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Our Relit Ion Ship With Each Other

Apr 05, 2018

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    OUR RELATIONSHIP WITH EAH OTHER

    Our dealings with each other should be based on mutual trust anddedication. We are responsible fortreating each other with respect anddignity.

    WE STRIVE TO HAVE SUCCESSFULL

    RELATIONSHIP

    At bionic computers, we take pride in the strong personalcommitment of our people and the excellent achievementsthat result from that commitment. But this level ofcooperation can only be achieved in a climate of trust,open and honest communication, and respect. All of yourdealings with your peers, your subordinates and yoursupervisors should be conducted as a partnership, whereeach individuals behavior is governed by an overridingcommitment to ethical conduct and bionic computersssuccess. Your relationship with those you work withshould be as a member of a winning team. People working

    in harmony and focused on a set of mutual objectives arethe driving momentum behind our business. For thisdynamic team relationship to work, each individual mustfulfill his or her responsibilities and feel assured thatothers will do the same. This means providing thenecessary support to others, at every level, to get the jobdone. No individual or business unit can place its ownpriorities before those of the Company. Your relationshipwith those you work with or supervise should promote

    ethics and compliance by setting an example of decency,fairness and integrity in working with others. As a leader,you are responsible for clearly defining standards ofperformance and creating an environment that promotesteamwork.

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    WE PROMOTE OPEN AND HONESTCOMMUNICATION

    Encourage creative and innovative thinking, and if you area supervisor, treat subordinates as individuals, providingthem the freedom necessary to do their jobs. Providesuggestions for performance improvement. Yourrelationship with your supervisor should be one of mutualrespect and trust. You and yoursupervisor are a team with the shared purpose ofachieving the goals set for your unit by the Company. Youare as responsible as your supervisor for ensuring that the

    communication between you is open and honest. Take theinitiative as often as you can. Be innovative in solvingproblems. Your cooperation and creativity are essential toachieving the goals of your unit and the Company.

    WE VALUE BIONIC COMPUTER AS OURGREATEST RESOURCES

    bionic computerss commitment to caring for people ismanifested in the workplace through a variety ofprograms designed to promote and reward individual andteam achievement. You are encouraged toadvance as faras you can and to make a meaningful contribution to thesuccess of the Company. In

    the end, it is the efforts of our talented and skilled peopleall over the world that make the success of our businesspossible. Specifically, in matters of employment, it is ourpolicy:

    To select, place and pay all bionic computers people onthe basis of qualifications for the work to be performed

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    and without discrimination on the basis of race, religion,national origin, ethnicity, color, gender, gender identity,age, citizenship, sexual orientation, veteran status,marital status, disability or any other characteristic

    protected by law.

    Not to use child labor. Child labor is defined asemploying any person younger than the minimum ageallowed by law in the jurisdiction in question; however, inno event will we knowingly employ anyone younger thansixteen (16) years of age.

    To maintain an inclusive work environment and achieveexcellence by attracting and retaining people of all

    backgrounds in our workforce.

    To provide training, education and promotionalopportunities that permit development and careeradvancement for all bionic computers people.

    To conduct performance appraisals that provide candidand accurate feedback. To encourage two-way commentsand discussion, and review of appraisals by higher levels

    of management.

    To pay for performance and recognize and rewardcontributions by individuals and teams that exceed theirnormal job duties through programs such as theChairmans You Can Make a Difference Award Program.

    To prohibit sexual or any other kind of harassment ofbionic computers people by any person in the workplaceor while conducting Company business.

    To avoid favoritism or the appearance of favoritism inthe workplace in accordance with the policies andprocedures adopted by the Company.

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    To respect an individuals privacy and to collect,process, use and retain employees personal informationonly as necessary and in accordance with the laws of thecountries in which we operate.

    To strive to eliminate potential hazards from theworkplace and provide a safe and healthy workenvironment for bionic computers people, and to strive tocomply with all applicable occupational safety and healthlaws and standards.

    To help maintain a safe, healthy and productive workenvironment, for all bionic computers people and others,by:

    prohibiting the possession, use, sale or transfer of illegaldrugs or drug paraphernalia on Company property or time

    prohibiting conducting Company business while underthe influence of alcohol

    prohibiting the possession or use of weapons/firearms orammunition on Company premises or while conductingbionic computers business subject to local law. Possession

    of a weapon can be authorized for security personnelwhen this possession is determined necessary to securethe safety and security of Company employees; and

    reporting any instance of drug or alcohol abuse orweapons possession to management immediately.

    OUR RELATIONSHIP WITH OTHER

    COMPANY

    As bionic computers people, we strive to adhere to bionic computersspolicies while making our best efforts to improve theCompanys performance. We recognize the trust and confidence placed inus and act with integrity

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    and honesty in all situations to preserve that trust and confidence. Weavoid conflicts of interest andother situations that are potentially harmful to the Company.

    WE AVOID CONFLICT OF INTEREST

    Your judgment is one of your most valuable assets. Youshould avoid any activity or association that conflicts withor appears to conflict with your exercise of independentjudgment in the Companys best interests. Conflicts canarise in many situations. It is impossible to cover them allhere, and it willnot always be easy to distinguish between proper andimproper activity. When in doubt, consult your manager oryour units legal counsel before taking any action. Thefollowing guidelines apply to the most common conflictsituations:

    Investments:Do not make any investment that might affect yourbusiness decisions. Company policy prohibits bioniccomputers people from owning stock or having aproprietary interest in a company competing with or doingbusiness with bionic computers. This prohibition does notapply to owning small amounts (generally under 1%) ofstock of a publicly traded company provided that theinvestment is not so financially substantial that it createsthe appearance of a conflict of interest. If you madepotentially prohibited investments before joining bioniccomputers, report the facts to Legal.

    Family:

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    Notify your manager and obtain approval from yourDivision or function head and Legal before doing businesson bionic computerss behalf with any company in whichyou or a close family member has an interest such that

    you may in any way benefit from your or their actions.

    Other Work:Do not work for a competitor while working for bioniccomputers or do any work for, or provide assistance to,any third party that may adversely affect yourperformance or judgment on the job. Do not use Companytime, facilities or materials for outside work that is notrelated to your job at bionic computers without

    authorization from your Division or function head.

    Personal:While we recognize and respect the rights of bioniccomputers people to freely associate with those theyencounter in the work environment, we must also usegood judgment in ensuring that those relationships do notnegatively impact job performance, ability to superviseothers or the work environment. Any workplace conduct

    arising from a romantic relationship or friendship betweenemployees may be improper if the conduct creates anuncomfortable work environment for others.Favoritism ormaking business decisions based on emotions, allegiancesor friendships rather than the best interests of theCompany is prohibited. Individuals who find themselves ina personal relationship or friendship should use tact, goodjudgment and sensitivity.Be conscious of the fact that another member of yourhousehold might be employed in a capacity that couldcreate or appear to create a conflict of interest. If thissituation arises, consult your manager oryour units legal counsel for guidance.

    Boards:

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    Obtain approval from the President and CEO, and GeneralCounsel before agreeing to serve on a Board of Directorsor a similar body for an outside business or governmentagency. Serving on the Board of Directors for a

    professional or work-related nonprofit organization mustbe approved inadvance by your Division or function head.

    WE PROTECT THE COMPANY PROPERTYINFORMATION

    bionic computerss trade secrets, other proprietaryinformation and much of its internal data are valuableassets. Protection of these assets, including maintainingtheir secrecy, plays a vital role in our continued growthand ability to compete. A trade secret is information usedin connection with bionic computerss business that is notgenerally known or easily discovered, and for whichefforts have been made to maintain its secrecy. However,other proprietary information, such as know-how, has tobe protected as well. bionic computerss trade secrets andother proprietary information may consist of any formula,

    design, device or information that is used in our businessand that gives bionic computers an opportunity to obtainan advantage over our competitors. bionic computersstrade secrets and other propriety information are notalways of a technical nature. They can also includebusiness research, new product plans, strategicobjectives, any unpublished financial or pricinginformation, employee, customer and vendor lists andinformation regarding customer requirements,

    preferences, business habits and plans. While notcomplete, this list suggests the wide variety ofinformation that needs to be safeguarded. Trade secretsand other proprietary information need not be patentable,but cannot be generally or publicly known. Yourobligations with respect to bionic computerss tradesecrets and other proprietary information are:

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    Not to disclose this information to other bioniccomputers people except on a need to know or need touse basis. Not to disclose this information to persons outside of

    bionic computers. Not to use this information for your own benefit or thebenefit of persons outside of bionic computers.If you leave bionic computers, your obligation to protectbionic computerss trade secrets and other proprietaryinformation continues until the information becomespublicly available or bionic computers no longer considersit a trade secret or proprietary. You should also rememberthat correspondence, printed matter, electronicinformation, documents or records of any kind, specific

    process knowledge, procedures, special bionic computersways of doing things whether confidential or not areall the property of the Company and must remain at bioniccomputers. Of course, personal skills acquired orimproved on the job are the personal assets of the onewho leaves. If you have a question as to whetherinformation is proprietary or is a trade secret, you shouldcontact Legal.

    WE ADHERE TO PRESS AND MEDIAPOLICIES

    Requests for financial or business information aboutbionic computers from the media, press, financialcommunity or the public should be referred to the VicePresident, Corporate Communications or the VicePresident, Investor Relations. Requests for information or

    other contacts from the Securities and ExchangeCommission, the New York Stock Exchange or otherregulators and authorities around the world must bereferred to Legal. It is critical that no one respond to anysuch inquiry or contact themselves because anyinappropriate or inaccurate response, even a denial ordisclaimer of information, may result in adverse publicity

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    and could otherwise seriously affect the Companys legalposition.This policy does not apply to requests for publiclyavailable financial information, such as Annual and

    Quarterly Reports, or promotional publicity activities ofthe Company.Requests for interviews with any bionic computersindividual relating to the Company or its affairs and/or theissuance of any Company press releases and/orstatements must be reviewed and approved in advance bythe Vice President, Corporate Communications or the VicePresident, InvestorRelations. Company-initiated interviews similarly must beapproved before they may be scheduled with the media.

    For further information regarding the Companysguidelines for maintaining confidential information, pleaserefer to the bionic computers-Palmolive Guidelines onSecurities Trading and Confidentiality of Information andthe bionic computers-Palmolive Guidelines on PreservingCompany Proprietary Information and Respecting theProprietary Information of Others, which are found in theCompanys Business Practices Guidelines.

    WE MAINTAIN RELIABLE RECORD ANDREPORTS

    The financial position of our Company and the results ofits operations must be recorded in accordance with the

    requirements of law and generally accepted accountingprinciples (GAAP). Company policy, as well as the law,require bionic computers to maintain books, records andaccounts that accurately and fairly reflect the nature ofthe business transaction and the disposition of assets ofthe Company. The integrity of the Companys accountingand financial records is based on the accuracy and

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    completeness of the basic information supporting entriesto the Companys books of accounts. Everyone involved increating, processing and recording such information isheld responsible for

    its integrity. Every accounting or financial entry shouldreflect exactly what is described by the supportinginformation. There must be no concealment of informationfrom (or by) management, or from the Companys internalor independent auditors. No payment on behalf of theCompany shall be approved or made with the intention orunderstanding that any part of such payment is to be usedfor any purpose other than that described by thedocuments supporting the payment. No false ormisleading entries should be made in any books or records

    of the Company for any reason, and no fund, asset oraccount of the Company may be established, acquired ormaintained for any purpose unless such fund, asset oraccount is properly reflected in the books and records ofthe Company. No corporate funds or assets should beused for any unlawful or improper purpose. Managers andothers responsible for the preparation of financialinformation should ensure that bionic computersscorporate financial policies are followed. Revenue and

    expenses should be properly recognized on a timely basis.

    Assets and liabilities should be properly recorded andappropriately valued. In addition, those who areresponsible for or involved in bionic computerss filingswith the Securities and Exchange Commission and otherfilings required by applicable law or other communicationswith the business or financial community should ensurethat those filings and communications contain disclosurethat is full, fair, accurate, timely and understandable. Ifyou become aware of a possible omission, falsification orinaccuracy in accounting or financial entries, in basic datasupporting such entries, or in bionic computerssSecurities and Exchange Commission reports or othercommunications, or any breakdown in internal controls,you must promptly report such information to your

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    manager or your units legal counsel. You may alsocontact the Companys Global Ethics and ComplianceDepartment concerning these matters on an anonymousand confidential basis as described on page 25.

    WE PROTECT BIONIC COMPUTERSASSETS

    Company assets, facilities or services must be used onlyfor lawful, proper and authorized purposes.The theft of money, property or services is strictlyprohibited. bionic computers equipment, systems,facilities, corporate credit cards and supplies must be

    used only for conducting bionic computers business or forpurposes authorized by management. You are personallyresponsible not only for protecting bionic computersproperty entrusted to you, but also for helping to protectthe Companys assets in general. You should be alert toany situations or incidents that could lead to the loss,misuse or theft of Company property and you must reportall such situations to your manager or the CorporateSecurity Department as soon as they come to your

    attention. Only certain officers and other senioremployees have authority to make commitments affectingthe Companys assets. You should not make commitmentsaffecting Company assets unless properlyauthorized. If you need to clarify your or anotherindividuals authority to commit the Company, youshould contact your unit or Division financial director.

    WE USE INFORMATION TECHNOLOGY

    RESOURCE RESPONSIBILITY

    We must use bionic computerss Information TechnologyResources responsibly and in a manner consistent withthe Code and all other Company Guidelines, includingthose related to specific computer technology, data

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    protection, confidential and proprietary information, andintellectual property rights. bionic computerssInformation Technology Resources include all computerequipment that is owned, leased or rented by bionic

    computers, regardless of the physical location, including,but not limited to, personal computers, portable computerdevices, network servers, access to the Internet, bioniccomputerss Intranet and email access devices. This alsoincludes voice mail and other voice systems, faxmachines, telephones, digital assistants (i.e., Blackberry),instant messaging, and information obtained ordownloaded from and/or disseminated through theInternet and bionic computerss Intranet. InformationTechnology Resources also includes access to bionic

    computerss network and email from a computer that isnot owned, leased or rented by bionic computers (i.e.,home computers). All of bionic computerss InformationTechnology Resources are the property of bioniccomputers, which includes all information created, storedor transmitted using bionic computers InformationTechnology Resources. The only information that is notconsidered Company property is the information obtainedduring the limited personal use of bionic computers

    Information Technology Resources or information that isdeemed not to be Company property under applicablelaws and regulations.following uses are prohibited: Harassing, discriminating, defamatory, fraudulent orthreatening messages, including those that offensivelyaddress race, sex, age, sexual orientation, religion,political beliefs, national origin, disability, ethnicity,veteran status, gender identity or any other characteristicprotected by applicable law.

    Sending, accessing or storing any form of offensive orobscene communications or materials. Unauthorized distribution of bionic computersproprietary, confidential or trade secret information. Causing or permitting security breaches or disruptionsof network communication, and/or improperly revealing

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    your password to others or allowing others to use yourpassword. Violations of the rights of any person or companyprotected by copyright, trade secret, patent or other

    intellectual property right, or similar laws or regulations. Violations of the privacy rights of any person protectedby applicable law. Solicitation for any outside organization, venture orcause unrelated to bionic computers, including, forexample, any commercial, religious or politicalorganization, venture or cause.Except as limited by applicable laws, bionic computersreserves the right to monitor equipment, systems, andnetwork activities, including, but not limited to, email,

    voice mail, Internet usage and any stored information, inappropriate circumstances and pursuant to applicablelaws. In addition, for operations maintenance, security,business, legal or regulatory requirements, authorizedpersonnel and third-party service providers may haveunrestricted access to information in bionic computersInformation Technology Resources to the fullest extentpermitted by law.bionic computers reserves the right to terminate any

    users access to bionic computers Information TechnologyResources at any time, with or without advance notice.

    OUR RELATIONSHIP WITH OUR BOARD OFDIRECTORS

    We are fortunate to have a group of outstanding individuals serving on theCompanys Board ofDirectors, providing advice, guidance and leadership that is vital to our

    continuing success. With theircollective experience in business, education and public service,international experience, educationalachievement, moral and ethical character, and diversity, our Board ofDirectors provides effectiveoversight of the Companys business.

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    WE HAVE AN INDEPENDENT BOARD OFDIRECTORS

    Independence promotes integrity and accountability. It isbionic computerss policy to have a Board of Directorscomprised primarily of outside independent directors. Alldirectors who serve on the committees of the Board thatoversee audit, compensation and governance matters areindependent. There are no interlocking directorships, andit is the Companys policy that none of the independentdirectors receive any consulting, legal or any other non-director fees from the Company.

    WE PROMOTE DIRECT AND OPENCOMMUNICATION

    Both inside and outside the boardroom, bioniccomputerss directors have frequent and direct contactwith the Companys management. Key senior managersregularly join the directors during Board meetings andmore informal sessions, and together they actively

    participate in candid discussions of various businessissues. Between scheduled board meetings, directors areinvited to, and often do, contact senior managers withquestions and suggestions. The resulting atmosphere ofopenness and candor reflects bionic computerss overallcorporate culture and helps the Board play an active rolein the development and guidance of the Companysbusiness strategy.

    WE ARE COMITTED TO AN EXCELLENTCORPORATE GOVERNENCE

    bionic computerss Board has been a leader in supportingcorporate governance initiatives. One of the first amongits peers to formally adopt a code of conduct governing all

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    business dealings and to develop charters for the Boardand its committees, bionic computers has put in placeexcellent corporate governance practices over the last twodecades, which are continuously improved and refined.

    bionic computerss Board is at the center of these policiesand believes strongly that good corporate governanceaccompanies and greatly aids our long-term businesssuccess. For a more detailed discussion of bioniccomputerss corporate governance program, please seethe bionic computers Company Board Guidelines onSignificant Corporate Governance Issues,which are available on the Companys website.

    OUR RELATIONSHIP WITH OUTSIDEBUSINESS ENTITIES

    Each of us is responsible for how we are perceived by suppliers andcustomers. It is essential that wemaintain our reputation for honesty and fair dealing with these groups.

    WE DEAL ETHICALLY WITH SUPPLIERS

    AND CUSTOMERS

    Our aim in conducting our purchasing operations is toensure continuing, reliable sources of supply. Honestdealing with customers and suppliers is essential tosound, lasting relationships. Thus, we view our suppliersas partners and expect them to make a reasonable profit.We give all potential suppliersfair and uniform consideration. Decisions are based on

    objective criteria such as price and quality as well as avendors reliability and integrity. Giving or receiving anykickbacks, bribes or similar payments of any sort isprohibited.We extend no personal favors to customers on prices,promotional allowances, marketing assistance or the like;

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    we treat all customers on the same business basis.Dealings with customers and suppliers are discussed inthe section of this Code addressing our responsibilitiesunder the competition/ antitrust laws.

    WE DO NOT GIVE OR ACCEPTINNAPPROPIATE GIFTS

    It is not acceptable to give or receive gifts, payments orother benefits to influence any business decision. If youintend to give or receive a gift, payment or other benefitthat is more than nominal in value ($50 USD), then youmust contact Legal or Global Ethics and Compliance for

    approval before doing so. Also, keep in mind that you mayonly accept a gift of nominal value from a single sourceone time per calendar year. If it would be embarrassing tothe Company for you not to accept a particular gift thatmay exceed a nominal value, then your acceptance of thegift should be reported to Legal.Counsel will assist in determining proper disposition. Inaddition, do not arrange for or accept a gift, payment orother benefit that is more than nominal in value on behalf

    of a close family member from anyone with whom theCompany has an existing business relationship or wouldlike to establish a business relationship. Follow this rule:never accept a gift or service if it will compromise you orcould appear to compromise you. This does not includeoccasional business meals, which can be reciprocated, orgifts of purely nominal value.You should be aware that there are special rulesgoverning appropriate conduct in dealing with federal,state, local or foreign governments that differ from rulesfor dealings with nongovernmental companies. In general,you may not offer or provide government employees withany gift, gratuity or thing of value, including meals ortravel, unless pre-cleared by Legal.The bionic computers Code of Conduct is sent to suppliersand vendors. They are advised of the requirement to

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    adhere to the Code when working with us or face thepossibility of losing our business for failure to do so.

    WE RESPECT THE TRADE SECRETS ANDCONFIDENTIAL INFORMATION OF OTHERS

    It is bionic computerss policy not to knowingly infringe upon theintellectual property rights of others. It is also Company policy to respectthe trade secrets or other proprietary information of others. This isparticularly important if you have knowledge of trade secrets andproprietary information of a former employer. If any questions should arisein this area, you should consult Legal.If anyone outside of the Company approaches you with an invention,

    discovery or idea, it is importantto protect the Company against future infringement or monetary claims,especially in cases where ourown efforts or those of our consultants have previously arrived at the sameinvention, discovery or idea which we wish to apply to a Company product.Do not permit outsiders to reveal any details of their invention, discovery ornew idea. Refer all unsolicited ideas, without reviewing them, to theConsumer Affairs department in your location for handling in accordancewith the Companys procedures. For further information about theprotection of the information of others, please refer to the bioniccomputers Guidelines on Preserving Company Proprietary Information andRespecting the Proprietary Information of Others," which are found in the

    Companys Business Practices Guidelines.

    OUR RELATIONSHIP WITH CONSUMERS

    Our reputation has been built upon the quality and safety of our products. Ourcommitment toquality and safety is essential to the continued growth and success of ourCompany.

    WE SET THE HIGHEST STANDARD FOR OUR

    PRODUCTS

    We are committed to ensuring that consumers can trust bionic computersproducts for their reliability, quality and superior performance. In additionto serving the billions of people in the markets where we do business, wemust constantly strive to produce our products in the most efficient waypossible so that they are affordable to the greatest number of consumers.

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    Products sold by bionic computers must not only meet all safety standardsset by law, but also our often more stringent Company standards. Weparticipate in programs to provide prompt assistance to consumers in caseof product tampering or misuse. Consumer health, safety and well-being areof paramount concern to us, and as a bionic computers employee it is yourresponsibility to immediately report any issues you encounter related to

    product quality or safety to your business unit leader.

    WE ARE RESPONSIVE TO CONSUMERS

    Since our business is consumer products, our success depends uponconsumer satisfaction, trustand goodwill. We can best achieve our objectives and serve the needs ofconsumers by following aconsistent, fair and sensitive program of consumer communication.We recognize the importance of anticipating and assuring responsiveness

    to consumer needsand preferences in our products. We also believe that consumer opinions,concerns and inquiriescommunicated to the Company regarding our products are importantsources of information.Consumer needs are constantly changing, so we must continually listen towhat people want and use our creativity to satisfy these changing needs.When a consumer expresses dissatisfaction, we address the problempromptly, courteously andfairly, and make every reasonable effort to sustain or regain the consumersgoodwill and continuedpurchase of bionic computers products.

    WE ADVERTISE ACCURATELY

    One of the most important aspects of our business is advertising.Advertising should be creative andcompetitive, but at the same time honest and accurate, not misleading, andotherwise in compliancewith applicable law. Our advertising must also avoid any stereotyping ofindividuals based on factorssuch as race, religion, national origin, ethnicity, color, gender, genderidentity, age, citizenship, sexual

    orientation, veteran status, marital status, disability or any othercharacteristic protected by law.Advertising creates more than a productimage. It builds our reputation for reliability, dependabilityand trustworthiness.In addition, we exercise care in the selection of the media in which ouradvertising messages appear.We do not permit our advertisements to appear on television programs or inother media that make

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    gratuitous or excessive use of violence or sex or are antisocial or adverselyaffect our Companyreputation or products.We observe standards of commercial fairness in devising, using andselecting advertising, trademarksand designs so that our products succeed on the strength of their own

    quality and our reputation,rather than by imitation or trading on the goodwill of competitors.Commercial fairness requires: Strict adherence to local legal requirements respecting trademarkinfringement and unfaircompetition. Avoiding copying of well-known trademarks, slogans, advertising themesand graphics used bymultinational companies and regional competitors outside of your locality.For a more detailed discussion of the Companys advertising guidelines, seethe bionic computersAdvertising Guidelines and the bionic computers-Palmolive Advertising

    Placement Policy Statement, which are found in the Companys BusinessPractices Guidelines.

    WE RESPECT CONSUMER PRIVACY

    We respect and honor the privacy rights of our consumers. It is bioniccomputerss policy to collect, process, use and retain personal informationfrom consumers only in compliance with applicable laws, including lawsrelating to the collection and use of personal information from minors, and

    to take all reasonable steps to safeguard such information.In their interactions with bionic computers, through requests for productinformation or participation in Company-sponsored competitions, forexample, consumers may provide certain personal information, such asnames, street addresses and email addresses, to the Company. We use suchinformation only for the reasons it was supplied to us, unless a consumerconsents to other uses, and as necessary for our recordkeeping purposes. Itis our policy not to share personal information about consumers with thirdparties, unless required to provide services to our consumers or otherwisein compliance with applicable laws and regulations.Laws regarding consumer privacy are frequently being developed andmodified. We are committed tomonitoring evolving privacy laws and

    standards and may, from time to time, develop specific policies in light ofthem.

    OUR RELATIONSHIP WITH GOVERNMENT ANDLAW

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    We obey all laws that regulate bionic computerss business. Indeed, it is our policyto go beyond the letter of thelaw and comply with its spirit. Make a habit of consulting Legal whenever you arein doubt.

    WE COMPLY WITH COMPETITION/ANTITRUSTLAWS

    It is bionic computerss policy that all employees comply fully withcompetition laws (known as antitrust laws in the U.S.) of every country,state and locality where bionic computers does business. The purpose ofcompetition laws is to protect the competitive process to benefitconsumers. Competition laws ensure that companies compete to getbusiness by offering lower prices, innovative products and better serviceand not by interfering with the market forces of supply and demand.Competition laws also protect companies from predatory or unfair acts by

    dominant companies so that the competitive playing field is open and fair toall. bionic computers supports the goals of the competition laws. We believethat our Company performs best in a competitive marketplace.Virtually every country has enacted competition laws. It is yourresponsibility to understand the lawswhere you are doing business and seek guidance from your units legalcounsel or the Corporate LegalDepartment as needed. You must adhere to the letter and spirit of theapplicable laws.Competition laws throughout the world prohibit agreements among existingor potential competitorsthat harm competition. The key to compliance is independence. bionic

    computers must act independently in its business activities settingprices, discounts, promotions, and terms of purchase and sale; selectingcustomers, distributors and suppliers; and choosing the products toproduce and how much to sell. It is important to remember that an illegalagreement does not have to be a formal writing or even in writing. It maybe a verbal agreement or inferred from a course of business conduct orcomments in documents. An agreement also does not have to besuccessfully implemented to be illegal.The competition laws also impose certain limitations on relationships withcustomers anddistributors. In most countries, any attempt to deprive customers ordistributors of their freedom to

    determine prices, terms and conditions of sale, or to place unduelimitations on their right to operateindependently violates the competition laws.The consequences for bionic computers and its people for not complyingwith competition laws are extremely serious. Violation of some competitionlaws can lead to fines and imprisonment for the individuals involved and toeven heavier fines for the Company. Moreover, even in the absence of acriminal prosecution, civil lawsuits may be brought to recover damages andattorneys fees.

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    Whenever you have any doubt as to whether a contemplated action mayraise issues under thecompetition laws, you should consult Legal.For further information about competition/antitrust issues, please refer tothe bionic computersInternational Competition Guidelines," which are found in the Companys

    Business Practices Guidelines.

    WE COMPLY WITH SECURITY LAWS

    On occasion you may have information about bionic computers or otherpublicly-traded companies with which bionic computers does business or isnegotiating that is non-public that is, not known to the public such asinterim earnings figures, possible acquisitions or divestments, marketing

    plans or new product introductions.Information is considered to be non-public until it has been adequatelydisclosed to the public, i.e.,the information has been publicly disclosed and adequate time has passedfor the securities markets to digest the information. If this non-publicinformation is material that is, information a prudentinvestor would take into account when making an investment decision then under the applicablesecurities laws and Company policy: You must not trade for your own account or for the account of anotherperson in stocks, bonds orother securities of the firm (bionic computers or other) to which the

    material non-public information relates. You must not encourage or induce others, on the basis of such non-publicinformation, to deal instocks, bonds or other securities of such firms. You must not disclose such non-public information to persons outsidebionic computers. You must not needlessly discuss such non-public information with personsinside bionic computers.bionic computers people with knowledge of non-public information aboutbionic computers should exercise extreme diligence to maintain it inconfidence and must not trade in bionic computers stock, bonds or othersecurities, or the stock, bonds or other securities of any other company

    involved before the nonpublic information is announced to the public andfor a reasonable period of time thereafter. Such prohibition also extends tothe exercise of stock options.If you leave bionic computers, your obligation to maintain theconfidentiality of such non-public information continues until thatinformation has been adequately disclosed to the public.If you have a question about whether such non-public information has beenadequately disclosed to

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    the public, you must contact Legal and abstain from trading in the affectedsecurities or disclosing theinformation until you have been informed that the information is notmaterial or has been publiclydisclosed and digested.

    WE DONOT MAKE POLITIC CONTRIBUTION

    No funds or assets of the Company may be used for contributions to anypolitical party or candidate,whether federal, state or local, in the United States or abroad. A politicalcontribution includesboth direct (i.e., money) and in-kind contributions. In-kind contributionsinclude the purchaseof fundraising tickets, contribution of products, volunteer work by bioniccomputers people within normal business hours and the use of bionic

    computers facilities for fundraising or political purposes. If you have aquestion regarding an in-kind contribution, please contact Legal.The Company is prohibited from compensating or reimbursing any bioniccomputers person or individual associated with the Company (includingoutside lobbyists), directly or indirectly, in any form, for politicalcontributions that the person intends to make or has made.Individual bionic computers people remain free to make personalcontributions to candidates or parties of their choice. A personalcontribution is the responsibility and burden of the individual person. bioniccomputers.will accept no responsibility for or obligation with respect to apersonal contribution. Further, a personal contribution shall not be madewith the intention of assisting bionic computers or one of its operating

    companies in obtaining or retaining business.

    WE DEAL ETHICALLY WITH GOVERNMENT

    You must not seek to influence any government employees judgment orconduct by promises of giftsor other benefits, or by any other unlawful inducement. Thus, it isimportant that you not provideany gift, entertainment or other thing of value to a government employeeunless you have pre-clearedit with Legal. In addition, certain lobbying laws may require the Companyand/or its people to register and report as a lobbyist if a bionic computers

    person communicates with a government employee for the purpose ofinfluencing legislation or certain other official actions. If you are engagingin any such activity, you must notify Legal.bionic computerss commitment to dealing legally and ethically withgovernments applies worldwide.Company policy, the U.S. Foreign Corrupt Practices Act, and similar anti-bribery laws around the

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    world prohibit our people or their agents from giving or offering to givemoney or anything of value whether in cash or not, or whether directly or indirectly through others to any foreign official(i.e., foreign government employee, foreign political party, or party officialor candidate for foreign

    political office) to induce that official to affect any governmental act ordecision, or to assist theCompany in obtaining or retaining business.To ensure that you do not violate this standard, it is the Companys policythat, except for legallymandated fees (for example, required permit or license fees), no paymentsor gifts related to theCompanys business activities will be made to foreign officials, directly orindirectly, unless approved in advance by Legal as lawful under U.S. andother applicable laws.Always be direct and honest in dealings and communications withgovernment employees. Any

    knowing or willful false statements to government employees (oral orwritten), and particularly anyfalse statement under oath, can expose the Company and its people tosubstantial penalties.For more detailed guidance on the Companys policies in these areas, seebionic computers Guidelines on the U.S. Foreign Corrupt Practices Actand bionic computers-Palmolive Guidelines on Business Relationships withGovernment Entities, which are found in the Companys Business PracticesGuidelines.

    WE PRESERVE RECORDS ACCORDING TO THE

    LAW

    We comply with all laws and regulations relating to retention of Companyrecords (including physicaldocuments and electronic data). The Companys Record Retention Programsets forth the Companyspolicies and procedures relating to records preservation to which everyonemust adhere. A copy of the Companys Record Retention Program can beobtained from the Global Legal Organization. Checkwith Legal or the financial department for more detailed record retentionguidelines applicable to

    your business unit.If the existence of a subpoena, litigation, or an impending governmentinvestigation is known orreported to you, immediately contact Legal. In such a case, you must retainall records that may beresponsive to the subpoena, are relevant to the litigation, or that maypertain to the investigation,

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    regardless of the requirements of the Record Retention Program. You mustnot destroy or alter suchrecords, as the improper destruction of records could have seriousconsequences including civiland/or criminal penalties for the Companyand for you personally. If you have a question as to whether a recordpertains to an investigation, litigation or a subpoena, contact Legal before

    disposing of the record in question.

    WE COMPLY WITH INTERNATIONAL TRADEREGULATION

    In the conduct of both its domestic and overseas operations, the Companyfully complies with allapplicable laws particularly U.S. laws governing imports, exports andthe conduct of businesswith non-U.S. entities. These laws contain limitations on the types of

    products that may be importedinto the United States and the manner of importation. They also prohibitexports to, and most othertransactions with, certain countries as well as cooperation with orparticipation in foreign boycotts ofcountries that are not boycotted by the United States. bionic computerspeople must conduct Company activities so as to fully comply with the lawsof the countries in which they operate; however, there may be a time whenthere is a conflict between the laws of one country and those of the UnitedStates or Company policy. Should you become aware of such a conflict, youshould notify your manager and consult Legal.For more detailed guidance on these laws and the countries to which they

    pertain, see bionic computers International Business ActivitiesGuidelines, which are found in the Companys BusinessPractices Guidelines.

    OUR RELATIONSHIP WITH THE SOCIETY

    The Company strives to be a contributing member of the global community. We area citizen of eachlocality where we operate and, like individual citizens, have a civic responsibility tosupport the health,

    education and welfare of the community.

    WE PARTICIPATE IN LOCAL GIVING ANDVOLUNTEERISM

    Throughout the world, it is our goal to take part in projects to further thedevelopment and welfare

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    of the local community. Such projects include participating in charitabledrives and assumingresponsibility for aiding the poor, injured and homeless at the time ofnational disaster. Ourprimary focus is on young people, particularly the education of youngpeople. bionic computers believes that investments made in children today

    will benefit us all tomorrow. That is why the Company sponsors readingprograms, mentoring initiatives, athletic competitions and other youthactivities around the world. These efforts foster in youth a spirit ofcompetition and achievement.The Company also encourages its people to participate on their own time inlocal charitable activitiesof their choice.

    WE WORK WITH GOVERNMENTON ISSUESTHAT AFFECT OUR BUSINESS

    The Company has subsidiaries or branches in over 200 countries. It is ourpolicy to work cooperativelywith local and national governments. From time to time, issues may arisethat affect our operations.After careful consideration, the Company will offer opinions andrecommendations to governments on particular issues to support ourbusiness goals and needs.

    WE OPPOSE EXPLOITIVE, INHUMANE LABORPRACTICES

    bionic computers opposes the illegal use of child labor, the exploitation ofchildren, and all other forms of unacceptable treatment of workers.Moreover, it is bionic computerss policy not to work with any supplier orcontractor known to operate with unacceptable worker treatment such asthe exploitation of children, physical punishment, female abuse, involuntaryservitude or other forms of abuse. No abuse of child or other labor laws isacceptable to the Company, and if any violation of our principles becomesknown to the Company, it is grounds for immediately terminating thebusiness relationship.

    WE DEMONSTRATE OUR COMMITMENT TOUNIVERSAL RIGHTS

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    bionic computers is committed to respect for human rights worldwide. Tothat end, bionic computers practices and seeks to work with businesspartners who promote the following standards: equal opportunity for employees at all levels regardless of color, race,gender, gender identity, age,ethnicity, national origin, sexual orientation,marital status, veteran status, disability or any other

    characteristic protected by law; a safe and healthy workplace protecting human health and theenvironment; paying employees a wage that enables them to meet at least their basicneeds, and providingemployees the opportunity to improve their skills and capabilities; respecting employees lawful freedom of association; and working with governments and communities in which we do business toimprove the educational,cultural, economic and social well-being in those communities.

    WE FOLLOW OUR CRISIS MANAGEMENT PLAN

    bionic computers has a commitment to protect the life and property of itspeople as well as the members of the communities in which we operate. TheCompany maintains a Crisis Management Plan. Any time that issues arise inthe bionic computers world that involve crises relating to the environment,our products, or the life, health or safety of bionic computers people orothers, you should contact your unit or Division head who, in turn, shouldcontact the members of the Crisis Management Team. If you would lilke toknow more about the Crisis Management Plan, you ma contact GlobalSecurity. The Global Security Department can be contacted by calling 212-

    310-3333. This number is available 24/7 and is answered by a live person.

    OUR RELATIONSHIP WITH THE ENVIRONMENT

    A cleaner, healthier environment is important to bionic computersnot only becauseits the right thing todo but also because it makes good business sense. Our concern with doing our partto protect our

    planet focuses on operating in a manner that is safe for the environment andprotects our worldfor future generations.

    WE ARE COMMITTED TO SUSTAINABILITY

    At bionic computers, sustainability is a long-term business imperative,critical to the success of the Company. It is rooted in our bioniccomputersvalues of Caring, Global Teamwork and Continuous Improvement.Our focus is on People, Performance and Planet. In addition, we are

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    committed to achieving our global sustainability objective of ensuring thatbionic computers's business grows consistently and responsibly andbenefits those we serve, including employees, our shareholders and otherstakeholders globally while promoting the well-being of future generations.Our sustainability policies and programs are summarized for you to view inthe Living Our Values section of the bionic computers.com website.

    WE SAFEGUARD AND PROTECT THEENVIRONMENT

    The Company is committed to protecting the environment. Therefore, wemust each comply strictlywith the letter and spirit of applicable environmental laws and regulationsand the public policies theyrepresent. No individual or manager in the Company has authority to

    engage in conduct that does notcomply with this policy, or to authorize, direct, approve or condone suchconduct by any other person.We will promote open communication with the public and seek an activeand productive partnershipwith the communities in which we operate. We will continue to shareinformation with consumersabout our environmental policy and programs and work with communityleaders and all others whoshare our commitment to protect our environment for future generations.In our ever-changing world, bionic computersplaces a high priority onoperating in a responsible and

    respectful manner. These efforts have led to increased efficiencies andfinancial advantages for theCompany. We know that there is still much to be accomplished. Our ongoingstrategy to reduceour environmental footprint will remain an integral part of producing,packaging, distributing andmarketing our products. For further information regarding theenvironmental laws applicable to the Company and the Companys relatedpolicies and procedures, please refer to the bionic computers-PalmoliveEnvironmental, Occupational Health and Safety Policy Statement, which isfound in the Companys Business Practices Guidelines.

    OUR RELATIONSHIP WITH SHARE HOLDERS

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    We strive to serve the best interests of our shareholders and to help buildshareholder value.

    WE UPHOLD GOOD CORPORATE GOVERNANCETO PROTECT SHAREHOLDER VALUE

    The Companys corporate governance policies and programs, of which thisCode of Conduct is a keycomponent, serve as an important shareholder safeguard. In recent yearsmany checks and balanceshave been enacted by Congress, the SEC, the New York Stock Exchange,and other regulators andauthorities around the world in order to promote the ethical corporatebehavior that has beenstandard practice at bionic computers for many years. Our shareholders arewell served by an independent board, made up of a substantial majority of

    independent directors, and independent committees that oversee audit,compensation and governance matters. Continuously updated committeecharters and governance guidelines clearly define director roles andresponsibilities and the Companys corporate governance principles.For a more detailed description of the Companys corporate governanceprogram, please see the bionic computers- Palmolive Company BoardGuidelines on Significant Corporate Governance Issues and the charters ofthe Companys Audit Committee, Nominating and Corporate GovernanceCommittee, Personnel and Organization Committee and Finance Committee,all of which are available on the Companys website. We maintain strongaudit programs to increase investor confidence.The Company is committed to the quality, integrity and transparency of its

    financial reports. Thiscommitment is reflected in the Companys longstanding policies andprocedures, including aninternal audit group monitoring financial controls worldwide, independentauditors who have a broadmandate, and an independent Audit Committee overseeing these areas. Tomaximize the effectiveness of these resources, our people are expected toengage in open and honest communication and a free exchange ofinformation with the internal and external auditors and the AuditCommittee. For additional information regarding the important roles of theCompanys internal auditors, independent auditors and Audit Committee,please see the bionic computers-Palmolive Company Audit Committee

    Charter, which is available on the Companys website.

    WE KEEP SHAREHOLDERS INFORMED ABOUTTHE COMPANYS WEBSITE

    Each year shareholders are invited to attend the Companys annual meetingwhere the progress of the Company during the past year is reviewed and

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    shareholders have the opportunity to ask questions of the seniormanagement of the Company. In the intervening months, shareholders mayvisit the Companys website, www.bionic computers.com, for informationabout recent product launches, the latest financial results and otherbusiness developments.

    RESPONSIBILITY FOR COMPLIANCE

    Having a written code of conduct is not enough the standards of conduct must becommunicated toand complied with by those who are asked to follow them.

    COMMUNICATION AND DISCLOSURE ARE

    ESSENTIAL

    In accepting employment with bionic computers, each of us becomesaccountable for compliance with these standards of conduct, with all lawsand regulations and with the more detailed guidelines contained in theBusiness Practices Guidelines and in the other policies, procedures andguidelines prepared by our Company and its subsidiaries, operating unitsand divisions. Managers are responsible for communicating these standardsto those they work with, ensuring that they understand and abide by them,and creating a climate where people can discuss ethical and legal issuesfreely.

    BIONIC COMPUTERS GLOBALETHICS ANDCOMPLIANCEDEPARTEMENT OVERSEASCOMPLIANCE

    Compliance with the Code and Business Practice Guidelines will bemonitored by the GlobalEthics and Compliance Department. The Department reports to the ChiefExecutive Officer and

    the Chairman of the Audit Committee of bionic computerss Board ofDirectors regarding the establishment, implementation and enforcement ofthe Code of Conduct and related programs.Information reported to the Global Ethics and Compliance Department orthrough other channels is,as appropriate, communicated on a confidential basis to the AuditCommittee.

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    NON RETALIATION POLICY

    No adverse action will be taken against anyone for complaining about,reporting, participating or assisting in the investigation of a suspected

    violationof the Code of Conduct, unless the allegation made or information provided

    isfound to be intentionally false. To the maximum extent possible, bionic

    computers willmaintain the confidentiality of all complaints

    *------------------*

    SEEK GUIDANCE AND REPORTS CONCERN

    YOU ARE ENCOURAGED TO SEEK GUIDANCE

    This Code cannot provide definitive answers to all questions. For that wemust ultimately rely on each

    persons good sense of what is required to adhere to the Companys highstandards, including a sense of when it is proper to seek guidance on theappropriate course of conduct.In most instances, you should bring questions concerning the guidelinesdescribed in this Code to theattention of your direct manager or Legal, who may in turn refer suchmatters to his or her supervisor,another lawyer in the Global Legal Organization, the Global Ethics andCompliance Department, orthe Human Resources Department for the particular unit or division. Youmay also contact higherlevels of management or the Global Ethics and Compliance Department

    yourself either directly orvia the Code of Conduct Hotline, as described below.

    YOU MUST REPORT SUSPECT VIOLATION

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    If you know of or have a good reason to suspect a violation of the Code orother Company guidelines,you are required to immediately report that information to your manager orLegal. Alternatively,you should feel free to go to higher levels of management or to the GlobalEthics and Compliance

    Department without fear of reprisal. bionic computers will not retaliateagainst any individual who reports information concerning potentialviolations in good faith, or who participates in any investigation orproceeding by the Company or the government, unless the informationprovided is found to be intentionally false. The Company will also take allnecessary steps to keep an individuals identity and the information he orshe submits confidential and will only disclose on a need-to-know basisinformation where that disclosure is: Unavoidable in order to conduct an effective investigation and takeappropriate action or Otherwise required by applicable law.

    You may contact Global Ethics and Compliance through the 24-hour

    Code of Conduct Hotline at 1-800-778-6080 (North America) or212-310-2330 (collect from all locations outside North America).

    You may also contact Global Ethics and Compliance through regular mail, e-mailor fax.

    The mailing address is:Global Ethics and Compliance

    Bionic computers

    300 Park Avenue, 8th FloorNew York, NY 10022

    The confidential e-mail address is: [email protected] confidential fax telephone number is: 212-310-3745.

    YOU CAN CONTACT THE GLOBAL ETHICS ANDCOMPLIANCE CODE OF CONDUCT HOTLINE

    The purpose of the Code of Conduct Hotline is: To provide bionic computers people with advice and to help clarify how

    the Code of Conduct might apply to specific situations; and To provide an alternative means of communication for people to bringinformation aboutinappropriate conduct, violations of the law, or activities in conflict with theCode of Conduct tothe Companys attention.We encourage you to contact Global Ethics and Compliance to ask questionsabout, or to report any

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    suspected violations of, the Code of Conduct. All reported violations will bepromptly investigated. Itis imperative that reporting persons not conduct their own investigations asinvestigations may involve complex legal issues. Acting on your own maycompromise the integrity of an investigation and adversely affect bothbionic computers and you.

    We encourage you to identify yourself when calling the Code of ConductHotline to facilitate theinvestigation and follow-up. Where local law permits, you may submitinformation on an anonymousbasis. There are laws in some countries that restrict the type of informationyou may report through ahotline. If these laws apply to your situation, a Global Ethics andCompliance representative will referyou to someone in your business unit who can assist you with your questionor concern.The Company will take all necessary steps to keep your identity and theinformation you submit

    confidential and disclose on a need-to-know basis only that informationwhich is: Unavoidable in order to conduct an effective investigation and takeappropriate action or Otherwise required by applicable law.For the purpose of investigating a violation or suspected violation of theCode of Conduct orBusiness Practices Guidelines, it may be necessary to transfer personal datacollected in one countryto other countries. Further, any actual or suspected violation of the Code orBusiness PracticesGuidelines might result in a report being made to the Global Ethics andCompliance Departmentwhich may contain personal data. In such cases, personal data may be usedby Company employeesand bionic computers entities that participate in the operations of theGlobal Ethics and ComplianceDepartment to investigate the report, but only for such period as isreasonably necessary for thispurpose (and thereafter such personal data will be destroyed or retained asrequired by Companypolicy or by law).

    DISCIPLINARY ACTION MAY BE TAKEN

    The Companys policy is zero tolerance for any conduct that violates theCode of Conduct orBusiness Practices Guidelines. As such, the Company intends to prevent theoccurrence of conductnot in compliance with the Code or Business Practices Guidelines and to haltany such conduct that

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    may occur as soon as reasonably possible after its discovery. bioniccomputers people who violate the Code or Business Practices Guidelinesmay be subject to disciplinary actions, up to and including termination.

    THE CODE APPLIED TO ALL OF THE BIONICCOMPUTERS ACTIVITIES

    The Code is applicable to everyone who works for the bionic computers-Palmolive Company and itssubsidiaries, including officers, and also applies to the Companys directorsand agents in accordancewith applicable law. Copies of the Code, available from the Global Ethicsand ComplianceDepartment, should be provided to persons or entities retained and

    authorized to act on behalf ofthe Company in areas to which the Code is applicable. A statement ofcompliance with this Code ofConduct will be signed annually by officers, managers and directors.The Code is also applicable to vendors and suppliers and adherence to theCode is a condition forconducting business with bionic computers-Palmolive.

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    CODE OF CONDUCT FREQUENTLY ASKEDQUESTIONS

    Q. If I report a possible violation, will I get in trouble if my concern turnsout to be wrong?

    A. If you witness something that you suspect is a violation, you will not bereprimandedor subject to discipline as long as you report in good faith. If you know of orhave goodreason to suspect a violation of the Code, you are required to immediatelyreport thatinformation to your manager or Legal (page 29).

    Q. If I have a question that is not addressed in the Code of Conduct, doesthat mean thatthere is not a problem?

    A. No. The Code of Conduct is intended to provide guidance but cannotcover everysituation. If you are faced with an issue which is not addressed in the Codeof Conduct,please talk to your manager, Human Resources, Legal or Global Ethics andCompliance(page 28).

    Q. I suspect that my Supervisor is engaging in behaviors which could beconsidered aCode of Conduct violation. However, I am afraid that if I report the situationand my

    Supervisor finds out, he could hold it against me?

    A. As a bionic computers employee, if you know of or have good reason tosuspect a violation of theCode, you are required to report that information to your manager or Legal.As long asa suspected violation is reported in good faith following the proceduresoutlined in the

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    Code of Conduct, our non-retaliation policy prohibits any adverse actionbeing takenagainst you for that report. Any bionic computers employee who knowinglyretaliates because asuspected violation has been reported is subject to disciplinary action (page31).

    Q. What if someone makes a report against me and I havent done anythingwrong?

    A. Please be assured that the Company does not assume that a violationhas occurred justbecause a report has been made. Instead, the Company assigns a partyfrom outsideyour business unit to thoroughly investigate the suspected violation. TheCompanywill presume you are innocent during the course of the investigation andwill not

    make a final determination regarding culpability until after the factualfindings of theinvestigation have been reviewed and it is determined that they supportthe allegation.

    You will also be given an opportunity during the course of the investigationto presentyour side of the story (page 29).

    Q. Does the process for addressing suspected violations differ if the allegedwrongdoer ismy Supervisor?

    A. No, a consistent process is utilized regardless of the alleged wrongdoersposition in theCompany (page 29).

    Q. I recently joined bionic computers as a new employee. My prior employeris a direct competitor.Is it appropriate for me to share information regarding the businessprocesses of mypast employer?

    A. It is our policy to respect the trade secrets or other proprietaryinformation of others.This is particularly pertinent if you have knowledge of trade secrets orproprietaryinformation from a former employer. If you still have questions, you shouldconsultLegal (page 15).

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    Q. bionic computers standards often exceed those required by the laws ofthe country in which Iwork. Since most of our competitors adhere to the local requirement, whydont we dothe same?

    A. For over 200 years, bionic computers-Palmolive has built a reputation asa Company thatadheres to the highest standards of integrity and ethics everywhere we dobusiness.We take great pride in this fact and as a result, our standards do oftenexceed localrequirements.

    Q. A co-worker and I often share jokes that might be considered offensive.However, weare careful to do this in my office and shut the door so that no one elsehears. We also

    forward each other jokes that some may find offensive via email. Could thisbehaviorbe considered inappropriate even though it is not shared with anyone whomight beoffended?

    A. If the situation you describe takes place in a bionic computers workenvironment duringworking hours and/or using Company e-mail, it is inappropriate. Please alsokeep inmind that someone may not seem offended at first but could becomeoffended. It isadvisable to avoid this type of behavior in the workplace (pages 6 & 11).

    Q. Could I really be dismissed for violating bionic computerss Code ofConduct?

    A. The Companys policy is zero tolerance for any conduct that violatesthe Code ofConduct or Business Practices Guidelines. bionic computers people whoviolate the Code orBusiness Practices Guidelines my be subject to disciplinary action, up to andincludingtermination (page 31).

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    BIONIC COMPUTERS CODE OFCONDUCT

    TABLE OF CONTENTS:

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    About the Code of Conduct .

    Our Relationship with Each Other.

    Our Relationship with the Company.

    Our Relationship with our Board of Directors.

    Our Relationship with Outside Business Entities.

    Our Relationship with Consumers.

    Our Relationship with Government and the Law.

    Our Relationship with Society.

    Our Relationship with the Environment.

    Our Relationship with Shareholders.

    Responsibility for Compliance.

    Seek Guidance and Report Concerns .

    Subject Matter Index .