards to keep all personal data used pursuant to your agreement with Anderson Development secure, and that you have in place procedures to ensure your activities fully comply with applicable data privacy and data protection laws. No personal information should be disclosed or used for any unauthorized purpose, and appropriate security precautions must be utilized to protect that data.

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There must be no conflicts of interest when doing business with Anderson Development Company and no personal relationships should influence a business decision or transaction. Our business partner must disclose a potential conflict of interest ahead prior to conducting business with us.

Our business partners may not trade in securities of any types using confidential information provided by Anderson Development Company.

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Anderson Development Company resources must be used in according to our instructions and for intended business purposes only.

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Our business partners must keep accurate records on any transactions with Anderson Development Company. These records must be retained in accordance with the applicable laws and are subject to review by Anderson Development Company.

Our business partners must have controls in place to prevent fraud and money laundering. Any potential fraud that may impact us must be reported to us immediately.

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Proper communication is a must when doing business with Anderson Development Company. Clear, factual, timely and open communication is important in developing a strong relationship with us. Our business partners will not disclose any information about us without the proper approval.

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Our business partners must supply a safe work environment for their employees and contractors. Safety rules must be followed when conducting business for Anderson Development Company at all times.

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There must be effective process safety programs in place for researching, manufacturing, and transporting products to or for Anderson Development Company. Safety procedures must be followed.

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Our business partners must comply with all product safety regulations and proper product labelling for the products manufactured and supplied to Anderson Development Company. They must communicate the appropriate product handling requirements and hazards for these products and these products need to comply will all relevant regulations.

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A process must be in place to manage and to learn from any incidents that may happen. Programs must be implemented for reporting incidents and injuries and to prevent from happening again (example: near-miss program).

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Our business partners conduct operations and business practices in a manner consistent with the Fundamental Principles and Rights at Work of the 1998 International Labour Organization (ILO) Declaration, including the elimination of child labor, forced labor and workplace discrimination; and manage activities in a manner that respects human rights and is consistent with the United Nations Guiding Principles on Business and Human Rights in effect as of 2011. Their people are not employed against their will, transported for exploitation, engaged in slavery or servitude, nor deprived of their rights. Children under the age of 16 are not employed.

They do not discriminate in any circumstance such as culture, nationality, race, religion, gender, disability, and others. They treat people with dignity and respect.

Our business partners comply with working hours laws. They compensate for overtime and leave is offered. They respect their employees' rights to freedom of opinion and association including the right to collective bargaining.

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Our business partners comply with all relevant environmental laws and have necessary permits in place to manufacture the products for Anderson Development Company. They have processes in place that use raw materials, energy and other natural resources efficiently. They shall strive to minimize waste, emissions and noise.

Our business partners are committed to working with their communities they operate in and having open communication with them.

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Our business partners have communication channels for employees to raise grievances about violations or potential violations of laws and these principles. These issues will be address in a fair and open way.

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Our business partner's subcontractors who work on behalf of Anderson Development Company will be made aware of these principles in this Code of Conduct and will be responsible for acting in accordance to them.

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