Code of Business Integrity 02 Our Code of Business Integrity Our Code of Business Integrity 03 One Linde

Making our world more productive

Our Code of Business Integrity 02 Our Code of Business Integrity Our Code of Business Integrity 03 One Linde

As One Linde, we are united by a shared purpose, common direction and mutual accountabilities.

Mission We live our mission of making our world more Vision productive every day. Through our high-qual- We are committed to fulfilling our vision to be the ity solutions, technologies and services we are best performing global industrial gases and engi- making our customers more successful and helping neering company, where our people deliver inno- to sustain and protect our planet. vative and sustainable solutions for our customers in a connected world.

Values

Safety Community Integrity Inclusion

Accountability 04 Our Code of Business Integrity Our Code of Business Integrity 05

CEO Message

We work hard every day to build on our tradition of success at Linde. That success is anchored to a strong foundation of integrity. Over the years, we have earned our reputation as a safe, reliable and honest business partner and corporate citizen. Our commitment to operating ethically at all times has served us well and is critically important to our success going forward.

Our Code of Business Integrity has been created to provide you with the valuable information and insight you need to navigate compliance and ethics questions, to promote an overall culture of compliance, and to arm you with the knowledge and resources required to make sure we keep our commitments to all our stakeholders.

Our Code cannot cover every possible scenario we might face, but it does contain helpful guidance for many of the more common issues that can arise. Most importantly, our Code provides a framework for asking questions and highlights the resources we have in place to report concerns.

At a minimum, we are all responsible for speaking up when something doesn’t seem quite right, or we believe misconduct has occurred. Please familiarize yourself with these reporting resources and know that the company does not tolerate any type of retaliation against those who speak up in good faith about potential issues.

I hope that you feel, as I do, that our strong foundation of integrity is a key asset that we must preserve and enhance. These standards embody our commitment to maintaining that foundation.

Thank you, 06 Our Code of Business Integrity Our Code of Business Integrity 07

Contents

One Linde ...... 02 Our4. Commitment to our Customers and Partners ...... 26 4.1 We Treat Our Customers Fairly...... 27 CEO Message...... 04 4.2 We Select Our Partners Diligently...... 28 4.3 We Provide Limited Gifts and Entertainment...... 28

Our1. Commitment to Integrity...... 08 Our5. Commitment to our Communities ...... 30 1.1 Our Code’s Purpose...... 09 5.1 We Do Not Bribe...... 31 1.2 Our Shared Commitment...... 09 5.2 We Compete Fairly...... 32 1.3 Asking Questions and Reporting Concerns 5.3 We Comply with Trade Regulations and Laws ...... 34 (“If You See Something, Say Something”)...... 10 5.4 We Are Committed to Human Rights ...... 35 1.4 Retaliation Is Prohibited...... 10 5.5 We Are Good Corporate Citizens...... 36 1.5 What Happens When You Report? ...... 11 1.6 A Manager’s Role ...... 11 1.7 We Make Ethical Decisions...... 12 1.8 We Protect Privacy ...... 12 Waiver6...... 38

Our2. Commitment to our Employees...... 14 Business7. Integrity Certification ...... 39 2.1 We Embrace a Diverse and Inclusive Workplace...... 15 2.2 We Work Safely...... 16

Our3. Commitment to our Company ...... 18 3.1 We Avoid Conflicts of Interest...... 19 3.2 We Keep Accurate Records...... 20 3.3 We Protect Our Assets...... 22 3.4 We Protect Data and Confidential Information...... 23 3.5 We Do Not Trade on Inside Information ...... 24 3.6 We Communicate Responsibly ...... 25 08 Our Code of Business Integrity Our Code of Business Integrity 09

1. Our Commitment to Integrity

1.1 Our Code’s Purpose

We believe that fairness, transparency and trust We follow the law, so we are bound by all local drive growth and prosperity for all parties involved laws governing our business operations wherever – employees, customers, suppliers, markets – and we are located. If there is a conflict between the the communities that encompass them all. Adher- law and our Code or company policy, we will follow ing to those qualities brings out the best in us, the stricter standard within the framework of the inspires the best in our business partners, reduces applicable laws. If you are unclear about which our exposure to legal risk and helps build and laws or policies apply to you and your job, then sustain a positive corporate reputation. Not only is please consult your line manager or the Legal & behaving ethically the right and legal thing to do, Compliance department. it is good business.

This Code of Business Integrity (“our Code”) pro- 1.2 Our Shared Commitment vides guidance on how we as Linde employees will conduct ourselves with each other and with cus- Compliance and ethics touch every role at Linde, tomers, suppliers, governments, other businesses so we all play a part in creating an ethical work and our environment. While our Code cannot environment. We show our commitment by famil- address every question or issue that may come up, iarizing ourselves with our Code, our policies and it does provide us clear guidance on many compli- any applicable laws or regulations. This will help ance and ethical challenges we may face. If you us spot potential issues and make sure we conduct have specific concerns, please consult our company business ethically and legally. We also speak up policies as highlighted in our Code or seek guid- when we have questions and concerns. ance from your manager, the Legal & Compliance department, or the Human Resources department. Failure to follow our Code can mean endangering employees, business operations, the environment, Our Code applies to everyone at Linde, including the communities in which we work, our business directors and officers, all employees and to all of relationships and our company’s reputation. In Linde’s majority-owned subsidiaries and affiliates cases of serious misconduct, it can also expose us worldwide. We also expect our subcontractors and to significant legal penalties, including fines and other stakeholders to know and follow the stan- criminal or civil prosecution. dards described in this document as it applies to their roles.

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1.3 Asking Questions and Report- 1.4 Retaliation Is Prohibited 1.5 What Happens When You Report? 1.6 A Manager’s Role ing Concerns (“If You See Something, Say Something”)

If you have questions about an issue that is We can all report concerns and participate in offi- When you make a good faith report, Linde opens a If you are a manager, you must support and covered in our Code, or any issue you feel involves cial investigations without fear of punishment. confidential investigation. All concerns are treated foster a workplace that recognizes our values and potential misconduct or violation of our Code, our Linde strictly prohibits retaliation against someone fairly and dealt with quickly and in accordance with demonstrates ethical conduct. This involves follow- policies or the law, you should promptly raise your reporting an issue or concern in good faith. The data protection legislation. If you do not wish to be ing and modelling our Code and making certain concerns with your manager or the Legal & Com- company may take serious disciplinary action identified while raising a concern, you can report your direct reports both understand their responsi- pliance department. Your manager is a valuable against employees found retaliating, up to and anonymously where it is legal. bilities under our Code and are comfortable speak- resource and your first point of contact for sharing including termination of employment. ing up with their questions and concerns. or discussing any concerns. It is expected from a manager to promptly and If you don’t feel comfortable approaching your properly escalate any concern raised or report manager, you may make a report to another made by any employee, as well as monitor and resource or report anonymously where allowed by In a good faith report, the person making enforce your team’s adherence to our Code, our local law. Some of our reporting resources include: the report honestly believes the informa- policies and the law. tion he or she is disclosing is true and accu- →→ Your Compliance Officers & Compliance rate. Even if an investigation finds that no Champions misconduct occurred, a good faith reporter →→ The Legal & Compliance Department is protected from retaliation. →→ The Human Resources Department →→ An email to the integrity hotline →→ A dedicated web portal designed to receive concerns →→ A globally accessible Integrity hotline phone operated through a third-party company that manages these calls for our company

Remember, if you see something, say something.

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1.7 We Make Ethical Decisions 1.8 We Protect Privacy Failure to comply with privacy laws is a serious For more information, consult your manager or the offense; violations can cause serious harm to our Legal & Compliance department. If you suspect Our Code cannot cover every circumstance, and it is In the course of doing business, we collect and business and our reputation, and may result in or know of the misuse or unlawful disclosure of not always easy to know the right thing to do in a manage the personal information of employ- criminal sanctions, administrative fines and liability personal or customer data, you should report it to challenging situation. If you are ever unsure about ees and our customers, suppliers and others. Our risks for our company as well as individuals. the Legal & Compliance Department or any other a decision or action you’re considering, ask these careful handling of this personal information is one reporting resource. questions: of the reasons we are a trusted employer and business partner. →→ Is it inconsistent with our Linde values? →→ Does it violate our Code or policies, or local Our company complies with all privacy laws in the You are finishing the process of outsourcing laws or regulations? countries in which we do business, and we acquire, a large database of personal customer infor- →→ Do you feel uneasy about it? process, use and retain only the personal data that mation to an external provider. A colleague →→ Would you feel uncomfortable if your family, is required for effective company operations to the tells you that there may be data protection friends, colleagues or the public found out extent allowed by applicable law. concerns in transferring such a large amount about it? of personal data outside the company, but →→ Could it damage your or Linde’s reputation if it If your role involves interacting with sensitive per- you do not want to postpone completion of were described in the media/social media? sonal or customer data, you may not process, use the transfer. What should you do? or disclose the information except as needed to If you answer “yes” to even one of these ques- perform your job. You may not disclose to any cus- →→ Transferring personal data to a third party tions, the action or decision you’re considering tomer or other entity any confidential or propri- must be managed very carefully. You may be unethical and you should not proceed with etary information about another customer without must always comply with data protec- it. Instead, consult with your manager or the Legal that customer’s specific, written permission and tion regulations and laws concerning the & Compliance department for guidance on how to the approval of your manager. transfer of such data. So, no matter how handle the issue. long it will postpone the completion of Additionaly, you must comply with all non-dis- your work, you should discuss the situa- closure agreements (NDAs) and data processing tion with the Legal & Compliance Depart- agreeements concerning confidential or personal ment to ensure that customer data is information provided by any business partners or properly handled and protected for such other companies. transfers.

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2. Our Commitment to our Employees

2.1 We Embrace a Diverse and Inclusive Workplace

We believe our strength lies in the diversity of our from or engage in a sexual relationship with any people. Inclusion is one of our core values, and we employee they directly or indirectly supervise. If are committed to creating and maintaining a safe, you engage in a consensual romantic relationship professional and inclusive work environment in with a subordinate, we advise you to immediately which all employees are treated with respect and coordinate with your manager or human resources dignity. representative so that appropriate actions, such as change of reporting lines, etc., may be taken. Our company complies fully with applicable labor and employment laws, and we do not tolerate discrimination or harassment against anyone based on race, color, religion, gender, gender identity, national origin, age, disability, veteran status, Harassment is behavior that creates an pregnancy or sexual orientation. We also provide intimidating, hostile or offensive work equal employment opportunity, and we recruit, environment. Harassment can be physical, hire, promote and compensate people based solely verbal or written. Some examples include: on merit and ability. →→ Expressing or displaying disparaging or At Linde, you must not engage in any discriminat- derogatory comments, gestures, jokes, ing or harassing behavior, and you are expected pictures, or drawings, or ridiculing an to speak up of any conduct you believe to be dis- employee based on his or her status or crimination or harassment to your manager, Human characteristics Resources representative, the Legal & Compliance →→ Expressing or displaying sexual com- department, or the Integrity Hotline. ments, gestures, jokes, pictures or photos If you are a manager, in addition to adhering to the →→ Engaging in unwelcome physical principles above, you must help create an inclusive contact, sexual advances or requests for environment in which different backgrounds and sexual favors, or basing employment viewpoints are respected and valued. Managers decisions on the rejection or coerced will not retaliate against any individual who com- acceptance of such requests plains of discrimination or harassment or who par- ticipates in an official investigation. Managers will not use their position to extract sexual favors

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2.2 We Work Safely

Safety, health, care for the environment and You must also recognize and report any unsafe Taking safety seriously also involves coming to quality are all pre-requisites for any business we practices or work conditions, hazardous material work free from the influence of any alcohol or undertake. Safety is a key value for us and we spills, potential permit compliance issues, accidents illegal drugs and never using any alcohol or illegal demonstrate our focus on good conduct and con- and injuries to your manager or regional SHEQ drugs at work. tinuous improvement in all business processes and representative. programs. A safe work environment is also free of threats and You are also expected to properly handle and intimidation, so we never use or threaten to use Linde has developed comprehensive safety, secu- dispose of any waste in accordance with company violence in the workplace. rity and environmental policies, standards and pro- environmental guidelines and all applicable laws. cedures for work processes to enable employees If you are a manager, you are also required to around the world to execute their jobs safely. As promptly record all incidents that may have failed a Linde employee, you should familiarize yourself to comply with environmental permits and laws with the policies and procedures that apply to your and regulations, then report them to your SHEQ role. If you are unsure what might apply, contact representative. your manager or your regional Safety, Health, Envi- ronment and Quality (SHEQ) representatives. You should alert your manager or Corporate Secu- rity at any workplace where you notice the pres- ence of anyone who may be unauthorized.

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3. Our Commitment to our Company

3.1 We Avoid Conflicts of Interest Jessica is in the middle of managing a As Linde employees, we must keep our personal project to build a new Linde site. A subcon- business pursuits completely separate from those tractor drops out at the last moment, and of the company’s. Otherwise, we may cause a the job they were doing is so complex that conflict of interest if we, a family member, or any it could take months to find a new subcon- person of a similar close relationship have a per- tractor. Jessica’s cousin runs a company sonal interest that competes or interferes with which could do this work immediately. Can our duties or could otherwise negatively affect a she employ her cousin’s company to do the company interest. work?

Not only do conflicts of interest raise doubts about →→ Not directly, as it could appear that our integrity and the quality of the business deci- Jessica was biased in giving them the sions we make, but even a perceived conflict of job. Instead, she should tell her manager interest can damage our company’s reputation or about the potential conflict and ask to be harm its business interests. removed from the decision about which new subcontractor Linde should employ. So we avoid conflicts of interest, or even the That way the company can form an appearance of a conflict of interest, at all times. unbiased view about whether or not to Anyone with an actual or apparent conflict must employ her cousin and avoid the appear- actively disclose it to a manager or the Legal & ance of a conflict of interest. Compliance department to discuss, manage and document it. 20 Our Code of Business Integrity Our Code of Business Integrity 21

3.2 We Keep Accurate Records

Accurate financial recording Managing Records We’re accountable at Linde and shareholders, All company books, records and reports we create, A strong records management program helps our financial analysts, creditors, lenders and other change or handle should accurately reflect our company keep its commitment to safeguard our Samuel has recently left Linde to work members of the public rely on us to provide them business activities and always align with our business information and that of our business for another company. He is going through with reliable information regarding the company’s accounting and record-keeping processes and partners. some files in a box at home and finds notes, operations, performance and outlook. Our cred- the law. memos and other Linde materials. He knows ibility is measured by the integrity of our books, We must retain or destroy records, including hard that he probably isn’t supposed to have this record-keeping and financial reporting. Managers who receive any complaints or reports copy documents and emails, according to applica- information anymore, so he puts it in the regarding accounting misconduct must immediately ble record retention schedules. Exceptions include trash at his home. Is this okay? We provide fair, accurate, timely and clear dis- report those allegations to the Head of Internal documents subject to “hold orders” issued by the closure and financial reports. All members of Audit and Security, the Chief Financial Officer, the Legal & Compliance Department in conjunction →→ No. Samuel still has a duty to keep any the public should have equal access to the same corporate General Counsel, or the Chief Compliance with ongoing investigations. potentially confidential information honest and accurate information, and we imple- Officer. Practices that require reporting include safe even after he leaves the company. ment and maintain effective business controls to improper internal accounting controls or auditing Your role as an employee is to make sure you Throwing it in the trash doesn’t meet ensure that Linde’s financial reporting is reliable. matters, fraud involving management, or any retal- understand and comply with our Records Man- his continuing obligation to protect our iation for reporting such fraud. agement policy and any records retention sched- information. He should contact his former ules for the documents under your control. Also, manager and make arrangements to you may not destroy or alter any records upon return the documents. either learning of an actual or threatened lawsuit or investigation, or receiving a legal hold order, regardless of your division’s records retention schedule. 22 Our Code of Business Integrity Our Code of Business Integrity 23

3.3 We Protect Our Assets 3.4 We Protect Data and Confidential Information As a Linde employee, you must follow all of the company’s computer security guidelines, partic- Company assets should be used for legitimate busi- Our company owes part of its success to the con- ularly with regard to creating safe passwords and ness purposes and not for any employee’s per- Brock is doing some construction work on fidential and proprietary information we develop using them effectively (including not allowing sonal benefit. Damaged, stolen, misused or wasted his house this weekend. Can he bring home and use. Therefore, we do not share confidential others to use yours), as well as being using proper company assets have a negative impact on all some of the tools he uses at work for his information with anyone unless there is a valid precautions in emailing confidential or proprietary Linde stakeholders and on the company’s opera- home project? business reason for them to have it and they sign a information to a third party. You are responsible for tional and financial performance. non-disclosure or a confidentiality agreement with following the Linde IT security policies and proce- →→ No. Our company tools and equipment Linde. Our responsibilty to safely secure confiden- dures that apply to your role. Assets can be physical objects, such as computers are to be used for business purposes tial and proprietary information remains in effect and other hardware, office furniture and the prod- only. even after we leave the company. These security obligations also apply to confiden- ucts we manufacture, as well as intangible items, tial and proprietary information that customers, such as software, intellectual property (IP), confi- Additionally, we always comply with applicable suppliers and others entrust to Linde. We never dential business information and trade secrets. laws designed to protect confidential information. leave confidential or proprietary information unse- cured nor do we dispose of it improperly, such as in You should report suspected fraud, theft or misuse a public trash receptacle. of company assets promptly to your manager or other resource in this Code. Because there is always a risk in public or in other Confidential or proprietary company infor- places that you might be overheard, be always In addition to using company assets for legitimate mation is information that belongs to Linde, aware of your corporate responsibility and do not business purposes, the company may determine in not public or is confidential due to agree- discuss confidential or proprietary information at from time to time on a regional level, if you may ment. “Proprietary” information also has such places. access company computer resources for personal a business value. It can include formulas, reasons if use is limited to an incidental level that methods, devices, pricing information, cus- Sometimes it may be hard to determine if informa- does not interfere with your job performance. Keep tomer information, strategies or plans – tion is confidential or proprietary. Do not guess if in mind that the use of the company’s computer, all things that are critical to our business you are uncertain; consult with the Legal & Compli- data and systems are subject to the rules set forth success. ance Department. in the Linde IT security policies. If you know or suspect that confidential and proprietary information belonging to Linde has been improperly disclosed, you should report it immediately to your manager or another resource in this Code.

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3.5 We Do Not Trade on Inside Information 3.6 We Communicate Responsibly

Linde does its part to support a fair and open secu- How important or “material” a piece of information Linde presents its image to the public through Please exercise great care not to disclose confi- rities (stock) market in compliance with applicable is considered can be difficult to determine, so you company communications. This is why our state- dential or proprietary company information when laws. Therefore, we do not buy or sell any stock should consult the Legal & Compliance Department ments must always be transparent, accurate and participating on social media platforms, message based on any material non-public, or inside, infor- if you have any doubts or questions. However, aligned with our strategic goals and values. This is boards, blogs or any other public forum (such as mation. We also do not provide inside informa- examples of potentially material information also the reason why only those employees autho- Facebook, Linked In or Twitter). tion to any other individuals, a practice commonly include news of: rized to do so should speak to the press or on known as “tipping,” so that they may trade. social media on the company’s behalf. All advertising, marketing and sales activities →→ a significant merger, acquisition, divestiture must describe our offerings and services legally, If your role gives you access to material non-pub- or joint venture Unless you are an authorized company spokes- fairly and honestly, never using false, misleading lic information regarding Linde or its subsidiaries, →→ a stock split person, you may not respond to inquiries about or deceptive information. We also must make sure a customer, a supplier or another company, you →→ the execution of a major contract Linde’s business, facilities, employees or custom- that we and our business partners use Linde trade- must use great care to make sure you do not reveal →→ the purchase or sale of a significant asset ers from someone you do not know. Instead, direct marks consistently and appropriately. Therefore, it, intentionally or unintentionally. Be aware that →→ significant litigation or government all such requests to your head of communications if you work in marketing or sales, you must get there are significant criminal and civil penalties for investigation or to the business or the corporate media relations approval from the communications department at those that violate insider trading laws. department. the regional or group level for all official advertising and promotions and before allowing customers If you receive inquiries from the investment com- or suppliers to use the Linde name or logo in their munity, you should forward them to Investor advertising. If you have any questions, contact the Relations. communications department. Material non-public information or inside information is data or facts a reasonable investor would consider important in decid- ing to buy, sell or hold stocks or other securities.

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4.Our Commitment to our Customers and Partners

4.1 We Treat Our Customers Fairly

Developing and sustaining community is another If you are working with a government, you must key value. While we work hard and take on chal- coordinate all government bids and contracts lenges, our drive to succeed never leads us to (including amendments) and coordinate the exe- forsake our obligations to our customers, compro- cution and administration of any government con- mise our values or cut any corners. tracts with the designated government contracting contact and the Legal & Compliance Department. We strive to ensure that our products are made Additionally, you must not sign any government to the highest standards with respect to safety, contract that has not been approved by your gov- health, the environment and quality. ernment contracting contact and the Legal & Com- pliance Department. We also work with local governments worldwide, so if you are an employee with those customer relationships, you must learn and follow the requirements of government contracts in addition to all other applicable regulations and the law. This A government (or public) official is an process can be very complex, but you can get the officer, employee or official representa- detailed information you need from the Legal & tive of a government or any government Compliance Department. It is important that you department or agency. Government offi- carefully read the “Doing Business with the Gov- cials can include political candidates, ernment” module. elected or appointed officials and members of royal families. Government divisions can include state-owned businesses and organizations. 28 Our Code of Business Integrity Our Code of Business Integrity 29

4.2 We Select Our Partners Diligently 4.3 We Provide Limited Gifts and Entertainment

Our suppliers and other third parties play a criti- While the exchange of gifts can build understand- The gift and entertainment policies Linde has cal role in our ability to operate and provide prod- ing, community and goodwill in everyday business developed for employees in various businesses, Recognizing Inappropriate Gifts or ucts and services to our customers. Because of our life, giving and receiving gifts can also create the functions and regions may require you to seek Entertainment business partnerships with them, our suppliers’ perception of a conflict and potentially compromise pre-approval. In case of any questions, consult The value, purpose and setting in which actions and practices reflect on us as well. There- our decision-making or the decision-making of our your manager and/or the Legal & Compliance a gift, entertainment or favor is given fore, we choose suppliers carefully based on merit partners. Therefore, we must use caution in how Department. or received determines how appropriate and a due diligence process. We require suppliers we exchange gifts, meals and entertainment. it is. If the item, event or activity would to comply with legal requirements and to act in a You are prohibited from offering, giving or receiv- be considered lavish or unusual in normal manner that is consistent with our values, the prin- A general rule at Linde is that the exchange of ing benefits of a sexual, offensive or illegal nature business practices, it is not acceptable. If ciples in our Code and the law. gifts and entertainment is an exception in business and gifts of cash or cash equivalents (such as you are negotiating transactions, evalu- transactions. No employee should offer, give or securities). ating bids or dealing with a government accept a gift, entertainment or other favor if it will employee, it is probably not acceptable for influence or could even appear to influence either As a Linde employee, you must never request per- you to receive a gift. party’s independent business judgment. Further- sonal gifts, favors, entertainment or other services more, employees must take special care regard- from an existing or prospective vendor, supplier ing entertaining or giving or receiving anything of or customer. You are also obligated to reject and value to government (or public) officials. report to your manager any gift, entertainment or favor offered to you or a family member that is not consistent with the company’s gift and entertainment policies or otherwise appears to be offered in order to gain influence.

Above all, be sure to review the gift and entertainment policy relevant to your business or country and act accordingly.

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5. Our Commitment to our Communities

5.1 We Do Not Bribe

We succeed through fair and honest dealings on A bribe is anything of value given or the basis of our integrity, Linde’s reputation and received by any person, either directly or our superior products and services. We do not seek indirectly, to try to gain an improper influ- to gain or give an unfair advantage by provid- ence or advantage. ing bribes or kickbacks. Such unethical and illegal conduct can create legal exposure for the company A kickback is a payment a third party and for you personally and can result in criminal makes or agrees to make in exchange for prosecution and substantial monetary fines. securing your business.

We do not tolerate the use of kickbacks or bribery Anything of value can be almost anything, in any form, and we prohibit third parties acting on including cash, cash equivalents (e.g. gift our behalf from giving or accepting bribes, directly cards), gifts, favors, food, entertainment or indirectly. and opportunities.

The company does not make or allow our represen- A government (or public) official can be tatives to make facilitation payments even if such someone employed by a government or payments may be permitted under certain national an employee of a business that is owned or laws. controlled by a government.

If you are in a position to hire or supervise vendors or other third parties, you must conduct appropri- You are not permitted to establish an illegal ate due diligence, complete a formal contract and on-book or off-book fund in order to make pay- otherwise assure yourself that the other company ments or provide anything of value to a third party, will not make bribes on our behalf. nor may you hire a foreign government official or a family member of a foreign government official to perform services for the company without prior written approval from the Legal & Compliance Department.

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5.2 We Compete Fairly

In providing gifts or entertainment, you must In supporting vigorous, lawful and ethical competi- You must plan in advance for any meetings with carefully follow the rules described in our Gifts tion, Linde complies with competition and antitrust competitors and get approval from your manager Sharla is excited to be heading to her first and Entertainment section and policies and make laws wherever we do business. We do not engage and the Legal & Compliance Department to attend trade show. When she joins a table for a lun- certain that any gifts you give or entertainment in anti-competitive behavior or misconduct. a trade association, professional society or certifi- cheon, she is seated next to a competitor you provide cannot be confused for a bribe. Pay cation organization for standards-setting or project. along with six other people. The competi- attention to the pre-approval process that may Have the Legal & Compliance Department review tor introduces herself and starts talking to apply. Be aware that many public officials are not and approve materials you’re sharing or presenting Sharla. She is not sure what to do? allowed to accept any gifts. Since this topic can be at the gatherings mentioned above. complex, please contact the Legal & Compliance Examples of anti-competitive misconduct →→ Sharla can speak with the competitor Department if you have any questions or concerns. include entering into unlawful agreements If a competitor tries to involve you in an inappro- at the luncheon, as long as the discus- with competitors and discussing pricing priate conversation or suggests you do something sion does not mention any prospective (price fixing), terms & conditions of sale, you suspect is illegal, you must announce your or ongoing Linde business, our confi- bid rigging, customer boycotts, and divi- refusal to participate in the misconduct before dential or proprietary information, strat- sions of customers, territories or markets. immediately leaving the conversation and promptly egies, marketing or any other sensitive Rodney, the purchasing manager responsible contacting the Legal & Compliance Department to company information. If the conversation for buying office materials, frequently uses report the encounter. turns to these topics, Sharla must exit the one particular supplier. That company’s sales We never seek out or accept a competitor’s con- conversation immediately and contact the representative offers Rodney an envelope fidential or proprietary information, nor do we If you have questions concerning antitrust law Legal & Compliance Department to report containing cash. What should Rodney do? discuss with competitors sensitive business strat- issues, you should consult with the Legal & Compli- the encounter. egies that may be valuable to them, such as plans ance Department. →→ Rodney should refuse the envelope and for divestiture, joint venture or acquisition. inform his manager. Accepting the cash would have violated our policy and our Code.

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5.3 We Comply with Trade Regulations 5.4 We Are Committed to Human Rights and Laws

All countries regulate the way products are Trade and sanction laws and regulations can be We recognize every person’s innate humanity and exported and imported across international complex and ever-changing. If your job respon- treat everyone with dignity and respect. In sup- borders. Certain types of products, software sibilities involve the import, export or transfer of porting the protection and promotion of human and information cannot be directly or indirectly hardware, technology, software and information, rights worldwide, Linde abides by the principles exported to specified countries. Other items can you must be aware of these regulations as well as of the International Bill of Human Rights enacted require a permit, license, valuation, end-user cer- the applicable Linde policies and procedures that by the United Nations, and does not condone nor tificate/end-use screening or record-keeping, and cover your work. Doing business in embargoed engage in discrimination, harassment, violations may require us to file for and receive them before countries, or with embargoed persons or organiza- of privacy, slavery or servitude, restrictions on free they can be imported or exported. tions, may be illegal or subject to restrictions. Vio- assembly or unfair employment practices. lations of these trade laws and sanctions can carry Laws may also prohibit or restrict exporting, serious penalties, including fines and civil or crimi- We adhere to these Human Rights principles and importing or re-exporting products based on nal prosecution. we expect everyone with whom we conduct busi- factors such as the product’s origin, classification, ness to observe similar standards. dual-use potential or the customer’s identity. If you have any questions regarding exporting or importing (including carrying by hand) of any Linde’s products or technologies, consult the Legal & Compliance Department or the trade compliance group. 36 Our Code of Business Integrity Our Code of Business Integrity 37

5.5 We Are Good Corporate Citizens

Linde’s corporate responsibility philosophy is based As a conscientious corporate citizen, Linde supports You also may not use company funds, property, on the company’s vision, values and principles: to employees’ personal participation in the political personnel or services to support any candidates, demonstrate responsible behavior towards each process. However, there are strict laws regarding elected or appointed office holders, government other, our communities and our environment. how corporations and employees or other parties officials or political parties. You may not engage representing corporations may engage in politics. in personal political activity on Linde time or use This means we are committed to developing tech- Therefore, you cannot engage in any unauthorized company resources for such a purpose. nologies and products that combine customer lobbying or make any direct or indirect political benefit with sustainability, we actively support contributions to candidates, elected or appointed Furthermore, managers must not coerce or pressure educational and research projects related to our office holders, government officials or political any employee to contribute to any political candi- core business areas, and we provide accountability parties on Linde’s behalf. date or party. to all our stakeholders at every business location worldwide. 38 Our Code of Business Integrity Our Code of Business Integrity 39

6.Waiver 7. Business Integrity Certification

Any waiver of our Code must be made by the Board of Directors. Please document your commitment to uphold the principles described in this Code of Business Integrity.

I certify that I have read and understand Linde’s Code of Business Integrity and that I have and will continue to comply with these standards.

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