Lawson, and its employees and representatives, will treat prospective and existing customer, business partners and suppliers fairly and will not engage in anticompetitive or unlawful practices that restrict the free market economy.

Bribes

Lawson's objective is to compete in the marketplace by providing superior products and services at competitive prices. No Lawson employee and/or representative may give any direct or indirect payment in any form (i.e., any item, service, or assistance of any value) to anyone anywhere in the world for the purpose of obtaining or retaining business, or to obtain any other favorable action.

Entertainment (non-governmental)

Appropriate business entertainment of non-government representatives occurring in connection with business discussions or the development of non-government business relationships is generally deemed appropriate in the conduct of official Lawson business. This may include, but is not limited to, reasonable business-related meals and trips and occasional athletic, theatrical or cultural events. Entertainment in any form that would influence your judgment, or cause you to feel or have any personal obligation, should not be given or received.

Gifts (non-governmental)

No gift may be given to or accepted from a non-governmental supplier, vendor or customer unless the gift has nominal value (e.g., a shirt or coffee cup) and a refusal to accept it would be discourteous or otherwise harmful to Lawson. If it is not clear whether a gift has nominal value, Lawson employees should consult their supervisor. Gifts that would influence your judgment, or cause you to feel or have any personal obligation, should not be given or received. As explained below, no gifts of any kind or value may be given to or accepted from government representatives.

Lawson employees giving gifts or providing entertainment to a non-governmental customer should ask themselves:

• Am I offering something in order to obtain special treatment for Lawson?
• Will I favor this supplier because the supplier gives me a gift?
  [Note: If the answer to either of the preceding questions is “yes”, then the employee must not undertake the activity.]
• How often this year have I provided gifts to this non-governmental customer?
• How often this year have I taken gifts from this non-governmental supplier?

International Business

The practice of giving and receiving gifts varies throughout the world. If you will be entertaining or will be entertained by people in different countries, explore beforehand what is and what is not appropriate for that culture. If you have any questions, please consult with your supervisor or Lawson’s Legal Department.

Entertainment and Gifts (public sector/governmental); U.S. Foreign Corrupt Practices Act

Gifts and entertainment in the public sector/governmental agencies are much more restrictive than practices that are acceptable for companies/non-governmental agencies. In addition to governmental rules and regulations, Lawson complies with the U.S. Foreign Corrupt Practices Act and the applicable laws of other countries which prohibit the payment of money or the provision of anything of value to any person who is a government official, member of a political party or candidate for political office, solely for the purpose of obtaining, retaining or directing business. These laws apply to Lawson, Lawson employees, temporary workers, consultants, business partners and other Lawson representatives. Lawson observes strict accounting standards imposed by these laws on public corporations and their subsidiaries relating to the accuracy of books and records and internal controls.

Because of these restrictions, no business entertainment or gifts of any kind (even token gifts) may be given to or accepted from any government employee or other government official without the prior written approval of Lawson’s Legal Department.

Lawson employees should review Lawson’s “Governmental Gifting Policy” for information on procedures to have a proposal reviewed by Lawson’s Legal Department. The Governmental Gifting Policy is available on the employee portal under the Government and Education section.

Americas-based Lawson employees should review Lawson’s “Travel and Expense” policy located on the employee portal under the Employee Self Service section. Access ERG Policy 3.75 through the Handbook section. EMEA and APAC-based employees should refer to the applicable section of their employee handbook or contact their HR representative for more information.

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