The EWA-Lab Code of Conduct will help employees in their daily life. This document is an ethical reference for your daily business life.

We are proposing great services for our users.

The foundation of our success is the Respect of values we share.

• Respect for laws and regulations.
• Respect for people.
• Respect for the environment.
• Respect for competition law regulations.
• Respect for rules on insider trading.
• Prevention of conflicts of interest.
• Transparency and integrity of information.

So please do read the Code and EWA’s values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, and to encourage other Label Heroes to incorporate, the principles of the Code and values into our work.

And if you have a question or ever think that one of your fellow Label Heroes or the company as a whole may be falling short of our commitment, please tell us. We want – and need – to hear from you.

Who Must Follow Our Code?

We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment.

Moreover, while the Code is specifically written for Label Heroes DAO and Board members.

What If I Have a Code-Related Question or Concern?

If you have a question or concern, ask it. You can contact your manager/referent, Ethics & Compliance committee.

If you have a misconduct concern about the CEO, a direct report to the CEO, or a C-level, you may also notify the Audit Committee of EWA-Lab. To notify the Audit Committee, please mail your concern to:

EWA-Lab

Address :

24 grandchamps street, 1971 Champlan, Sion.

Or

Mail: compliance.support@ewalab.ch

You may report your concerns to the Audit Committee anonymously. However, the Audit Committee encourages you to provide your name and contact information so that we may contact you directly if necessary.

No Retaliation

EWA-Lab prohibits retaliation against any Label Heroes or former Label Heroes who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact Ethics & Compliance service.

I. Code of conduct

Our users value our company not only because we deliver great profits and services, but because we hold ourselves to a higher standard in how we act, work, collaborate. Keeping the following principles in mind will help us to maintain that high standard:

1. Integrity

   Our reputation as a trusted company is our most valuable asset. Every employee needs to make sure EWA-Lab keeps this trust. Trust with users, market, providers, partners. All of our communications and other interactions with everyone should increase their trust in us.

2. Usefulness

   Our products, features, and the services deployed to give full visibility on possible diversifications in line with our values, manage financial assets, using cryptocurrency to enjoy life. have many different types of users, from small to little community member, but one guiding principle: “Is what we are offering useful and good for the users interests?”

3. Privacy, Security, and Freedom of Expression

   By using our platform, users agree to share their personal information. Every Label Heroes needs to respect and protect the privacy and security of that information.

   Our security procedures strictly limit access to and use of users’ personal information, and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.

4. Responsiveness

   Evolve thanks to feedback : We recognize the interest of relevant user feedback. The latter will be raised within the company's DAO. Any holder will therefore be able to govern, to take part in the daily life of the company.

   We commit to have a clear communication with our users, whether questions, problems, or compliments. If something is broken we will fix it in a reasonable time.

5. Take Action

   Any time you notice our users aren’t being well-served, talk to us - let your manager know about it. Continually improving the platform and the services will provide us

II. Support and Respect Each Other

A. Our principles

EWA-Lab has an unwavering commitment to prohibiting and effectively responding to harassment, discrimination, misconduct, abusive conduct, and retaliation. To that end, EWA-Lab adheres to these Guiding Principles:

Commitment: EWA-Lab sets a tone at the top of commitment to a respectful, safe, and inclusive working environment for all employees and members of the extended workforce.

Care: EWA-Lab creates an environment with an emphasis on respect for each individual at all levels of the organization, including specifically by offering assistance and showing empathy to employees and members of the extended workforce throughout and after the complaint process.

Transparency: EWA-Lab is open and transparent as an organization regarding the frequency with which complaints arise regarding harassment, discrimination, misconduct, abusive conduct, and retaliation, and the Company’s approach to investigating and responding to those allegations.

Fairness & Consistency: EWA-Lab ensures that individuals are treated respectfully, fairly, and compassionately in all aspects of the company policies and values

Accountability: EWA-Lab holds all individuals responsible for their actions, and ensures that where appropriate, those individuals hold others accountable too.

B. Our practice

Consistent with the Principles, Label Heroes are expected to do their utmost to create a supportive work environment, where everyone has the opportunity to reach their fullest potential, and be free from harassment, intimidation, bias, and unlawful discrimination.

1. Equal Opportunity Employment

   Employment here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

2. Harassment, Discrimination, and Bullying

   EWA-Lab prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual, as discussed more fully in our Policy Against Discrimination, Harassment and Retaliation. If you believe you’ve been bullied, harassed, or discriminated against by anyone at EWA-Lab, or by a EWA-Lab partner, we strongly encourage you to immediately report the incident to your referent, C-level or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to the ethics and compliance committee. The ethics and compliance committee will promptly and thoroughly investigate any complaints and take appropriate action.

3. Drugs and Alcohol

   Our position on substance abuse is simple: It is incompatible with the health and safety of our employees, and we don’t permit it. Consumption of alcohol is not tolerated during working hours. Exception for special event schedule one week before allowed by the ethics and compliance committee members.

   During this event, please use good judgment and never drink in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited.

   If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request alcohol and/or drug screening. Reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

4. Remote work details

   Establish regular check-ins. Managers should set up regular meetings with their whole team and one-on-one check-ins with individuals. Emphasis on clear, regular communication can help bridge any gaps that come from working remotely. Make sure everyone on the team knows how to use the selected communications tools.

   Model behavior. Managers can set the example – if business casual clothing is expected on video calls, be sure to dress appropriately.

   Reinforce work/life balance. Managers can help reinforce work/life balance by ensuring employees are taking breaks and taking time off from work – working at home shouldn’t be a 24/7 job. Determine if employees must have set office hours or if they can split their day.

   Set clear goals. Managers and employees should determine priorities and how they’ll evaluate success. Regular goal setting can help keep productivity high despite the challenges of remote work.

   Allow for multiple technology options. E-mail, texts, video chats, phone calls, or using group messaging services can help give a team a sense of cohesiveness despite being dispersed.

   Be consistent in implementing and enforcing rules. While facing a pandemic has brought on new challenges and required new levels of flexibility, employees should still be making clear progress on goals and meeting company standards. Managers should avoid micromanaging but still need to provide feedback and support if team members are off track.

   Allow time for social interaction. Whether at the end or beginning of team calls, or a special time set aside for team chat, supporting social interactions is essential to avoid feelings of isolation.

   Offer support. Employees are likely under more pressure than ever and likely face much uncertainty. Ensuring that you offer support, whether it’s time to talk or additional resources, during this time is crucial.

   Provide the necessary tools. Provide remote employees with the equipment to do their job correctly. This may include laptops, headsets, and mobile phones.

   Be flexible when possible. Many employees may be trying to balance caring for elderly family members, children who aren’t in school or daycare, and pets who aren’t used to everyone at home. A little flexibility can go a long way.

   Most of all, celebrate every success. As the pandemic surges again, many employees will be facing lockdowns or quarantines again. Any form of celebration or recognition can help people feel more connected and happy, despite the challenges of navigating so many unknowns.

III. Avoid Conflicts of Interest

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of EWA-Lab or our users, you may be faced with a conflict of interest.

All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of MNPL.

If the answer is “yes,” the action you’re considering is likely to create a conflict-of-interest situation, and you should avoid it.

Below, we provide guidance in seven areas where conflicts of interest often arise:

• Personal investments
• Outside employment, advisory roles, board seats, and starting your own business
• Business opportunities found through work
• Accepting gifts, entertainment, and other business courtesies
• Use of EWA-Lab products and services, tools

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t.

If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and the Ethics & Compliance committee.

Please note, if your personal situation or goal changes in the future, be sure to connect with your manager and/or the Ethics & Compliance committee to allow you to pursue your career and your personal choices.

1. Personal Investments

   Avoid making personal investments in companies that are EWA-Lab competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm EWA-Lab.

   When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, EWA-Lab’s business, and what you do at EWA-Lab, including whether the company has a business relationship with EWA-Lab that you can influence, and the extent to which the company competes with EWA-Lab.

   You should also consider:

   1. Any overlap between your specific role at EWA-Lab and the company’s business,

   2. The significance of the investment, including the size of the investment in relation to your net worth,

   3. Your ownership percentage of the company,

   4. The extent to which the investment gives you the ability to manage and control the company.

2. Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business

   Avoid accepting employment, advisory positions, or board seats with EWA-Lab competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm EWA-Lab.

   Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your manager before accepting a board seat with any outside company. EWA-Lab board members and employees who are VP and above should also notify Ethics & Compliance. Finally, do not start your own business if it will compete with EWA-Lab.

3. Business Opportunities Found Through Work

   Business opportunities discovered through your work here belong first to EWA-Lab, except as otherwise agreed to by EWA-Lab.

4. Personal Relationships at Work

   Certain relationships within EWA-Lab may compromise or be seen to compromise your ability to perform your job responsibilities, may create uncomfortable or conflicted positions, and may raise issues of fairness, favoritism, or harassment. Therefore, be mindful of how your relationships within EWA-Lab could impact or be perceived by others. Romantic, physical or familial relationships are not permitted between a Label Heroes and another Label Heroes or member of the extended workforce where one individual is in a position to exercise authority or supervision over the other. This prohibition includes any situation where one person is in the reporting line of the other, For more information, see the Policy on Personal Relationships at Work.

5. Accepting Gifts, Entertainment, and Other Business Courtesies

   Accepting gifts, entertainment, and other business courtesies from a Label Heroes competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant.

   Label Hero’s Non-Government Related Gifts & Client Entertainment Policy provides specific guidance on when it is appropriate for Label Heroess to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all Label Heroess) from any of our competitors or business partners.

   Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and EWA-Lab business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult the Non-Government Related Gifts & Client Entertainment Policy, and be aware that you may need to obtain manager approval.

   Contact Ethics & Compliance if you have any questions. See the discussion of Anti-Bribery Laws in Section VII(d) for guidance on when it is appropriate to give gifts and business courtesies in the course of doing EWA-Lab business.

6. Use of EWA-Lab Products and Services

   Avoiding potential conflicts of interest also means that you should not use EWA-Lab products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of EWA-Lab. For example, you should never approve EWA-Lab accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as a Label Heroes to participate in or to generate a financial benefit for yourself or others from invalid ad traffic (IVT) on EWA-Lab products, such as generating IVT, purchasing or selling IVT (except for the purposes of company-sanctioned research), or linking to (or appearing to link to) business partners that may be engaging in IVT. If you find yourself subject to a conflict of interest regarding the use of EWA-Lab’s products, services, tools, or information, discuss the situation with your manager, Legal, or Ethics & Compliance.

7. Reporting

   Compliance Steering Committee all matters involving EWA-Lab C-Level – approved under this section of the Code, and will periodically report to the EWA-Lab Nominating and Corporate Governance Committee all matters involving EWA-Lab management and C-level approved under this section.

IV. Preserve Confidentiality

We get a lot of press attention around our innovations and our culture, and that’s usually fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential EWA-Lab material

– We must also:

• Properly secure, label, and (when appropriate) dispose of Confidential EWA-Lab material;
• Safeguard Confidential information that EWA-Lab receives from others under non-disclosure agreements;
• Take steps to keep our trade secrets and other confidential intellectual property secret.

1. Confidential Information

   Make sure that information that is classified as “Need to Know” or “Confidential” in EWA’s Data Classification Guidelines is handled in accordance with those Guidelines and EWA’s Data Security Policy. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, EWA-Lab policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.

   There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information. Be cautious in what advice or insight you provide or, better yet, ask for guidance from Ethics & Compliance.

   And don’t forget about pictures you and your guests take at EWA-Lab – it is up to you to be sure that those pictures don’t disclose confidential information.

   Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.

2. EWA-Lab Partners

   Just as you are careful not to disclose confidential EWA-Lab information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.

3. Data protection

   Be sure to protect the confidential information of EWA-Lab.

   You may have access to confidential information through collaborations, access to EWA-Lab networks, or simply through casual interactions. Don’t access or use confidential information when authorized and reasonably necessary for valid business purposes within the scope of your work at EWA. Take all reasonable steps to maintain the confidentiality of any such information just as you would for EWA confidential information.

   Don’t disclose any confidential information about EWA company, including financial, partner, business, technical, or IP information, before obtaining appropriate sign-off from Legal, which may include getting consent from affected the company.

4. Competitors/Former Employers

   We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any Label Heroes’s former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it. Should you happen to come into possession of a competitor’s confidential information, contact Legal immediately.

5. Outside Communications

   You probably know that our policy is to control and protect confidential proprietary information.

   You must be ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information.

   People can consider that you are speaking on behalf of EWA-Lab so weigh every word or every picture you wish to share.

   The same applies to communications with the press. Finally, check with your manager and Corporate Communications before accepting any public speaking engagement on behalf of the company.

   In general, before making any external communication or disclosure, you should consult our Employee Communications Policy and our Communications and Disclosure Policy.

V. Protect EWA’s Assets

1. Intellectual Property

   EWA’s intellectual property rights (our trademarks, logos, copyrights, trade secrets..) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use EWA-Lab’s (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the Marketing Team.

   We strongly encourage you to report any suspected misuse of trademarks, logos, or other EWA-Lab intellectual property to Legal.

   A word about open source – EWA-Lab is committed to open source software development. Consistent with our policy of respecting the valid intellectual property rights of others, we strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against EWA-Lab, as well as significant damage to the company’s reputation and its standing in the open source community. Please seek guidance from Ethics and Compliance before incorporating open source code into any EWA-Lab product, service, or internal project.

2. Company Equipment

   EWA-Lab gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the EWA-Lab stuff we are given. The company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Please ask your manager if you have any doubts.

3. The Network

   EWA’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security policies. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smartphone or think that your network password may have been compromised – please promptly report the incident to Information Security. For more information, consult EWA's Security Policy.

4. Physical Security

   If you’re not careful, people may steal your stuff. Always secure your laptop, important equipment, and your personal belongings, even while on EWA’s premises

5. Use of EWA’s Equipment and Facilities

   Anything you do use EWA’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, EWA may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting employees and users, maintaining the security of resources and property, or investigating suspected employee misconduct.

6. Employee Data

   We collect and store personal information from employees around the world. Access this data only in line with local law and EWA internal policies, and be sure to handle employee data in a manner that is consistent with EWA-Lab’s Data Classification and Employment Data Guidelines and other EWA-Lab policies.

VI. Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of EWA-Lab is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at EWA-Lab– not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to EWA-Lab, sign a new business contract, or enter into any deals on EWA-Lab’s behalf.

To make sure that we get this right, EWA-Lab maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.

Stay in full compliance with our system of internal controls, and don’t hesitate to contact Ethics & Compliance or Audit Committee if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at EWA.

1. Spending EWA’s Money

   A core EWA value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on EWA’s behalf, make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner on EWA, always record in our expense reimbursement tool the full names and titles of the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your referent. Referents are responsible for all money spent and expenses incurred by their direct reports and should carefully review such spend and expenses before approving.

2. Signing a Contract

   Each time you enter into a business transaction on EWA’s behalf, there should be documentation recording that agreement, approved by the Legal Department. Signing a contract on behalf of EWA is a very big deal. Never sign any contract on behalf of EWA unless all of the following are met:

   • You are authorized to do so under our Signature Authority and Approval Policy. If you are unsure whether you are authorized, ask your manager
   • The contract has been approved by Legal. If you are using an approved EWA-Lab form contract, you don’t need further Legal approval unless you have made changes to the form contract or are using it for other than its intended purpose
   • You have studied the contract, understood its terms and decided that entering into the contract is in EWA’s interest

   All contracts at EWA should be in writing and should contain all of the relevant terms to which the parties are agreeing – EWA-Lab does not permit “side agreements,” oral or written.

3. Recording Transactions

   If your job involves the financial recording of our transactions, make sure that you’re fully familiar with all of the EWA policies that apply, including our Revenue Recognition Policy and our Purchasing Policy.

   Immediately report to the Audit Committee any transactions that you think are not being recorded correctly.

4. Reporting Financial or Accounting Irregularities

   It goes without saying (but we’re going to say it anyway) that you should never, ever interfere in any way with the auditing of EWA’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other EWA records.

   Familiarize yourself with our Reporting of Financial and Accounting Concerns Policy. If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to Ethics & Compliance.

5. Hiring Suppliers

   As EWA grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for EWA-Lab. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision. Please do not hesitate to contact the Purchasing Team if you have any questions regarding how to procure equipment or services.

6. Retaining Records

   It’s important that we keep records for an appropriate length of time. The EWA Records Retention Policy suggests minimum record retention periods for certain types of records. These are great guidelines, but keep in mind that legal requirements, accounting rules, and other external sources sometimes specify longer retention periods for certain types of records, and those controls where applicable. In addition, if asked by Legal to retain records relevant to a litigation, audit, or investigation, do so until Legal tells you retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact the Records Retention Team.

VII. Obey the Law

EWA-Lab takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. Take advantage of Legal and Ethics & Compliance to assist you here. A few specific laws are easy to violate unintentionally and so are worth pointing out here:

1. Competition Laws

   Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition.

   Generally speaking, these laws prohibit

   1. Arrangements with competitors that restrain trade in some way,
   2. Abuse of intellectual property rights, and
   3. Use of market power to unfairly disadvantage competitors.

   Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for EWA-Lab.

   Examples of prohibited conduct include:

   • Agreeing with competitors about prices
   • agreeing with competitors to rig bids or to allocate customers or markets
   • agreeing with competitors to boycott a supplier or customer

   Other activities can also be illegal, unfair, or create the appearance of impropriety. Such activities include:

   • Sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
   • Entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
   • Using EWA size or strength to gain an unfair competitive advantage

   Although the spirit of these laws is straightforward, their application to particular situations can be quite complex.

   EWA is committed to competing fair and square, so please contact Ethics & Compliance if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated EWA’s Antitrust Policies will, subject to local laws, be disciplined, up to and including termination of employment. If you suspect that anyone at the company is violating the competition laws, notify Ethics & Compliance immediately.

2. Insider Trading Laws

   As we said earlier, internally we share information, including non-public information, about EWA’s business operations pretty freely (think of TGIF). In addition, you may overhear a hallway conversation or come across a memo at a copy machine, either of which might involve confidential information. To use this non-public information to buy or sell stock, or to pass it along to others so that they may do so, could constitute insider trading. Insider trading not only violates this Code, it violates the law. Don’t do it.

3. Anti-bribery Laws

   Like all businesses, EWA is subject to lots of laws, both EU. and non-EU., that prohibit bribery in virtually every kind of commercial setting. The rule for us at EWA-Lab is simple – don’t bribe anybody, anytime, for any reason.

4. Non-government relationships

   You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of EWA-Lab. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.

   Consult EWA’s Non-Government Related Gifts and Client Entertainment Policy before providing any business courtesies and contact Ethics & Compliance if you have any questions.

VIII. Conclusion

EWA-Lab aspires to be a different kind of company. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Label Heroess to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions of your manager, Legal or Ethics & Compliance.