Code of Business Conduct and Ethics

Who this applies to

This Code of Business Conduct and Ethics applies to Grenelle, its subsidiaries and affiliates (together, the "Company"), and to the Company’s directors, officers, employees, and key consultants (collectively, "Personnel"). It sets out the standards of conduct and ethical behaviour expected of Personnel in carrying out their responsibilities to the Company.

Purpose

The Code sets the standards of conduct expected of the Company’s Personnel: compliance with applicable law in every jurisdiction in which the Company operates, integrity and personal accountability, confidentiality, fair and even-handed treatment of third parties, and the avoidance and disclosure of conflicts of interest.

This Code exists to:

1. 01Ensure the Company and its Personnel comply with all applicable laws, rules, and regulations in every jurisdiction in which the Company operates;
2. 02Build a culture rooted in integrity, honesty, and personal accountability;
3. 03Safeguard the confidentiality of information Personnel obtain in the course of their role with the Company;
4. 04Encourage fair and even-handed treatment of the Company’s customers, suppliers, competitors, and other third parties;
5. 05Set clear expectations for honest, ethical conduct, including the proper handling of any actual or perceived tension between personal interests and professional duties;
6. 06Require Personnel to avoid situations that give rise to conflicts of interest, and to promptly disclose to appropriate management any material transaction, interest, or relationship that could reasonably be seen to create such a conflict; and
7. 07Reaffirm that Personnel’s outside business interests, investments, or personal relationships must never compromise, or appear to compromise, the objective performance of their duties to the Company.

Personnel are expected to uphold these standards consistently, in all aspects of their work on behalf of the Company.