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GasLog Ltd.
	Abuse of or Fraud with Company Benefits	Improper, misleading or deceptive actions taken, falsification of records, or misrepresentation of physical conditions related to benefits plans including health and supplemental income plans, tuition reimbursement and sick or other paid time off programs.
	Accounting and Auditing Matters	The unethical systematic recording and analysis of the business and financial transactions associated with generally accepted accounting practices. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions.)
	Accurate Books & Records	The falsification or improper modification of information in the Company's books and records, or the improper omission of information from the Company's books and records. (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions)
	Antitrust Activity	Oral or written agreements, arrangements or understandings with other business parties to fix prices; boycott specific suppliers or customers; allocate products, territories or markets; or exchange competitively sensitive information; as well as discussions regarding price, trade allowances or rebates, costs, competition, marketing plans or studies, production plans and capabilities or any other confidential information.
	Bullying, Discrimination or Harassment	Uninvited and unwelcome verbal or physical conduct directed at an employee because of his or her sex, religion, ethnicity, or beliefs. (Examples include: bias in hiring, bias in assignments, wrongful termination, bias in promotions, bias in educational decisions, unfair compensation, inappropriate language).
	Confidentiality and Misappropriation	Confidentiality refers to the protection of the Company's and our customer's non-public information and use of such information only for legitimate business purposes. Misappropriation refers to the unauthorized or improper use of a third party's intellectual property rights, including patents, trademarks, copyrights and trade secrets.
	Conflict of Interest	A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations)
	Data Privacy	Refers to the technical, contractual, administrative and physical steps taken by the Company to protect against unauthorized access to and disclosure of personally identifiable data of employees and customers and other third parties that we possess.
	Disclosure of Confidential Information	Unauthorized and unlawful disclosure of corporately owned intellectual property or trade secrets, as well as employee, customer or consumer information, marketing and other corporate databases, marketing plans, business proposals and strategies.
	Embezzlement	To appropriate (as property entrusted to one's care) fraudulently to one's own use. (Examples include: bookkeeping errors, misapplication of funds, and mishandling of cash)
	Employee Relations	Any act or omission, which is perceived to be detrimental to the physical or mental well-being of an employee.
	Environmental Protection, Health or Safety Law	Violation of any environmental law, regulation, corporate policy or procedure with respect to the handling and disposal of hazardous materials or the health and safety of other individuals.
	Export Control Violation	Violations of export control regulations including both physical exports and deemed exports.
	Falsification of Contracts, Reports or Records	Falsification of records consists of altering, fabricating, falsifying, or forging all or any part of a document, contract or record for the purpose of gaining an advantage, or misrepresenting the value of the document, contract or record.
	Foreign Corrupt Practices Act Violations	Violations of the FCPA include (i) bribery of a foreign official (including persons employed directly by a foreign government, persons employed by commercial enterprises owned or controlled by foreign governments and private persons who have responsibilities similar to those of governmental employees) and (ii) making false or misleading entries on a company's books for any purpose.
	Gifts and Entertainment	Refers to the inappropriate offering, solicitation or accepting of items of more than nominal value from vendors, customers or other third parties in a capacity as an employee of the Company.
	Government Contracts	Failure to comply with applicable government, state, province or local laws and regulations or contractual obligations relating to government business or government agencies, including any work that does not comply with bidding rules, contract terms, or applicable regulations and any improper dealings with a government employee or a former employee.
	Improper Supplier or Contractor Activity	Supplier or contractor activity in violation of corporate policies and procedures; improper supplier or contractor selection based on personal gain, improper negotiation or diversion of contract awards.
	Improper Use of Intellectual Property	Unauthorized and unlawful disclosure of confidential information including inventions, research and technical data, formulas, discoveries, designs, improvements, ideas, manufacturing directives, computer programs, trademarks, patents, copyrights, unpublished financial or pricing information and all related documentation.
	Insider Trading or other Securities Violations	Infringement, transgression; specifically: an infringement of the rules which securities acts define.
	Misleading Sales, Marketing & Advertisement	False, misleading or deceptive advertising, packaging, point of purchase displays or promotional materials, deliberately misleading messages, omissions of important facts or false claims about the Corporation’s or competitors’ products.
	Misuse of Assets or Services	Use of Company resources or equipment without permission for non-business reasons.
	Offensive or Inappropriate Communication	The use of inflammatory, derogatory, unduly critical or insulting communication to an employee.
	Retaliation	Verbal, physical or written discriminatory or harassing behavior toward an individual who has made a good faith report regarding a compliance issue.
	Safety	Failure of meeting requirements needed to perform all duties in a secure environment. Potential areas of harm. (Examples include: environmental damage, OSHA, EPA, supervisor directive, poor housekeeping). Violence is an expression of the intention to inflict evil, injury, or damage to a person or their property. (Examples include: direct, veiled, conditional, violent)
	Securities Violations	Infringement, transgression; specifically: an infringement of the rules which securities acts define. (Examples include: insider trading)
	Sexual Harassment	The making of unwanted and offensive sexual advances or of sexually offensive remarks or acts, especially by one in a superior or supervisory position or when acquiescence to such behavior is a condition of continued employment, promotion, or satisfactory evaluation.
	Substance Abuse	Substance abuse is defined as the misuse of both legal and illegal drugs including alcohol. (Examples include: cocaine, narcotics, marijuana, stimulants)
	Theft	The act of stealing; specifically: the felonious taking and removing of personal property with intent to deprive the rightful owner of it.
	Time Abuse	Concerns about an employee or manager who is falsifying his/her work hours.
	Unfair Trade Practices, Deception and Fraud	Includes practices such as misrepresenting, creating misleading impressions, omitting important facts or making false claims about the Company's or its competitors' product or service offerings, as well as bribery and other similar exploitive or inequitable conduct.
	Unsafe Working Conditions	Failure of meeting requirements needed to perform all duties in a secure environment. Potential areas of harm. (Examples include: environmental damage, OSHA, EPA, supervisor directive, poor housekeeping)
	Violation of Policy	Willful or innocent actions that are in direct violation of company policy, procedures, code of conduct, and/or implied contractual responsibilities. (Examples include: non-disclosure agreements, hiring standards, safety, Internet usage, corporate guidelines)
	Workplace Violence	A verbal or physical threat of bodily harm to any person currently working or anyone who will be returning to work, allowing the individual who made the threat to carry out the threat.
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