ROLLS-ROYCE GLOBAL CODE OF BUSINESS ETHICS - EthicsPoint

SECTION3.2RUNNING OURCOMPANYAVOIDING CONFLICTSOF INTERESTSECTION3.2RUNNING OURCOMPANYAVOIDING CONFLICTSOF INTERESTWe avoid any relationship,influence or activitythat might impair,or even appear to impair,our ability to make objective decisions whenperforming our jobs.As employees,we do not:– Provide services (as an employee,consultant,or otherwise) to a competitor or potentialcompetitor.– Place business with a firm owned orcontrolled by an employee of Rolls-Royceor his or her family,unless written approvalhas been received beforehand.– Own,or have a substantial interest in,acompany which is or has the potential to be aRolls-Royce customer,supplier or competitor.If such a situation arises,or if we are unsureas to whether or not any conflict of interestmay have arisen,we will report it promptly tothe responsible manager and seek advice.We comply with the laws and regulations thatapply to the actual or potential employmentor engagement of former military and civiliangovernment personnel.Q:My husband works for a company thatsupplies Rolls-Royce with equipment.Sometimes I am responsible for purchasingsupplies from them.What should I do?A:Explain this to your manager,who will provideguidance or seek advice.Q:I have often dealt with military customersin the course of supplying Rolls-Royceequipment.One of them has asked meabout the possibility of employment bythe company after he leaves the military.How should I respond?A:You should not discuss the details of anyemployment opportunities without first agreeingthe position with HR.There are also conflict ofinterest regulations that must be fully andcarefully observed.Share the facts of the situationwith your manager and the Legal department.We do not engage in,encourage or facilitateinsider trading.This means that we will notuse any non-public information aboutRolls-Royce or other companies for buyingor selling shares,other securities or financialinstruments for personal gain.Neither will wepass on such information to anyone else 15 .24 Rolls-Royce Global Code of Business Ethics25 Rolls-Royce Global Code of Business Ethics