PURPOSE AND SCOPE OF THE CODE. The Code guides our daily business conduct. It sets out with clarity the moral principles and values, as well as the internal rules of conduct and ethical behaviour that must be observed by all those who have a working relationship or partnership with Growthfund. Compliance with and adherence to the values, principles, and rules of the Code is a collective responsibility we all share. The Code also sets out guidelines for the Growthfund subsidiaries, which establish and implement independent policies and procedures to comply with their requirements, always in accordance with the principles, values, and rules of this Code. It should also be stressed that the Code is complemented by relevant Company policies, instructions, and procedures. In any case, it is not possible to accurately address all possible situations and behaviours, so we are all obligated show good judgment and avoid what might just seem as inappropriate behaviour. In order to ensure compliance with the Code, all of us, regardless of when we were hired at Growthfund, are required to fully acquaint ourselves with its rules and principles, to train accordingly, and to commit to its adherence by signing the attached Personal Commitment.
