Introduction
Impact Health is committed to dealing with all of its stakeholders with the highest ethical standards, integrity and as responsible corporate citizens. The trust and confidence of all our stakeholders, together with our reputation, are among the most valuable assets of the Group. Along with our commitment to competitiveness and performance, we will continue to be led by our values to achieve sustainable success.

Every Impact Health employee is required to make a personal commitment to follow the Company's Code of Conduct, as well as the detailed standards issued in support of it, and uphold our commitment to our values, integrity and corporate responsibility.

Policy
Impact Health requires its companies, and their employees, to observe the highest standards of integrity and honesty and act with due skill, care, diligence and fairness in the conduct of business. To this end, all Impact Health companies, and their employees, are required to comply with the laws of all countries in which they operate and with the high ethical standards detailed by Impact Health in support of this policy.

Compliance
It is the responsibility of management to ensure that Impact Health’s Code of Conduct and standards are communicated, understood and acted upon. They are required to positively promote them by personal example and are not entitled to permit any exceptions to the required behavior.

All employees should familiarize themselves with the Code of Conduct and must comply with it. Failure to act in compliance with the Code will result in appropriate disciplinary action against both the employee committing the breach and others who condone it.

The Standards set out in the code are general and do not address each and every situation that may confront employees in markets around the world. In appropriate cases, guidance on the application of the Code to particular situations should be sought from management.

It is the responsibility of each employee to report promptly any violations of the Code of Conduct of which they become aware. Impact Health assures individual employees who raise issues that they will be protected from any adverse impact on their employment as a result. Impact Health actively encourages employees to raise issues of concern.

Business Practices
Impact Health and its affiliates, and their employees, must comply with the laws of all countries in which they operate, with appropriate international and national industry codes of practice and with the high ethical standards specified by Impact Health.

It is the responsibility of all employees to ensure, by taking advice where appropriate, that they are fully aware of all relevant laws, regulations, practices and codes of practice, particularly as they relate to their job.

Employees should ensure that, within their sphere of business activity, Impact Health and its affiliates carry out their contractual obligations in a proper and timely manner and are not in breach of contract.

Business practice, and what amounts to improper conduct, varies from country to country and from industry to industry. All employees will comply with (a) the high ethical standards specified by Impact Health, (b) Impact Health’s published policies relating to business practices, and (c) any international and national codes of practice applicable to the conduct of business in each environment.

Gifts, entertainment and personal favors may only be offered to a third party if modest in value and if they are consistent with customary business practice. No gifts, entertainment or personal favor may be offered in contravention of any applicable law or code of practice.

No employee should seek or accept a gift, entertainment or personal favor which might reasonably be believed to have any influence on business transactions. An offer of entertainment should not be accepted unless the offer is within the bounds of accepted business hospitality.

Gifts which do not meet the above criteria should be reported to management who shall determine how they shall be dealt with.

Impact Health’s funds will not be used in payments, direct or indirect, to government officials, people participating in government bodies, employees of state organizations or representatives of political parties, for unlawful or improper purposes.

Equal Opportunities
All employees shall be treated with equal respect and dignity and shall be provided with equality of opportunity to develop themselves and their careers.

Impact Health is striving to achieve diversity at all levels of the organization and values the individuality, diversity and creative potential that every employee brings to its business and supports the continuous development of their skills and abilities.

Judgments about people for the purpose of recruitment, development or promotion shall be made solely on the basis of a person's ability and potential in relation to the needs of the job and shall only take account of matters relevant to the performance of that job. Overall, success and advancement within Impact Health shall depend solely on personal ability, behavior and work performance.

In some countries these principles may be modified by national legal requirements for affirmative action.

Personal Harassment
Personal harassment, such as verbal abuse or sexual harassment, of any employee of Impact Health, its suppliers or customers is unacceptable in any form whatsoever.

Any person who believes they have been personally harassed should report the incident and circumstances to their immediate manager or HR manager or other senior manager who will arrange for it to be investigated impartially and confidentially.

Impact Health is fully supportive of the principles set forth in the UN Declaration of Human Rights. These include freedom from torture and arbitrary arrest, the right to a fair trial and equality before the law.

Political Contributions
Any political contributions by Impact Health or its affiliates must be lawful and approved under procedures laid down by the board or governing body of the company concerned.

Approval should not be given to any political contributions by Impact Health and its affiliates which, by their scale or affiliation, might be seen as excessive or inappropriate. Impact Health's accounting procedures require any political contribution must be approved by Impact Health’s Board.

Conflicts of Interest
Employees dealing with Impact Health's business must act in the best interests of Impact Health and must disregard any personal preference or advantage.

Employees should avoid entering into situations in which their personal, family or financial interests may conflict with those of Impact Health. Where any potential conflict of interest may arise, the employee shall declare that interest and seek advice from senior management.

Examples of conflict to be declared and resolved include:

These examples do not extend to normal and proper financial investments in publicly quoted companies.

Property and Resources
Impact Health resources should be kept securely and should only be used for the proper advancement of its business and not for personal gain.

Individuals expending Impact Health resources should recognize that they owe a duty of care to the shareholders of Impact Health, who are its ultimate owners. Commitments and expenditure should only be such as could be justified to shareholders if the facts were known. This includes any expenses claimed and purchases made for which reimbursement is sought.

Impact Health resources include not only tangible assets such as materials, equipment and cash, but also intangible assets such as computer systems, trade secrets and confidential information. Employees should observe global and local guidelines concerning the classifying and handling of documents and electronic data. The storage of personal data in an electronic medium may be governed by laws with which relevant employees should familiarize themselves and comply.

Information generated within Impact Health, including research and development, costs, prices, sales, profits, markets, customers and methods of doing business, is the property of Impact Health and must not, unless legally required, be disclosed outside Impact Health without proper authority.

Policies, Delegated Authorities and Reserved Powers
Impact Health employees are expected to make themselves aware of and comply with the letter and spirit of all Impact Health policies and with the reserved powers and delegated authorities established by the Board from time to time. Copies of these policies shall be made available to employees upon request.

The freedoms which individuals have to carry out their jobs must be exercised within both the letter and spirit of Impact Health policies and procedures, reserved powers and delegated authorities. These are designed to empower people to carry out their responsibilities within a necessary framework of corporate control and legal responsibility but are not so voluminous as to prescribe appropriate action in every circumstance.