Anti-Bribery and Anti-Corruption Policy

 OBJECTIVES

These Guidelines provide guidance on business ethics. They supplement the principles set out in the Code of Conduct to show that all Colfax entities operate fairly, transparently and with integrity

The purpose is to ensure that Colfax and its subsidiaries (“Colfax”) comply fully with all applicable laws and operate to ethical standards wherever they conduct business

SCOPE

These Guidelines apply to all employees of Colfax, ESAB, Howden and EWAC with the exception of employees employed by AGI or its subsidiaries who are covered by separate guidelines issued by AGI.

These Guidelines apply throughout the group irrespective of the country where business is conducted and/or a particular business unit is situated. The principles contained in these Guidelines must be applied in all countries, even if they are more stringent than local law. Where local laws are more stringent than these Guidelines, then they must also be complied with.

Everyone at Colfax must show that all business is performed to the highest ethical standards and complies both with these Guidelines and all applicable laws.

POLICY

No one at Colfax will engage in any form of bribery.

A “bribe” is the promise of money, reward, favour or a benefit to a person or public official in order to influence the conduct or judgment of that person.

In particular, no Colfax employee will

  • Offer any bribe to any person or public official;
  • Accept any bribe; and/ or
  • Engage in any form of indirect bribery by offering or receiving any bribe through a 3rd party

COMPLIANCE AND OVERSIGHT

Senior Management (which means the MD/ Chief Executive and the FD / Head of Finance), of the relevant business unit, are responsible for implementing these Guidelines and enforcing them. They must advise on and approve payments, gifts and