Kedge Code of Conduct - Enhancing Life with the Right Decisions

At Kedge, we are committed to doing business the right way.

At Kedge, we are committed to doing business the right way to maintain and enhance our reputation in the marketplace and to continue to earn the trust placed in us by our customers and other stakeholders.

Our Code of Conduct, "Making the Right Decisions," includes our principles, core values, and integrates the high ethical financial standards expected of everyone associated with Kedge.

This code serves to guide us to act in a manner consistent with our company purpose, principles, and core values.

Responsibility and Accountability

We hold everyone associated with Kedge responsible for understanding and abiding by our Code of Conduct and accountable for working with high ethical standards.

When employees are hired, they are required to complete an ethics course and to attest to their commitment to follow the high ethical standards of behavior outlined in our code of conduct.

On an ongoing basis, doing business the right way is reinforced through training and education.

In addition, we are required to disclose any potential or perceived conflicts of interest consistent with our policies and our code of conduct.

Our Principles Guide Us

  • We do the right thing.
  • We take a long-term perspective.
  • We win with talent, culture, and execution.
  • We make and keep promises.

These principles guide our actions and decisions as a company.

Human Rights

Consistent with the UN Human Rights Council's Guiding Principles on Business and Human Rights, Kedge is fully committed to supporting and respecting the protection of internationally proclaimed human rights, and in ensuring the company is not complicit in any abuse of human rights around the globe.

We work to ensure its policies and practices foster a business environment that upholds our high standards of integrity, promoting responsible citizenship globally. Simply put, we are committed to making the right decisions.

These attributes form the basis of our Code of Conduct, and Kedge is committed to promoting respect for human rights by our own actions everywhere we do business.

Anti-bribery and Corruption

The goal of Kedge's anti-bribery and corruption (ABC) compliance risk management program is to ensure that ABC risks are properly identified, assessed, measured, monitored, and reported. The ABC compliance risk management program helps business management be reasonably assured that effective controls and processes are in place to ensure compliance with applicable ABC laws and regulations.

Internal Audit executes its mission by applying a systematic, independent approach to evaluating governance, risk management, and control processes, including periodic, risk-based audits of Kedge's anti-bribery and corruption (ABC) compliance risk management program across our first and second lines of defense globally.

Resources for Reporting Ethical Concerns

Kedge has a number of resources available for those who seek information about or guidance on the code of conduct, or who wish to report a potential violation of standards or policies. This process encourages employees to seek out local management or their local ethics officers, who are located within Kedge's businesses and functional areas. In addition, Kedge's telephone help line and website are available seven days a week, 24 hours a day, and are continually promoted as resources to report or seek guidance on ethical issues.

Compliance Enforcement

Kedge has a compliance infrastructure that is responsible for the coordination, oversight, monitoring, and enforcement of Kedge's policies, compliance programs, and activities. Prudential offers compliance training for employees and management on a variety of topics. Additionally, guidance and support are provided from the compliance teams within the businesses. If a Kedge employee fails to comply with applicable laws, rules, regulations, standards, policies, and procedures, he or she could be subject to disciplinary action, up to and including termination of employment.

Transparency

Kedge is committed to operating openly, and we believe the best way to address concerns and questions about how we do business is to continually communicate our principles and core values to our employees and to demonstrate integrity in all aspects of conducting business.