Introduction

Dear Colleagues,

Integrity is our business and one of our key values. Not only does it form a basis of trust for our clients, business partners, stakeholders and one another, but it also guarantees our success as a Swiss market leader in survey research.
We consider it an obligation to provide the highest quality, innovative approaches and transparent procedures in our survey projects in social and market research, where we supply services from data collection and consulting to quality management
We set out our principles and professional rules of conduct in our code of business conduct and ethics (“code”). It defines framework conditions for all our business activities and must therefore be upheld by all LINK employees.
It encompasses the values and principles by which we act, and confirms our obligation with regard to honesty, integrity, responsibility and mutual trust and respect. Our code therefore does not introduce new concepts, nor does it impose additional obligations or restrictions, but it merely formalises the core principles of our activities, which we have already applied in the past.
No single document can cover all the circumstances facing you in your daily work. Our code illustrates our values and serves as a navigational guide, which should help you to make consistent and ethical decisions. We would ask each of you to assimilate the principles included in our code and to implement them fully in your own area of work.
An essential element of integrity is the commitment to an open culture in which all employees feel secure to seek advice and express their concerns. If you have questions or doubts, please turn to your line manager or a person you trust. If you identify an actual or presumed breach of our code, we would ask that you report your observation. This is in the interest and to the benefit of the entire LINK organisation. We ensure that anyone who poses questions or reports possible breaches can rely on protection from retaliation.
We, you and your colleagues are all responsible for the reputation of LINK. It is therefore expected that every LINK employee is aware of our code, understands it, and applies it without exception. As employees of LINK, we can be proud of what we do; by following our code, we can also be proud of how we do it.

Kind regards,

Benedikt Lüthi, CEO

I. Introduction

1. Purpose
Reading and complying with our code helps each of us ensure that we conduct our business activities in line with the highest ethical, legal and professional standards.
It is not possible for our code to anticipate every individual situation that we might encounter in the future. However, it will help us to make sound ethical decisions. Our code serves as a standard and refers to the LINK guidelines as well as the applicable laws and provisions of which we must be aware in order to be able to act in accordance with our fundamental values and expectations.

2. Application
Our code applies to and must be upheld by each individual full-time employee of LINK. It is also our aim to extend the most important principles of our code to our freelance and part-time employees, as well as to our business partners, such as suppliers or clients who are associated with the company.

3. Higher standards for management
Our colleagues with management responsibility have additional duties in the context of our code. The following is expected of them:

• to lead by good example – in other words, show what it means to act with integrity;
• to ensure that those reporting to them understand the requirements of our code and have the resources to fulfil this;
• to carry out our code consistently, and to monitor compliance by the people they supervise;
• to serve as a first point of contact, and support employees who pose questions or voice concerns in good faith.

II. Compliance with laws

1. Laws and professional ethics in market and social research
LINK expects its employees to comply with the laws and provisions in force. LINK also abides by the professional ethical regulations of market and social research in particular, such as is specified in the “Esomar Code on Market and Social Research” (http://www.esomar.org/knowledge-and-standards/codes-and-guidelines.php).

2. Anti-corruption
The success of LINK is based on the quality of its services and the autonomy of its employees. We strictly prohibit any form of bribery or corruption and any business practices that might create any appearance of exerting undue influence. For our international business activities, we are subject not only to Swiss and European anti-corruption laws but also to laws with extraterritorial reach (e.g. the U.S. Foreign Corrupt Practices Act (FCPA) or the UK Bribery Act (UKBA)).

• The interpretation of these laws is very clear: we may neither directly nor indirectly offer, authorise or accept bribes or services of monetary value to or from a public official or private commercial counterparty.

The consequences of breaching anti-corruption laws may be severe for LINK as well as for the persons concerned.

3. Gifts and invitations
In the context of business relationships, it is possible that employees of LINK may receive or offer gifts and invitations. Modest gifts (advertising gifts, etc.) and invitations (to meals, sport or cultural events, etc.) are usual and are part of business dealings. They may be accepted, provided they are appropriate in terms of the interests of the clients and LINK in their form and scope. They become bribery or corruption if they are intended to influence the decisions of the recipient based on their scale or type.
In order to avoid even the perception of unlawful relationships with third parties or potential third parties, every LINK employee must adhere to the following principles:

• Do not give gifts or invitations if they go beyond the usual courtesy and well-established local business practices, and in particular but not restricted to, gifts and invitations in the context of ongoing or planned business negotiations or new business acquisition processes.
• he value of a gift or hospitality must always be appropriate and must not introduce the question of an obligation for the recipient.
• Do not offer any kind of advantage to public officials.

4. Fair competition
National and international antitrust laws are in place to preserve, as far as possible, fair and free competition and the interests of clients. We ensure that all business practices comply fully with the applicable competition law, whenever and wherever business is carried out. A breach of antitrust law is a serious matter and may lead to considerable penalties for LINK as well as for individuals. Contravention of these laws is not tolerated by LINK.

• Our employees may not undertake any agreements, arrangements or coordinated activities with actual or potential competitors; in particular, they should not coordinate with competitors if this would represent a breach of applicable antitrust or competition law (e.g. to set prices or divide up markets or customers).

5. Money laundering
LINK complies with all relevant national and international laws and provisions to combat money laundering. Our objective is to only work with reputable business partners that participate in lawful business activities and with assets that come from legitimate sources.

• We adhere fully and completely to the internationally established “know your customer” principle, which requires essential standard information about the beneficial owner. Payment transactions are never made in cash. We do not make any payments to bank accounts in US and EU countries that are subject to an embargo. Transfers to private bank accounts of business partners are prohibited.

6. Insider information and insider dealing
Information that LINK employees receive in the context of their professional activity is used exclusively for the purpose for which it was originally provided.

• Insider information may neither be used for your own purposes nor in the interest of third parties. LINK is also obliged to comply with all insider laws in force that apply to LINK, our CEO and our employees.

III. Business integrity

1. Data protection and data security
LINK is entrusted with a great deal of information from clients, cooperation partners, suppliers and other business partners. LINK handles confidential information with the appropriate care. Data protection provisions and non-disclosure obligations with regard to clients and other persons are an inextricable element of market and social research and must therefore be reflected in personal conduct as well as the technical environment.
Data protection in respect of respondents in LINK studies must be adhered to unreservedly in particular. This means that the anonymisation of data is a top priority within LINK too.

• To protect personal data and keep data secure, LINK employees are obliged to comply with the data protection declaration and the IT policy of LINK.

2. Conflict of interests
The reputation of LINK depends greatly on the independence of decision-making processes and the integrity of our employees who act within the scope of LINK to ensure long-term economic success. The overall interest of LINK is therefore essentially based on particular interests.

• Personal and private interests should not play any part in business relationships or decisions. Only economic and ethical perspectives serve as a basis for our activities on behalf of LINK. Should a conflict of interests arise, employees are obliged to inform their managers and seek their agreement prior to any decisions being made.

3. Information systems and e-mail
The employee is not permitted to use or copy software from LINK IT systems for private purposes or to install private software on the company’s hardware without the permission of the LINK IT team.
E-mail services and Internet access are mainly offered for business purposes. You must take the same care as you would with paper communication when sending and receiving e-mails and attachments on your LINK account, and you should handle this in the same way. Please bear in mind the consequences it could have if such information became public.

• You may not, under any circumstances, misuse the IT systems, Internet access, e-mail accounts or other information and communication media of LINK for illegal or unethical purposes. The searching, downloading or passing on of information with content that is racist, extremist, propagandist, pornographic or promotes violence is considered to be a particular abuse and may lead to severe disciplinary measures.

4. Precise recording and reporting
Open and effective financial communication requires correct and truthful accounting and reporting, which is supported by an adequate and effective internal control system. This applies equally to relationships with clients, employees, business partners and investors as well as the public and all government agencies.

• The proper safekeeping of our financial documents and recordings is essential for our business. As such, we must store all financial documents, files and other relevant information according to the legal provisions and our internal guidelines.

Failure to keep precise and complete books and recordings not only contravenes the standards and guidelines of LINK but may also be in breach of the law. Therefore, we proceed openly and precisely in the creation and reporting of financial data and results.

5. Protection of company assets
At LINK, we regularly generate valuable expertise and other types of business information which we own and therefore have to protect as intellectual property or business secrets. Such information is a large part of what gives us a competitive advantage in our business environment.

• We have the responsibility and the legal obligation to protect all the physical, intellectual and financial assets of LINK, as they are vital for us in achieving our ambitious business objectives.

IV. Our employees

1. Respectful interaction, diversity and anti-discrimination
LINK employees conduct themselves respectfully with regard to clients, suppliers, colleagues and other persons. It is expected that all employees interact openly, fairly and respectfully.
We facilitate diversity of the workforce. At LINK, equality of opportunity therefore applies, irrespective of gender, age, nationality, religion or ideology, sexual identify or ethnic origin. These principles extend to all employment decisions, including recruitment, training, assessment, promotion and remuneration.

• Any attempts to discriminate will lead to disciplinary action and will not be tolerated. LINK employees are obliged to actively discourage discrimination.

2. Internal and external communication
LINK communicates important information centrally and in a targeted way. Communication specifications and/or language regulations are made available to employees by the company management or the respective head of department. We conduct ourselves professionally and cautiously at all times both internally and externally with regard to what we express. Neither incomplete knowledge nor untruths are disseminated about LINK or its competitors (tendered bids, studies won or lost, employment, terminations, etc.).

3. Harassment
We all have the right to work in an environment that is free from harassment. It is a form of discrimination that consists of unwanted behaviour, the purpose or effect of which is to create an intimidating, hostile or offensive working environment.

• Harassment may take many forms, including physical actions, verbal or written remarks or visual representations. LINK opposes all forms of harassment and will investigate any incidents resolutely.

V. Adherence to and enforcement of the code

1. Adherence to the code and cooperation
All our employees must read, understand and adhere to our code as well as the provisions and internal guidelines mentioned therein. In deciding whether an action or omission could represent a contravention of our code, common sense together with the following questions may serve as a guide:

• Is this conduct unlawful?
• Could it be regarded as dishonest or unethical?
• Would it damage the reputation of LINK or my reputation and credibility if it became public?

If the answer to any of these questions is “yes” or “perhaps”, you have identified a possible problem that you should discuss with your managers.

2. Contravention of our code
Contraventions of our code, our guidelines or the law may have severe consequences for LINK and all employees, for example, disciplinary measures, civil actions and/or prosecution. Irrespective of legal consequences, breaches are also punished internally with serious consequences at LINK. This not only concerns those who contravene the rules, but also the relevant line managers and all those who were aware of the breaches but did not report them.

3. Reporting and protection from retaliation
At LINK, everyone should feel able to speak up and express their concerns with regard to non-compliant conduct that contravenes this code. Reports may be made privately or anonymously and will be handled in strict confidence. No employee should fear retaliatory measures if they voice concerns in good faith.

• LINK does not tolerate attempts at retaliation in any form against persons who report suspected misconduct by others in good faith, or who support investigations in this respect.

LINK encourages all employees to report potential breaches of legal or internal regulations to their direct line manager.
LINK will carefully follow up all reports of wrongdoing, and expects all employees to work together thoroughly and honestly in the investigation of possible unlawful or unethical activities.

Checked by the Chairman of the Board of Directors of LINK Marketing Services AG
27 September 2018