* On June 20, 2024, our Board of Directors amended our Code of Business Conduct and Ethics due to changes in international law and guidelines relevant to the company’s international operations and updates to the company’s Anti-Corruption Policy and Guidelines, to clarify certain provisions regarding conflicts of interest, and add references to company policies, including the company’s Regulation FD Policy and Workplace Violence Prevention Plan. The remainder of the changes to the Code are technical, administrative, or non-substantive.
* On June 23, 2022, our Board of Directors amended our Code of Business Conduct and Ethics to designate our General Counsel as our Chief Ethics Officer and to add our Chief Accounting Officer to the list of “Principal Executive and Senior Financial Officers” under the Code. The remainder of the changes to the Code are technical, administrative, or non-substantive.
* On June 17, 2021, our Board of Directors amended our Code of Business Conduct and Ethics to incorporate the company’s new operating subsidiaries, reconcile certain provisions to the company’s Anti-Corruption Policy, and clarify that political contributions or donations using company funds or assets may be made if permitted by all applicable laws and regulations and pre-approved by the company’s general counsel and chief financial officer. The remainder of the changes to the Code are technical, administrative, or non-substantive.
On November 27, 2018, our Board of Directors amended our Code of Business Conduct and Ethics to reconcile a provision in a separate, internal Company policy regarding the limit on nominal gifts that may be received or given to an actual or potential supplier of the Company.
On June 20, 2018, our Board of Directors amended our Code of Business Conduct and Ethics to update the following sections of the code: Gifts and Entertainment, and Interactions with the Government and Military. In addition, various sections of the code were amended to update the name of our “Human & Resources” department to “People & Culture” department.
On June 22, 2017, our Board of Directors amended our Code of Business Conduct and Ethics to update the title of the Ethics Officer within the Human & Resources Department.
On June 23, 2016, our Board of Directors amended our Code of Business Conduct and Ethics to update the following sections of the code: Gifts and Entertainment; FCPA and Anti-Corruption Compliance; Employment Practices and Export Compliance. In addition, various sections of the code were amended to update the persons in the company from whom guidance on a particular issue would be sought.
On March 5, 2016, our Board of Directors amended our Code of Business Conduct and Ethics to include our company policy to comply with all applicable laws and regulations prohibiting human trafficking, forced labor and slavery and that we will not do business knowingly with any supplier who engages in such practices.