June 2014

Ethics code
For Coats plc

The code
Comply with laws and regulations
We will comply with both the letter and the spirit of the laws and regulations that govern our business.
We will all
be honest, open and cooperative with all regulators;
properly record, report and review financial and tax information; and
comply with all employment legislation affecting our businesses in countries in which we operate.
Zero tolerance towards discrimination and harassment
We are committed to providing a safe and respectful working environment free from threats, violence,
harassment and discrimination. We will all

treat employees fairly and impartially throughout every stage of their work at Coats including
recruitment, progression, terms and conditions and representation;
not tolerate harassment or discrimination of any kind;
treat each other, suppliers and customers with dignity and respect; and
establish a consultative structure allowing everyone to have their say.

A safe and healthy working environment

We are committed to providing a safe and healthy working environment. We will all

comply with all environmental, health and safety laws and regulations;
provide and wear the appropriate equipment;
assess and control the specific risks arising from our work activities;
report accidents or injuries or safety concerns to the appropriate manager in the business;
not accept the use of alcohol or illegal drugs or abuse legal drugs in the workplace;
safeguard the health and safety of visitors, contractors and any others that may be affected by our
operations; and
provide appropriate health and safety and emergency training for all employees.

Further references
Our health and safety policy
Limit our environmental impact
We observe environmentally-sound business practices throughout the world because it is the right
thing to do. Coats will work to promote environmental care and awareness, with an emphasis on the
need to reduce energy consumption and waste production. We will all

comply with environmental laws and regulations; and

report environmental concerns to the appropriate manager.

Further references
Our environmental policy

June 2014

Strictly adhere to anti-trust laws

We value open and fair competition and will not knowingly enter into business arrangements that
eliminate or discourage competition or that provide us an improper competitive advantage. It is our
policy to compete independently and not to enter into any anti-competitive agreements. We will all

familiarise ourselves with and adhere to all laws that apply to our areas of the business;
not price fix, offer bribery or kickbacks, enter into agreements with competitors to divide the
markets in which we compete by allocating territories or markets and/or limiting the production
or sale of products or product lines, or condition the sale of one product on the sale of another
unwanted product or service.

Further references
Our competition policy
Our anti-corruption policy
Comply with anti-bribery and corruption legislation
We will not voluntarily give or receive (either directly or through a third party) any financial payment or
other advantage, with the intention to induce or reward any person to improperly perform a function or
activity that he is otherwise expected to perform in good faith, impartially or from a position of trust.
We prohibit bribery and facilitation payments in any form whatsoever, whether to public officials or
business contacts or made by Coats companies or on their behalf. We compete on the merits of our
products and services and do not use the exchange of business courtesies to gain an unfair
competitive advantage, nor do we offer or accept gifts of substance or inducements, particularly those
that encourage or reward decisions in the course of business. We will all act honestly and with
integrity to safeguard the resources for which we are responsible.
Business courtesies
These are defined as a gift, gratuity, favour or other intangible or tangible item having monetary value for
which fair market value is not paid by the recipient.
These include, but are not limited to cash, entertainment and recreation (tickets to sporting, recreational or
other events), transportation, discounts, lodging.
Business courtesies exclude advertising or promotional items of little intrinsic value (generally $20 or less)
such as a coffee mug, modest refreshments and other items, apart from transportation with a value of less
than $20 per occasion.
Employees who procure goods or services will
treat all suppliers uniformly and fairly and avoid favouritism.
not accept gifts from suppliers or vendors except advertising or promotional items.
Employees in non-procurement functions can accept business courtesies as long as
the provision or acceptance will promote goodwill and successful business relations;
the courtesies are not lavish or extravagant under the circumstances;
the courtesies are not frequent and do not reflect a pattern or the appearance of a pattern of frequently
providing or acceptance of courtesies from the same entities or persons;
they would feel comfortable discussing the courtesies with their manager or a co-worker, or having the
courtesies known by the public; and
it is duly approved and within the limits set by each Regional Chief Executive for their Region or within
the limit set by Group CEO for Group employees.
Further references
Our anti-corruption policy
Our whistle blowing policy

Avoid conflicts of interest

Our business is committed to upholding the highest standards of ethical business conduct and
expects the same of employees. It is our policy to ensure employees are precluded from having
personal interests in companies which have a business relationship with Coats and may therefore
create a conflict of interest.
Protect sensitive and personal information
We will not use information received in the course of business improperly for personal gain or for any
purpose except that for which it was given. We prohibit employees from soliciting and using
confidential information from other organisations.
Proper use of company assets
Business resources and assets (physical assets and company information) belong to our shareholders and we
will not use them to support a personal business or for an illegal act or purpose which would cause
embarrassment to Coats. We will all

use and maintain company property, electronic communication systems, information resources,
materials, facilities and equipment with the utmost care and respect; and
use company assets, for Coats business only.