Code of ConductCode of Conduct

Everything Starts with Ethics and Integrity
At Cramlington Precision Forge Ltd. (CPFL), ethics is not just a guideline—it's a daily requirement that shapes every decision we make. We understand that this commitment to ethics and integrity is essential and influences every action we take within the company. The complexity and robustness of our processes can sometimes present ethical dilemmas, requiring us to approach decisions with extra care. During these moments, when our choices have significant impacts on the company, it's crucial to have a solid foundation. This is where our Code of Conduct comes in. This document is designed to assist our employees, management, and partners in their decision-making processes. CPFL's Code of Conduct translates our company’s values into actionable ethical principles, which must be applied to both minor and major decisions. By adhering to these principles, we can collectively achieve our mission: We exist to excel in precision forging, shaping the future with integrity and innovation.

Table of Contents
Introduction
Our Values and Related Principles
2.1 Life Matters Most
2.2 Respect Our Planet and Communities
2.3 Value the People Who Build Our Company
2.4 Act with Integrity
2.5 Make It Happen
Managing the Code of Conduct
3.1 Who Does the Code Apply To?
3.2 How Should We Apply the Code?
3.3 Questions
3.4 Whistleblower Channel
3.5 Consequences of Violations
Glossary
Terms of Acknowledgement and Commitment
1. Introduction
CPFL’s Code of Conduct consolidates the fundamental principles that drive our business purpose.

Our Purpose: To shape the future with precision and excellence in forging.

Our Values:

We believe in the importance of precision engineering to the development of the world.
We only serve society when we generate prosperity for all and take care of our planet.
We exist to create and deliver precision-forged solutions that improve industries and enrich lives.
Our Core Values:

Life Matters Most
Respect Our Planet and Communities
Value the People Who Build Our Company
Act with Integrity
Make It Happen
Each value embodies the principles that guide us as we strive to remain an ethical company that continually grows in a sustainable manner. Understanding and living by these values means embracing key behaviors in our daily work: an obsession with safety and risk management, open and transparent communication, empowerment with accountability, ownership, and engagement with society.

2. Our Values and Related Principles
2.1 Life Matters Most
Security in All Aspects: We prioritize the safety and well-being of our employees. Every decision made at CPFL reflects our commitment to maintaining a safe and healthy work environment. We report every accident, near miss, and unsafe condition promptly, handling them with honesty and professionalism, aligning with our value that "Life Matters Most."
2.2 Respect Our Planet and Communities
Care for the Environment: At CPFL, we respect nature as a cornerstone of our operational excellence. We are committed to balancing our environmental impacts with sustainable practices and controls, ensuring that we contribute to global efforts in conservation.

Our Relationship with Society: We manage the risks and impacts of our operations on communities responsibly. Our actions are guided by respect, ethics, and integrity, fostering partnerships and positive legacies in the regions where we operate.

2.3 Value the People Who Build Our Company
Inclusive Work Environment: We value diversity and promote an inclusive workplace. Every individual at CPFL is respected and given the opportunity to reach their full potential, regardless of their background. We reject any form of discrimination or harassment.

Healthy and Constructive Relationships: Our work environment is built on mutual respect, ethics, and integrity. We acknowledge the uniqueness of each individual and consider these aspects in every decision we make.

2.4 Act with Integrity
Open and Transparent Dialogue: CPFL fosters an environment where different opinions and views are valued. We encourage open dialogue and active listening, ensuring that all voices are heard and respected.

Absence of Conflicts of Interest: We avoid any conflicts of interest that could compromise our integrity. Our decisions are made solely for the benefit of CPFL and its stakeholders.

Data and Asset Accountability: We are responsible for safeguarding CPFL’s assets, including equipment, materials, and information. This includes ensuring the proper use and protection of all company data and resources.

Intolerance for Corruption: CPFL has zero tolerance for corruption and bribery. We strictly adhere to ethical practices in all our dealings, maintaining the highest standards of integrity.