Page 51 - Footprint Employee Handbook - US 2021

WAIVERS AND AMENDMENTS
Any waivers of the provisions in this Code for executive officers or directors may only be granted by the CEO, or in
the case of a matter involving the CEO, the Board of Directors. Any waivers of this Code for other employees may
only be granted by the CLO. Amendments to this Code must be approved by the Board of Directors.

COMPLIANCE WITH ANTITRUST LAWS
The antitrust laws prohibit agreements among competitors on such matters as prices, terms of sale to customers
and allocating markets or customers. Antitrust laws can be very complex, and violations may subject Footprint and
its employees to criminal sanctions, including fines, jail time and civil liability. If you have any questions, consult the
CLO.

POLITICAL CONTRIBUTIONS AND ACTIVITIES AND CHARITABLE CONTRIBUTIONS
Any political contributions made by or on behalf of Footprint and any solicitations for political contributions of any
kind must be lawful and in compliance with Footprint policies. Footprint’s financial support to political organizations
requires the express approval of the Chief Legal Officer. This policy applies solely to the use of Footprint assets and
is not intended to discourage or prevent individual employees, officers, or directors from making political contributions
or engaging in political activities on their own behalf. No one may be reimbursed directly or indirectly by Footprint for
personal political contributions.

For information and guidance on charitable contributions, please consult the Company’s Global Anti-Corruption
Policy – “Political and Charitable Contributions”.

RELATED POLICIES

Footprint has established a number of other policies of which you were informed upon joining Footprint. For example,
there are topics that are related to certain items noted in this Code and in the Company’s Global Anti-Corruption
Policy. An integral part of this Code of Business Conduct and Ethics is that all employees abide by all policies
established by Footprint. These policies are deemed a part of this Code, and can be found in the employee
handbook.

CUSTOMER RELATIONS

It is always Company policy to provide its customers with exceptional quality of service in a courteous and thoughtful
manner. The customer comes first – our reputation and the customer’s perception of the Company rest with each
employee.
• Provide courteous, professional service in a prompt and efficient manner.
• Establish and maintain positive relationships with customers by gaining their trust and respect through
professional, honest interaction.
• Handle complaints quickly and professionally. Never argue with a customer. If you are unable to resolve the
complaint to the customer’s satisfaction, review the situation with your supervisor.

GLOBAL ANTI-CORRUPTION POLICY

Footprint International Holdco, Inc. and its subsidiaries and affiliates (collectively, the “Company”) operate in a wide
range of legal and business environments, many of which pose challenges to our ability to conduct our business
operations with integrity. As a company, we strive to conduct ourselves according to the highest standards of ethical
conduct. Throughout its operations, the Company seeks to avoid even the appearance of impropriety in the actions
of its directors, officers, employees, and agents.

Accordingly, this Policy reiterates our commitment to integrity and explains the specific requirements and prohibitions
applicable to our operations under anti-corruption laws, including, but not limited to, the US Foreign Corrupt Practices
Act of 1977 (“FCPA”). This Policy contains information intended to reduce the risk of corruption and bribery from
occurring in the Company’s activities. The Company strictly prohibits all forms of corruption and bribery and will take
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