ANTI-BRIBERY AND CORRUPTION 

Hettich Instruments, L.P. (Hettich) is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA) and similar laws in other countries that prohibit improper payments for obtaining a business advantage. This document describes Hettich’s Policy prohibiting bribery and other improper payments in the conduct of Hettich business operations and employee responsibilities for ensuring implementation of the Policy. Please direct questions about the Policy or its applicability to particular circumstances to our compliance officer. 

POLICY OVERVIEW 

Hettich strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and Hettich to possible criminal prosecution, reputational harm, or other serious consequences. This Policy applies to everyone at Hettich, including all officers, employees, and agents or other intermediaries acting on Hettich’s behalf. Each officer and employee of Hettich has a personal responsibility and obligation to conduct Hettich’s business activities ethically and in compliance with all applicable laws based on the countries wherein Hettich does business. Failure to do so may result in disciplinary action, up to and including dismissal. 

Improper payments prohibited by this Policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment, and other legitimate activities directly related to the conduct of Hettich’s business.