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Having a written code of conduct is not enough – the standards of conduct must becommunicated to and complied with by those who are asked to follow them.COMMUNICATION AND DISCLOSURE ARE ESSENTIAL.In accepting employment with Colgate, each of us becomes accountable for compliance with thesestandards of conduct, with all laws and regulations, and with the more detailed guidelines contained inthe Business Practices Guidelines and in the other policies, procedures and guidelines prepared by ourCompany and its subsidiaries, operating units and divisions. Managers are responsible for communicatingthese standards to those they work with, ensuring that they understand and abide by them, and creating aclimate in which people can discuss ethical and legal issues freely.COLGATE’S GLOBAL ETHICS AND COMPLIANCE DEPARTMENT OVERSEES COMPLIANCECompliance with the Code of Conduct and Business Practices Guidelines will be monitored by the GlobalEthics and Compliance Department. The Department reports to the Chief Executive Officer/Chairmanof the Board and the Chairman of the Audit Committee of Colgate’s Board of Directors regarding theestablishment, implementation and enforcement of the Code of Conduct and related programs.Information reported to the Global Ethics and Compliance Department or through other channels is, asappropriate, communicated on a confidential basis to the Audit Committee.COLGATE-PALMOLIVE COMPANY 27
SEEK GUIDANCE AND REPORT CONCERNSYOU ARE ENCOURAGED TO SEEK GUIDANCE.This Code cannot provide definitive answers to all questions. For that we must ultimately rely on eachperson’s good sense of what is required to adhere to the Company’s high standards, including a sense ofwhen it is proper to seek guidance on the appropriate course of conduct.In most instances, you should bring questions concerning the guidelines described in this Code to theattention of your direct manager or the Global Legal Organization, who may in turn refer such matters tohis or her supervisor, another lawyer in the Global Legal Organization, the Global Ethics and ComplianceDepartment, or the Human Resources Department for the particular unit or division. You may also contacthigher levels of management or the Global Ethics and Compliance Department yourself – either directly orvia the Colgate-Palmolive EthicsLine (formerly known as the Hotline), as described below.YOU MUST REPORT SUSPECTED VIOLATIONS.If you know of, or have a good reason to suspect, a violation of the Code or other Company guidelines, youare required to immediately report that information to your manager, Human Resources or the Global LegalOrganization. Alternatively, you should feel free to go to higher levels of management or to the Global Ethicsand Compliance Department without fear of reprisal. Colgate will not retaliate against any individual whoreports information concerning potential violations in good faith, or who participates in any investigation orproceeding by the Company or the government, unless the information provided is found to be intentionallyfalse. The Company will also take all necessary steps to keep an individual’s identity and the information he orshe submits confidential, and will only disclose information on a need-to-know basis when that disclosure is:• Unavoidable in order to conduct an effective investigation and take appropriate action or• Otherwise required by applicable law.YOU CAN CONTACT THE GLOBAL ETHICS AND COMPLIANCE COLGATE-PALMOLIVEETHICSLINE.The purpose of the Colgate-Palmolive EthicsLine is:• To provide Colgate people with advice and to help clarify how the Code of Conduct might apply tospecific situations; and• To provide an alternative means of communication for people to bring information about violations ofthe law, or activities in conflict with the Code of Conduct, to the Company’s attention.You may contact Global Ethics and Compliance through our 24-hour Colgate-Palmolive EthicsLine at1-800-778-6080 (North America) or 1-212-310-2330 (collect from all locations outside North America).You may also contact Global Ethics and Compliance through regular mail, e-mail or fax. The mailing address is:Global Ethics and ComplianceColgate-Palmolive Company300 Park Avenue, 8th FloorNew York, NY 10022The confidential e-mail address is: ethics@colpal.com. The confidential fax telephone number is: 1-212-310-3745.28 CODE OF CONDUCT
Page 1 and 2: CODE OF CONDUCTLiving Our ValuesCAR
Page 3 and 4: LIVING OUR VALUESBy living our Colg
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Page 7 and 8: Our dealings with each other should
Page 9 and 10: As Colgate people, we strive to adh
Page 11 and 12: safeguarded. Trade secrets and othe
Page 13 and 14: Managers and others responsible for
Page 15 and 16: We are fortunate to have a group of
Page 17 and 18: Q:A:As part of my job, I make arran
Page 19 and 20: In addition, we exercise care in th
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Page 33 and 34: Q: Where can I go for training on a
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