Code of Conduct

GMS is fully committed to maintaining the highest standards of conduct and ethical behavior, honesty, openness and accountability in all our business activities and to promoting and supporting a culture of corporate compliance and good governance. GMS recognises that its employees and other stakeholders, such as customers, suppliers and other market participants, play an important role in achieving this commitment and this Code of Conduct is the centrepiece of our commitment when conducting business globally with the highest standards of business ethics. This Code is applicable to all employees and workers, including executive directors, non-executive directors, other corporate officers and staff of GMS and of any subsidiary in which GMS has a controlling interest, as well as any secondees, contractors/sub-contractors, consultants, agents, suppliers, irrespective of their location, function, grade or standing, engaged by GMS or its subsidiaries on its behalf and under its effective control and serves as the overarching guiding principles.

Your Responsibilities:

• You must understand and adhere to ethical responsibilities imposed by this Code. You should seek additional guidance from a department manager or from the Human Resources Manager when in doubt.
• You must participate in any compliance training and certifications required by GMS.
• You must advise fellow employees when their actions appear as a breach of this Code.
• You must cooperate with any investigations into potential misconduct.
• You must avoid situations which could result even in the appearance of wrongdoing or impropriety under this Code.
• You must read and ensure compliance with the GMS Anti-Slavery and Human Trafficking Procedure (T3-HR-PROC-020).

All Directors, Executive Committee members and managers have the responsibility to promote a culture of compliance and integrity and create a positive working environment in which people are treated with utmost respect and dignity. They are expected to:

• Lead by example through upholding the standards of this Code.
• Help the employees they supervise understand and comply with this Code and underlying policies and procedures.
• Support those who raise concerns and protect the employees from retaliation.
• Drive implementation and adherence of the GMS policy on modern slavery and human trafficking.

Compliance with this policy is further explained in our Code of Conduct Procedure (T3-GMS-PROC-024); you may also directly contact the Human Resources Manager.