To ensure that Argos continues to conduct itself in a lawful manner and in full compliance with the antitrust laws, the following procedural safeguards must be followed by Argos’ employees when they are involved in trade association activities:

1. Prior to joining a trade association or attending any event hosted by a trade association, all employees are required to request and obtain approval from the Company’s Compliance Department by submitting an email to USCompliance@argos-us.com with all relevant details of the request, including:

   a) the name of the trade association or group;
   b) if available, a written agenda for each meeting and a list of expected attendees with their affiliations.

   2. Following each formal or informal meeting of a trade association or any of its committees, all documents (such as minutes) distributed at or after the meeting must be sent to and reviewed by the Company’s Compliance Department.
   3. Advance approval must be obtained from the Company’s Compliance Department before any documents, statistics, or other information are submitted to a trade association or shared among trade association members. The Compliance Department, in coordination with Legal, will determine whether (and in what manner) the documents, statistics, or other information may be submitted to a trade association.
   4. Employees attending trade association meetings must take special care to avoid discussing prices, pricing or sales strategies, costs, customers, and other competitively sensitive subjects with competitors. This applies both at regularly scheduled meetings and at social and informal gatherings associated with trade association meetings. If you find yourself inadvertently in a situation in which a competitor wishes to discuss such subjects, you should immediately and clearly decline to discuss them, excuse yourself from the meeting, and report the incident promptly to the Company’s Compliance Department.