Policies and Control Processes

Our Morgan Code underpins our commitment to our people, our communities, our customers, our suppliers and our shareholders. It defines how we do business and sets out key principles, supported by Group policies, that define how we conduct ourselves. The Morgan Code has four sections covering working safely, working ethically, treating our people fairly and protecting our business. The Morgan Code applies to all employees and, where appropriate, our business partners including agents, joint venture partners and third-party representatives.

Supporting the principles of the Morgan Code are a suite of Group policies, including Bribery Corruption and Facilitation Payments, Competition Law and Anti-Trust, Trade Controls, and Information Security.

Morgan’s ethics and compliance policies are available to employees in multiple languages, together with related manuals and guidelines. These require employees to operate not only in accordance with applicable laws and regulations, but also in line with internal rules and reporting requirements relating to areas such as ethical business behaviour, trade compliance, gifts & entertainment, donations and sponsorships.

Our policies also apply, to the extent appropriate, to Morgan’s business partners including agents, joint ventures and third party representatives. In particular, Morgan’s Supplier Code of Conduct sets out the minimum conduct standards that we expect from our suppliers globally.

All policies, manuals and guidelines are subject to routine review.

Control processes are in place at the site level to ensure the policies are effectively implemented.