CODE OF

ETHICS
2018

ABS | CODE OF ETHICS 2018 | i

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ABS MISSION
The mission of ABS is to serve the public interest as well as the
needs of our members and clients by promoting the security of
life and property and preserving the natural environment.

ABS GROUP MISSION

The mission of ABS Group of Companies is to be a leading
global provider of technical services that better enable our
clients to operate safely, reliably, efficiently, and in compliance
with applicable regulations and standards. We are focused
on adding value to the industries we serve and strategically
capturing synergies with ABS.
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TABLE OF CONTENTS
Who Must Follow the Code?............................................................................................... 1
Our Guiding Principles.......................................................................................................... 2
Using the Code........................................................................................................................ 3
Reporting and Non-retaliation Policy............................................................................. 4
Treating One Another Fairly............................................................................................... 6
Disclosing Conflicts of Interest.......................................................................................... 8
Complying with Economic Sanctions, Import and Export Laws
and Anti-boycott Laws................................................................................................... 11
Avoiding Corrupt Practices................................................................................................14
Money Laundering.................................................................................................................16
Offering and Accepting Gifts............................................................................................17
Protecting Information and Assets............................................................................... 20
Ensuring Data Protection and Privacy..........................................................................22
Competing Fairly in Accordance with Industry Standards...................................25
Maintaining Good Financial Controls............................................................................ 27
Focusing on Safety and Environmental Awareness................................................29
Investing in Our Communities...........................................................................................31
Ethics and Compliance Resources.................................................................................33
MESSAGE FROM THE CHAIRMAN
One of our most important assets at ABS
and ABS Group is our reputation for ethical
and reliable service. It affects every aspect
of our business and operations. Whether
we are providing classification services,
assisting clients with asset integrity and
reliability, certifying systems or processes, or
engaging in any number of other tasks, the
industries we serve count on us to provide
an independent and impartial view that
can be trusted.

We trade on our integrity. Each of us is

personally responsible for maintaining the
credibility of this organization. We must,
at all times, operate at the highest level of
integrity. And we must continue to build
on the trust and loyalty we have cultivated
over the years with our clients.

Within the Code of Ethics you will find

the standards and practices that form the
foundation for conduct based on integrity.
This is your guide to fulfilling your ethical
and legal responsibilities as an employee of ABS or ABS Group. This document also
establishes guidelines for interacting with one another as well as clients, stakeholders and
competitors. We expect every member of our team to follow the Code.

If you have any questions regarding the information in this document, I encourage you
to reach out to your supervisor or contact a member of the Ethics and Compliance team.
An open dialogue regarding ethical behavior is a cornerstone of our organization. This
includes the freedom for any employee to raise concerns about possible infractions of the
Code, in good faith, without fear of retaliation.

A strong commitment to ethics and integrity is not just good business – it is part of the
fabric of who we are as an organization and as individuals – the Spirit of ABS. Our clients
trust us to be their partner. We trust one another to operate according to the highest
standards of conduct. It is our commitment to ethics and integrity that has laid the
foundation for past and future success, to the benefit of us all.

Sincerely,

Christopher J. Wiernicki
Chairman of ABS and ABS Group of Companies
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WHO MUST FOLLOW THE CODE?

The short answer is: everyone. The Code of
Ethics is applicable to all employees of ABS and
PENALTIES FOR VIOLATIONS
its affiliates, including ABS Group of Companies
(the Company). The Code also applies to third Employees who fail to comply
parties who work on behalf of the Company, with the Code are subject to
such as agents, independent contractors and disciplinary action, up to and
other non- employee representatives.
including termination of
employment.
Officers, supervisors and other management
personnel are responsible for enforcing the
Code within their specific areas of supervisory
responsibility. This responsibility includes a
commitment to review the Code with their employees to make sure they understand
its provisions, and to encourage open communication about the Code, including raising
questions and compliance concerns.

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OUR GUIDING PRINCIPLES

Our day-to-day business is guided by three principles: integrity, good faith and excellence.

INTEGRITY comes from consistently behaving according to a set of values and ethics. We
are committed to maintaining the highest level of ethical conduct in all of our actions,
wherever we operate throughout the world. This commitment includes complying with
all laws and regulations.

GOOD FAITH is inherent in all of our dealings. Whether working with colleagues,
customers, vendors, representatives of government agencies or other parties, we will
always demonstrate respect, sincerity, honesty and impartiality. Our pledge to always act
in good faith preserves our reputation as a trusted business organization that serves the
public good.

EXCELLENCE and its pursuit are fundamental to the success of our business. Through our
company-wide commitment to excellence, we strive to meet our customers’ needs while
serving the best interests of our surrounding communities and the public at large.

These principles are the foundation of the Code of Ethics, which helps define who we are
as a company. By incorporating them into everything we do, our Company will be strong
and successful and recognized as a valued business partner.

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 What would you do?

COMPLIANCE COUNTS When faced with a

difficult situation that is
not specifically covered in
the Code, use your good
judgment and common
USING THE CODE sense. Ask yourself the
following questions:
The success of our Company depends on every individual’s
• Am I uncomfortable
commitment to strive for the highest standard of ethical
with what I am being
business conduct at all times.
asked to do? Does it
violate any law or
The Code serves as a blueprint for doing what is right
regulation?
and for acting ethically and in compliance with the law,
no matter where we conduct business. It is not a book • Is the action consistent
of instructions but rather a set of guidelines created to with Company policies?
highlight ethical standards and protect our Company’s • Is it consistent with
reputation as we conduct business worldwide, across the Company’s guiding
different countries and different cultures. principles?
• Could it put the
Although the Code cannot address every possible scenario
Company’s reputation at
you could encounter, it will support you in making ethical
risk?
decisions and understanding when and how to seek
additional guidance. • How would I feel if the
situation was reported
Where local laws, cultures or customs differ from the in a newspaper or on a
principles and standards established in the Code, you news website?
should seek guidance from Ethics and Compliance. • Would I want my family
to know about it?
• Before acting, would I
THE CODE PROMOTES
feel more comfortable
• The highest level of honest and ethical conduct talking through my
concerns with my
• Protection of confidential and proprietary information
supervisor?
• Compliance with applicable laws, rules and regulations
• Would I want someone
• Open communication and prompt reporting of to treat me in the same
violations way that I would be
• A culture of mutual respect acting?

If something seems
unethical or improper,
it probably is. If you are
unsure of what to do,
don’t guess. Play it safe
and ask before acting.
Seek assistance from your
supervisor or Ethics and
Compliance.

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REPORTING AND
NON-RETALIATION POLICY
Open communication about the Code is fundamental to its integration into our culture
and daily activities. We encourage employees to discuss ethics openly with their peers and
to seek advice from supervisors and other managers about the right course of action when
a questionable situation arises.

Supervisors have a duty to provide guidance in ethical business conduct, and their
doors should always be open. However, if you do not feel comfortable approaching
your supervisor, you can report your concern or discuss your question with Ethics and
Compliance.

REPORTING CONCERNS
Each of us has a duty to report illegal or unethical conduct within our workplace.
Reporting concerns and asking questions is fundamental to following our Code. The
Company takes all reports of misconduct seriously. Your identity and the information you
provide will be shared only to the extent necessary with those responsible for addressing
the concern.

To report a concern, the best place to start is generally with your supervisor. Remember,
it is your supervisor’s job to help solve problems. But if you are not comfortable speaking
directly with your supervisor, there are several other options available to you.

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 Can I remain anonymous
when I report my concerns?
EMAIL
Send an email to the following account:
[email protected] When you call the
Each message will be addressed by a member EthicsPoint Hotline or
of Ethics and Compliance. submit a concern via the
web, you may choose to
PHONE remain anonymous. As
The EthicsPoint Hotline is a toll-free number long as maintaining your
(1-866-293-1461) managed by EthicsPoint, Inc. anonymity does not conflict
It is available 24 hours-a-day, seven days-a-week. with local laws, your
If you are calling from outside the United States request will be honored.
and Canada, please visit the EthicsPoint website However, we encourage
(www.abs.ethicspoint.com) for a list of toll-free numbers you to identify yourself
for other countries. because that will make
it easier to review your
ONLINE concerns. The Company will
Submit a concern electronically on the EthicsPoint website investigate each concern,
(www.abs.ethicspoint.com). and you anonymity will be
maintained to the fullest
MAIL extent possible.
Send a message by mail to:
Ethics and Compliance
ABS Plaza
What can I expect when
16855 Northchase Drive
I call the EthicsPoint
Houston, TX 77060 USA
Hotline or submit an online
concern?
Confidentiality will be maintained
to the fullest extent possible.
When you call the
NON-RETALIATION POLICY
EthicsPoint Hotline, your
Our Company is committed to fostering an ethical culture
call will be answered by a
in which individuals feel comfortable making reports or
third party who will listen
raising concerns regarding illegal or unethical conduct
to your concerns and ask
without fear of retaliation. Retaliation occurs when
negative action is taken against an employee because he you follow-up questions.
or she made a good faith report or raised a good faith Your report will be made
concern about possible illegal or unethical conduct in available only to specific
the workplace. Adverse treatment of individuals who individuals within the
raise concerns in good faith is a violation of both our Company who are charged
Code and our ethical principles and will not be tolerated. with addressing the
Any individual who retaliates against someone who concern. Following your
has made a report or raised a concern in good faith is conversation or online
subject to discipline, up to and including termination of submission, you will be
employment. given a unique password.
This will enable you to get
If you feel you have been subject to retaliation for
an update on the status
raising a concern or making a report regarding illegal
of your report and/or
or unethical conduct, contact Ethics and Compliance
immediately. communicate additional
information or concerns.

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TREATING ONE ANOTHER FAIRLY

We are committed to fostering a culture that encourages mutual respect and the
promotion of diverse ideas and perspectives. Our commitment to respectful behavior
extends beyond the Company’s walls and includes everyone with whom we interact in the
course of business. All supervisors and other members of management are responsible
for maintaining a workplace atmosphere that promotes mutual respect, diversity and
freedom from all forms of harassment and discrimination.

HARASSMENT
The Company prohibits all forms of harassment including sexual harassment and other
hostile behavior, such as bullying and intimidation. Harassment – whether verbal, visual
or physical – has the potential to harm an individual as well as interfere with his or her
work performance.

The Company will not tolerate harassment of or by any employee or individual with
whom we do business. Anyone who participates in any form of harassment will be subject
to disciplinary action, up to and including termination, whether or not the inappropriate
conduct constitutes a violation of law.

Some examples of harassment include:

• Derogatory comments based on racial or ethnic characteristics
• Unwelcome sexual advances or requests for sexual favors
• Displaying sexually explicit pictures, cartoons or other materials
• Offensive remarks or jokes and lewd behavior, including vulgar or profane language
• Any form of physical threat or physical intimidation

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 I recently went out
for dinner with a
• Unsolicited questions about a person’s sex life or sexual
few co-workers
orientation
following our first day
• Demeaning comments about a person’s appearance of a week-long offsite
• Using patronizing titles or nicknames, especially training seminar. One
relating to a person’s age, race, sexual orientation or of my co-workers said
disability some offensive things
that made me really
• Spreading malicious rumors or insulting someone
uncomfortable. Even
directly
though this didn’t
• Making threats or comments about a person’s job happen at the office,
security without good reason should I still report it?
• Any conduct that denigrates, ridicules, intimidates or is
physically abusive to an individual or group
Yes, you should report
DISCRIMINATION this conduct to your
The Company does not discriminate against any supervisor or any other
employee, or applicants for employment, based on member of management.
personal characteristics such as: You may also report
the conduct to Human
• Race • Color
Resources and Ethics
• National origin • Gender and Compliance. Even
• Age • Physical or mental disability though this conduct did
• Marital status • Sexual orientation not take place during a
traditional work day, our
• Gender identity • Veteran status
Company’s commitment
• Citizenship status • Religion to mutual respect
• Transgender status • Creed extends beyond what
happens in the office.
The Company is firmly committed to providing equal It also covers all work-
opportunity in all aspects of employment and personnel related settings, such
practices, including recruitment, advancement, salary and as business trips and
benefits, termination and retirement processes.
business-related social
events.

TAKEAWAYS

• Respect all employees, clients and business partners.

• Be sensitive to how your behavior may affect those around you. Never tell jokes
that may offend someone else.
• Consider your actions and put yourself in the other person’s position.
• Speak up if you find someone’s actions offensive or hostile.
• Report issues to your supervisor, other management, an HR representative or
Ethics and Compliance if you experience or are aware of any act of discrimination
or harassment.
• Seek guidance from an HR representative or Ethics and Compliance if in doubt
about the appropriate action to take.

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DISCLOSING CONFLICTS OF INTEREST

All employees have a responsibility to act in the Company’s best interest. A potential or
actual conflict of interest arises when an employee’s personal interests conflict, or appear
to conflict with his or her objectivity and loyalty to the Company. For example, conflict of
interest may arise when an employee has a close personal, family or business connection
to an individual or company that is one of our customers, contractors or suppliers.

Although the Company encourages its personnel to succeed as both professionals and
individuals, it is important to make every effort to avoid conflicting business loyalties.
Where a situation arises that could be or appear to involve a conflict of interest, you must
disclose it to Ethics and Compliance for appropriate action.

Employees must inform the Company about all conflicts of interest, not only those that
currently exist, but also those likely to occur in the future.

If you need to disclose a potential or actual conflict of interest, you must promptly
complete and submit a Conflict of Interest Statement to your supervisor and Ethics and
Compliance. You can find a copy of this form on the Company intranet under Ethics and
Compliance. Each form will be reviewed by the appropriate individuals at the Company to
determine whether a conflict exists. You will be informed about the outcome and whether
further action is required.

Although this Code provides guidance on conflicts of interest, it is not possible to list
every type of conflict or potential conflict than can arise. Employees need to be aware
of and avoid situations in which such conflicts may arise, including the situations
described below.

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 I was recently asked to join
the board of directors of
FINANCIAL INTERESTS
a small start-up company.
Conflicts or potential conflicts of interest may arise Is it okay to accept this
when you or your immediate family, other household position as long as I
members, relatives by marriage or close personal friends participate only during my
have a financial interest in a company that has a business free time?
relationship (or is looking to do business) with our
Company, competes with the Company or has interests
that may be substantially affected by the performance
That depends. When
of your responsibilities for the Company. Avoid any type
determining whether
of financial interest that may affect your loyalty to the
Company. outside activities are
appropriate, the Company
FAMILY AND PERSONAL RELATIONSHIPS will consider a number
of factors. These include
Conflicts or potential conflicts of interest may occur
when you have a familial or close personal relationship not only the time
with an individual who does business (or is looking commitment the position
to do business) with or competes with the Company. requires and your ability to
Such conflicts can also occur when you supervise or are conduct the related work
supervised by someone with whom you have familial or outside of your regularly
close personal ties. Even if you feel that your business scheduled work time, but
relationship is entirely appropriate, the existence of also your position at the
a personal relationship can give other employees the Company, the nature of
impression of favoritism. For this reason, if you have a the outside company’s
familial or close personal relationship with anyone who business, its nonprofit or
works for the Company, you must submit a Conflict of
profit status and whether
Interest Statement to your supervisor and Ethics and
compensation is involved.
Compliance.
You must submit a Conflict
OUTSIDE EMPLOYMENT AND ACTIVITIES of Interest Statement to
your supervisor and Ethics
Outside employment and activities, including consulting
and Compliance.
activities, can create a conflict of interest or the
appearance of a conflict. This is especially true when the
employment or activity is associated with a competitor,
customer or supplier of the Company or someone who is
looking to do business with the Company.

Outside employment can also create a conflict or

the appearance of a conflict if participation in the
employment or activity affects an employee’s ability to
devote his or her full time and energy, during working
hours, to regular assignments and responsibilities.

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My daughter is the vice
president of a small
You must avoid:
business that provides
services to the Company. • Accepting excessive gifts, hospitality, discounts or other
I was recently promoted benefits from a potential supplier or customer
and I may be asked to • Learning of a business opportunity the Company
approve invoices from my may be interested in pursuing and investing in that
daughter’s business. Is this opportunity personally or revealing it to third parties
a problem?
• Using corporate property, information or your position
within the Company for personal gain, including using
time on the job at ABS to manage other employment
Yes, because it represents or business
a potential conflict
• Competing with the Company in any way
of interest. You must
inform your supervisor • Using inside information for any type of personal gain
and submit a Conflict
of Interest Statement to Given the potential for these types of conflicts to arise,
the Company requires all employees to seek approval
Ethics and Compliance
when considering outside employment and activities.
so the conflict can be
This applies equally to prospective new employees with
avoided. Even if you feel
existing outside activities and positions that they propose
that you would act entirely to maintain.
appropriately, you cannot
approve invoices from your
daughter’s company.
TAKEAWAYS

• Act in the best interest of our Company

and never let personal interests interfere or
appear to interfere with your ability to make
sound, objective business decisions.
If one of my relatives or
• Disclose any outside jobs and affiliations
a close friend works for a
with customers, competitors, or suppliers
customer of the Company,
to your supervisor and to Ethics and
do I need to disclose this
Compliance by completing a Conflict of
information?
Interest Statement.
• Ask yourself whether your personal interests
Even if you do not work could interfere with those of our Company.
directly with your relative Even if private interests do not affect your
business decisions, you should consider
or friend, you should
whether others may perceive it that way.
disclose any situation
that could create even the • Withdraw from decision-making that creates
appearance of a conflict or could appear to create a conflict of interest
until you are sure that none exists.
of interest. If you find
yourself in a situation • Seek advice from your supervisor and Ethics
where you would be and Compliance if you are unsure of the
working directly with the appropriate action to take.
relative or friend, you must
bring it to your supervisor’s
attention and submit
a Conflict of Interest
Statement to Ethics and
Compliance.

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COMPLYING WITH ECONOMIC SANCTIONS,

IMPORT AND EXPORT LAWS AND
ANTI-BOYCOTT LAWS
Our Company offers services all over the world. It is our responsibility to observe all
national and international laws that apply to our global business operations.

Complying with international trade laws and regulations is a challenge we face daily.
Understanding the responsibilities each of us has is critical.

Many countries restrict or regulate exports and trade activities with other countries,
entities and individuals. Violating these laws can have serious consequences, including
significant fines and/or imprisonments.

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US AND INTERNATIONAL ECONOMIC SANCTIONS
The US applies trade sanctions to promote national security or advance foreign policy.
These sanctions prohibit companies from conducting business with certain countries,
individuals or entities. Similarly, trade sanctions imposed by other organizations, such
as the European Union or the United Nations, may also restrict our ability to conduct
business. As a global corporate citizen, the Company fully complies with legal trade
restrictions on our international business.

TAKEAWAYS

• Keep up to date with US and other sanctions by reviewing online training

materials, participating in live training and reading local and international
news.
• Be aware. Sanctions can target entire countries, as well as specific entities and
individuals in otherwise unsanctioned countries.
• Never deal with sanctioned entities.
• Reach out to your supervisor or Ethics and Compliance if you are unsure about
whether a sanction violation has occurred.

US EXPORT CONTROL LAWS

The US Government controls the export of sensitive equipment, software and technology
to protect US national security interests. Although most people think of imports and
exports in terms of the movement of physical goods, imports and exports also include the
transfer of information, intellectual property, software and technology to unauthorized
persons or across international borders. This means that sending an email, discussing
technical specifications in public, providing a service, or giving a company tour could
result in violation of US law. Employees are expected to understand and comply with all
export controls and trade restrictions.

TAKEAWAYS

• Obtain proper permission before exporting or importing goods, technology,

software or services across national borders.
• Make accurate, truthful and complete declarations in connections with imports
and exports.
• Keep up to date with changing import and export rules in the country where
you work.
• Reach out to your supervisor and Ethics and Compliance if you are unsure of
whether import or export laws may have been violated.

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ANTI-BOYCOTT LAWS
Some countries adopt boycott laws which try to prohibit companies from conducting
business with individuals and companies in designated countries. For example, a purchase
order, tender, contract or letter of credit might prohibit the use of goods or services from a
specific country or from persons or companies on a “blacklist.” In the US, it is against the
law for companies to participate in boycotts that the US does not support. The Company
complies with all trade sanctions imposed by the US and strictly adheres to all anti-
boycott laws. We expect employees to understand and comply with all applicable laws.

TAKEAWAYS

• Never comply with requests to cooperate with unlawful boycotts.

• Read carefully and understand business correspondence, including tenders,
contracts, letters of credit, procurement or shipping documents.
• Report any doubtful activity or correspondence to Ethics and Compliance
• Reach out to your supervisor and Ethics and Compliance if you are unsure
whether an unlawful boycott is taking place.

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AVOIDING CORRUPT PRACTICES

Our pledge to live by our values of integrity, good faith and excellence mandates a
commitment to fair dealing and avoiding corrupt practices in all of our actions. Our policy
is to do business on the basis of quality, service, delivery and price and to live up to the
highest ethical standards. Bribery means giving, offering or promising anything of value
to gain an improper business advantage. The Company prohibits offering, promising,
making, authorizing or accepting a payment or anything of value to or from anyone to
obtain an improper business advantage. We expect this same commitment from all of our
agents, contractors, consultants and business partners. We make no distinction between
bribing a government official and bribing a private official in the commercial sector.

Most countries consider providing gifts or services in an effort to induce an official to

violate the public trust as a criminal act of bribery. For example, the US Foreign Corrupt
Practices Act (US FCPA) provides criminal penalties of up to five years in prison and up to
a $250,000 fine for individuals and fines of up to $2 million for corporations. Furthermore,
the government may seek penalties equal to two times the gain obtained by the bribe. In
addition to criminal penalties, the public reaction to bribery and corruption can be very
damaging to the Company’s reputation and the individual’s career.

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 I have heard that in some
instances it might be
For more information, please consult the following
acceptable to offer a small
Policies located on the Company intranet under Ethics
payment to a low level
and Compliance.
government official to
expedite a routine activity.
• Anti-bribery Policy Is this true?
• Travel and Hospitality Policy for Non-employees
• Meals and Entertainment Policy for Non-employees
Some laws (including
• Gift Policy for Non-employees the US FCPA) permit the
• Facilitating Payments Policy payment of small sums
• Conducting Business with Government Officials to low-level officials to
Policy expedite or secure the
• Charitable Contributions Policy performance of certain
routine, nondiscretionary
• Due Diligence Policy
government functions.
These are sometimes called
“facilitating payments.”
TAKEAWAYS The Company makes
no distinction between
• Comply with Company policy and all anti-bribery facilitating payments and
and anti-corruption laws, including the FCPA and
bribes. Company policy, as
UK Bribery Act.
well as many non-US laws
• Report bribery or corruption immediately to your that apply to the Company
supervisor and Ethics and Compliance, regardless (including the UK Bribery
of the parties involved.
Act) strictly forbid
• Accurately record and fully disclose transactions facilitating payments. The
in which a bribe has occurred. Company takes violations
• Never offer or accept anything of value meant to of this policy very seriously.
improperly influence business decisions.
• Immediately report any instances where a bribe is
offered or accepted to your supervisor and Ethics
and Compliance.
• Consult with your supervisor and Ethics and
Compliance when in doubt about what is
considered a bribe.

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MONEY LAUNDERING
Money laundering is the process by which individuals or entities disguise the proceeds
of criminal activity by making it appear legitimate. To avoid engaging in acts of money
laundering, we must strictly follow Company payment procedures and report any
irregular payments or refund requests to senior management and Ethics and Compliance.

Red flags to consider include:

• Payments made in currencies other than those specified in the invoice.
• Any request to make overpayments or underpayments.
• Attempts by business partners to make payments in cash or cash equivalents.
• Unapproved payments by or to someone not a party to the contract.
• Use of an irregular bank account for the business relationship.

TAKEAWAYS

• Familiarize yourself with Company payment procedures.

• Watch for irregular payments or refund requests.
• Promptly report any payment irregularities to your supervisor and Ethics and
Compliance.

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OFFERING AND ACCEPTING GIFTS

In general, all Company personnel must exercise caution when offering or accepting
gifts or benefits to or from anyone with whom the Company has a business relationship.
This is also true for anyone who is trying to establish a business relationship with the
Company, competes with the Company or has interests that may be affected by the
Company representative receiving or offering the gift.

You should not offer or accept gifts of cash or gifts that are excessive in value. If you
receive a gift and are unsure whether accepting it would be appropriate, immediately
disclose the gift to your supervisor and Ethics and Compliance.

PERMISSIBLE GIFTS AND ENTERTAINMENT

There are certain times when it is appropriate to accept or offer gifts or entertainment.
Acceptable gifts and entertainment include those that are reasonable in nature, related
to a clear business purpose and customary within that business purpose. You should
be confident that any gift or entertainment is appropriate and does not cast doubt on
your intentions. You must avoid even the appearance of impropriety when dealing with
business partners.

Permissible gifts and entertainment include those that are infrequent and modest in
value, such as:
• Business-related meals and refreshments where the cost is not excessive
• Modest forms of entertainment, such as sporting or theatrical events or outings with a
customer or supplier
• Advertising and promotional materials, such as pens, note pads, calendars, paperweights,
plaques or other items of modest and reasonable value that bear the Company logo or
commemorate a business event

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I was recently invited by a
customer to join a five-day
OFFERING GIFTS TO GOVERNMENT OFFICIALS
all-expense-paid golf-
outing at a luxury resort Many different laws and regulations (including the US
in Mexico. The customer FCPA and the UK Bribery Act) strictly limit the gifts and
assured me that we would other benefits that can be provided, directly or indirectly,
be able to “talk business” to government officials. It is, therefore, necessary to use
on the golf course and extreme caution when offering anything of value to or for
while eating dinner in the benefit of any government official.
the evenings. Would it
be permissible for me to Anti-corruption laws define “government officials” very
attend? broadly to include employees of government-owned
enterprises, relatives of government officials, employees
of private companies wholly or partially owned by a
Permissible gifts often fall government official or relative of a government official,
into a gray area. You may and employees of companies in which a government
participate in a round of official or government official’s relative holds an
economic interest.
golf in some cases. But the
circumstances you describe
When offering meals, entertainment or gifts to business
above, including the
partners, be sure they are:
duration of the proposed
• Modest in value
outing and the luxury
resort location, make • Infrequent in nature
accepting this particular • Not in the form of cash
invitation inappropriate
• Do not appear improper
• Permitted under the laws of the host country
• Customary, in type and value, in the host country
• Made at an appropriate time and in an appropriate
circumstance
• Given as a courtesy or token of respect or in return for
hospitality
• Provided openly, rather than secretly
• Accurately recorded in the Company’s accounts

18 | CODE OF ETHICS 2018 | ABS

 I have recently been
asked to present at an
It is important to ensure compliance with all laws
educational conference
governing public and foreign officials. Before you make
and the sponsoring vendor
any payment or offer any gift or benefit to a government
has offered me $500 for
official, directly or indirectly and regardless of the
my participation. May I
individual’s rank, title or level or the amount or purpose
accept this payment?
of the payment, gift or other benefit, you must obtain the
written approvals of Ethics and Compliance and an officer
of the Company with line responsibility for the applicable
territory. Honorariums, or fees
offered for presenting
at or participating in
certain educational
TAKEAWAYS conferences, may be
accepted by employees,
• Never give or receive any gift that may officers and directors
inappropriately influence a business decision. when participating solely
• Ask yourself the following questions: for personal reasons and
not as a representative
– Is the gift or entertainment customary for the
relationship or is it intended to influence a of the Company. If
business decision? the presentation or
participation relates to
– Is the gift modest or could it create an
a business purpose, the
obligation?
payment must be declined.
– Would I be embarrassed if someone else
became aware of the gift or entertainment?
If the sponsor persists in
offering the honorarium,
donate it to charity
consistent with the
Charitable Contributions
Policy located on the
Company intranet under
Ethics and Compliance.

ABS | CODE OF ETHICS 2018 | 19

 COMPLIANCE COUNTS
COUNT ME IN

PROTECTING INFORMATION AND ASSETS

Protecting the Company’s assets is everyone’s responsibility. These assets include physical
assets (such as buildings, inventory and office supplies), as well as financial assets,
information assets and intellectual property. As a general rule, Company assets should be
used only for business purposes.

Limited personal use of Company assets is permitted in some situations (for example,
making a personal phone call or checking an email on a Company-issued smartphone) as
long as it does not get in the way of your business responsibilities.

CONFIDENTIAL INFORMATION
Safeguarding the confidential information of the Company, as well any confidential
information entrusted to us by our business partners is fundamental to the success of
our business and the preservation of our reputation. Such safeguards include never using
confidential information learned through the course of our work at the Company for
personal gain, such as to make investment decisions, offer investment recommendations
or “tips” or engage in “insider trading.” Furthermore, all work product, intellectual property
and confidential information developed by you while employed by the Company is
Company property.

Your duty to protect and safeguard confidential information exists during your
employment with the Company and continues even if you depart the Company.

20 | CODE OF ETHICS 2018 | ABS

 I was near the copy
machine in the Finance
Confidential information includes, but is not limited to:
department and found a
• Strategies • Business plans report that includes the
• Pricing schedules • Customer lists total revenue the Company
generated from certain
• Marketing plans • Controlled documents
customers last year. What
• Financial results and projections should I do?
• Inventions and technical information
• Intellectual property
Protecting confidential
The responsibility to protect and safeguard confidential information is the
information exists both during and after employment at responsibility of each
the Company. employee. You should
immediately take the
INTELLECTUAL PROPERTY report to management in
Like confidential information, the intellectual property the Finance department
of the Company and our customers is an invaluable to determine who left
asset. Safeguarding our intellectual property is crucial the report near the copy
to sustaining our success and reputation. Examples of machine and to reiterate
intellectual property include: the duty to protect the
• Plans • Drawings Company’s confidential
information.
• Specifications • Blueprints
• Calculations • Owners’ manuals
• Sketches • Methodologies
• Software and user documentation

You may disclose intellectual property to outside parties

only in accordance with Company policies. Similarly, you
should only share intellectual property with Company
personnel on a “need- to-know” basis.

TAKEAWAYS

• Protect our Company’s confidential information and the confidential

information with which we are entrusted by others. Do not disclose it unless
authorized to do so by an appropriate officer of the Company.
• Never disclose or use the confidential information or intellectual property of
others, including prior employers, without appropriate authorization.
• Guard Company physical assets and computing devices against theft or loss.
• Exercise caution when discussing Company information in public places, such as
restaurants, airports and coffee shops.
• Do not post on social media (“check-ins” “selfies” on client property, using
hashtags) anything that could compromise the confidentiality of the project,
information or client for which the Company is providing services.

ABS | CODE OF ETHICS 2018 | 21

 COMPLIANCE COUNTS
COUNT ME IN

ENSURING DATA PROTECTION AND

PRIVACY
Maintaining our reputation as a trusted employer and business partner mandates our
commitment to protecting all of the data that we access and possess, whether it pertains
to our employees, customers or business partners.

PROTECTING THE DATA OF OUR CUSTOMERS AND BUSINESS PARTNERS

Our customers and business partners entrust us with confidential data on a daily basis.
They expect that we will treat their information with sensitivity and use it only for
business purposes. Even within the Company, you should share customer data only as
necessary to perform your job. Our Company complies with the laws and regulations
that apply to the use and administration of personal information and data in all
countries where we do business.

PROTECTING THE PRIVACY OF OUR EMPLOYEES

Protecting the personal and private information of everyone who works for or on behalf
of the Company is an absolute. Occasionally, our Company collects sensitive information
about our employees, such as race or ethnic origin, medical information, criminal
behavior or trade memberships. Such information is only gathered, used and disclosed
on a business need-to-know basis or when required by law or court order. We respect
a person’s right to privacy and protect this acquired information from misuse. No one
may access prospective, current or former employee records without proper authority.
When personal information is no longer needed, the Company securely deletes, destroys
or makes anonymous any personal information collected.

22 | CODE OF ETHICS 2018 | ABS

 Why do we have
restrictions for social
We commit to using the highest level of care when
media?
handling employees’ personal information. The Company
works to ensure that only appropriate individuals have
access to employee personal and sensitive information
and that their collection, access to and use of this Social media activity
information is justified and meets applicable legal resides in the public
requirements. Furthermore, the Company works to ensure domain. Postings can
adequate protection of personal information that is be viewed, published or
transferred to third parties and/or across international discussed by any segment
borders. For more information about the Company’s data of the population,
privacy policy, see the Data Privacy Policy located on the including the media.
Company intranet.
The Company’s
PROTECTING OUR COMPANY’S REPUTATION communications with the
When information is shared online through social media media and other public
it may become public information. It is never appropriate entities are arranged
to use social media for business purposes or on behalf carefully to protect the
of the Company without proper authorization. When Company’s reputation
you use social media during personal time and for non-
and must be coordinated
business purposes use common sense. Understand that
appropriately.
your personal social networking activities can affect our
Company’s business interests and reputation. For more
information about the Company’s policy on social media, Employees should not post
see the Social Media Policy located on the Company conversations that are
intranet under Ethics and Compliance. meant to be pre-decisional,
internal, proprietary or
As part of our commitment to protecting confidential confidential about the
information, the Company requires that all Company or its customers.
communications with the public and media be carefully
coordinated with the ABS Senior Vice President of In addition, all employees
Marketing and Communications or the ABS Group must respect copyright
Director of Marketing. and financial disclosure
laws and always protect
PROTECTING OUR COMMUNICATION SYSTEMS
sensitive information,
The Company’s applications and communication systems, including the acquisition
including email, are integral to how we conduct all and use of personally
aspects of our business. It is essential for everyone to identifiable information.
maximize and protect these systems by using them
carefully and in accordance with Company policy.
Under no circumstance
may videos or photographs
When using computers and communication systems for
company business, remember the following: of customers’ projects
and employees engaged
• Use Company communication systems and computers
in business activities be
for appropriate purposes only
used without express
• Safeguard all mobile devices, such as laptops and prior written approval
mobile phones from loss or theft from ABS Marketing and
• Protect computers and phones by using encryption and Communications or ABS
passwords Group Marketing and
• Use strong passwords and never share them with Communications.
others

ABS | CODE OF ETHICS 2018 | 23

• Never view, download or distribute material that could be considered offensive or
illegal
• Do not open email attachments unless you know they are from a trusted source

Remember, misuse of these systems or even honest mistakes can damage the Company’s
reputation. The Company reserves the right to monitor the use of its communication
systems, including all content on those systems, except as restricted by applicable law.

PROTECTING COPYRIGHTS
It is against Company policy to copy, reproduce, digitize, distribute or use third-party
copyrighted material without permission from the copyright holder. If permission is
granted, employees must credit the source properly when using the material in Company
documents and products. Improper use of copyrighted material can lead to civil and
criminal penalties. Employees should forward questions regarding copyrights to the Legal
department.

Employees should also be aware of digital rights management practices to protect the
ownership and/or copyright of confidential Company content. Digital rights management
information includes but is not limited to copyright notices, watermarks, license keys,
encryption algorithms and embedded tags. It is a federal crime to alter, tamper with,
remove or circumvent digital rights management information or to use technology to do
any of the foregoing, even if an infringement does not occur. Digital rights management
practices include:
• Protecting confidential documents from being leaked outside or inside the Company
• Restricting the distribution of confidential documents to certain individuals or groups
based on job roles, titles and functions
• Controlling the printing, copying and editing of confidential documents
• Establishing time control access
• Changing usage rights after distribution
• Dynamically applying document usage rights to manage use online as well as offline
• Improving compliance via audits of activity logs throughout the document’s life cycle
• Encrypting and digitally signing electronic documents for distribution to customers

TAKEAWAYS

• Consult with Ethics and Compliance if I you are unsure whether you must obtain
Company permission before using or sharing confidential information.
• Seek advice from the Legal department about applicable laws and regulations
before transferring personal data to someone in another country.

24 | CODE OF ETHICS 2018 | ABS

 COMPLIANCE COUNTS
COUNT US IN

COMPETING FAIRLY IN ACCORDANCE WITH

INDUSTRY STANDARDS
Many countries, including the US, have laws that regulate competition. US Antitrust laws
and similar laws in other countries promote fair competition by prohibiting practices that
unreasonably restrain trade, restrict competition or fix prices.

The consequences for violating these laws are severe. Our promise to conduct business
fairly and with integrity includes a commitment to comply with all laws regulating
anti-competitive activity. This promise also includes a pledge to act with integrity in the
marketplace, never obtain information about competitors through inappropriate means
and never make false or misleading statements about competitors. You will find some key
principles and guidelines discussed below.

PROHIBITED AGREEMENTS WITH COMPETITORS

Never discuss or reach any formal or informal understandings or agreements with our
competitors about:
• Terms of sale regarding what is charged or paid, with representatives of other class
societies or competitors
• Company business plans
• Dividing or assigning territories or customers
• Customer lists and territory descriptions

ABS | CODE OF ETHICS 2018 | 25

A competitor has asked
about the Company’s
For more information about antitrust laws or policy,
pricing plans. How should I
review the Antitrust and Competition Policy located on
respond?
the Company intranet under Ethics and Compliance.

It is important to avoid exchanging confidential

The answer is always, “We information with competitors. This is especially critical
never discuss prices with when attending trade association meetings, such as
a competitor.” For more meetings of the International Association of Classification
information, consult the Societies, on behalf of the Company.
Antitrust and Competition
Policy located on the Keep these guidelines in mind when attending a trade
Company intranet under association meeting:
Ethics and Compliance • Discuss only items that are listed on the meeting
agenda
• Avoid discussions about current or future business
plans
• Immediately raise concerns in a way that will be
remembered if you believe an inappropriate discussion
is taking place. If the discussion continues after you
have raised your concern, leave the meeting and contact
Ethics and Compliance as soon as possible

TAKEAWAYS

• Treat all customers and suppliers honestly, fairly

and objectively.
• Avoid unfair or deceptive practices.
• Always present our services in an honest and
forthright manner.
• Immediately raise concerns at any trade
association meeting where anticompetitive
behavior is exhibited. If the behavior continues
after you raise concerns, leave the meeting and
contact Ethics and Compliance.
• Report any discussions or behavior that could be
considered anticompetitive.
• Seek the advice of Ethics and Compliance if you’re
unsure how to handle a situation.

26 | CODE OF ETHICS 2018 | ABS

 COMPLIANCE COUNTS
COUNT ME IN

MAINTAINING GOOD FINANCIAL

CONTROLS
Our customers and suppliers trust us to maintain good financial controls and
demonstrate accuracy and transparency in all of our accounting practices. Our
commitment to financial integrity includes maintaining our books, records and financial
statements, including time and expense reports, in accordance with legal requirements. It
also includes recording and reporting on our financial statements in an honest, accurate
and timely manner and ensuring that Company funds are disbursed only in accordance
with strict Company criteria.

It is everyone’s responsibility to watch for and avoid fraud, deliberate error or misleading
entries in our books, records and financial statements. If you believe that you have
identified false or misleading information or an error, whether intentional or not, you
must report your concerns to one of our Ethics and Compliance resources. The Company
takes concerns pertaining to financial integrity seriously.

All books and records must be accurate and up to date, regardless of whether you are
making entries and recording transactions or asking someone else to do so. Employees
must cooperate with internal investigations and audits and provide accurate and
complete information to the Company’s officers, Ethics and Compliance and Legal
personnel, auditors and any other person authorized to receive the information.

ABS | CODE OF ETHICS 2018 | 27

I overheard one of my co-
workers in the breakroom
PRACTICING GOOD RECORDS MANAGEMENT
talking about how his
department was having Good records management is an important part of our
a spectacular quarter. He Company’s commitment to integrity and ethical business
was saying something practices. All Company records, including both paper and
about “moving things electronic, must be maintained and/or destroyed in a
around” so the quarter careful manner. Our work with the US Government gives
would look really good. us additional responsibilities regarding the length of time
He was talking softly, and
we maintain records. In certain situations, for example,
I don’t think he knows
litigation or government investigations, the Company may
that I heard. Although I
be required by law to maintain specific records. You will
don’t know exactly what
he was talking about, it be informed if these requirements apply to you.
didn’t sound right. Is there
anything I should do? ACCURATELY REPORTING EXPENSES
Expenses can only be submitted for authorized business
purposes. Expense reports that are not properly approved
It sounds as if someone or that lack the required documentation may be rejected
in the Company might by the Accounts Payable department. This can delay the
be doing something that issuance of an expense check.
violates this Code. Our
books and records must be All expense reports must be approved before they are paid.
complete and accurately Obtain the approval of a supervisor or manager within
reflect all transactions. We your reporting line before submitting expense reports
encourage employees to to the Accounts Payable department. Supervisors and
question things that don’t managers outside of your reporting line are not permitted
make sense or that appear to approve your expense reports.
to be suspicious, even
when they don’t have all
of the facts. Talk to your TAKEWAYS
supervisor and contact
Ethics and Compliance to • Understand what records comprise information that
raise your concerns. must be properly reported, retained or destroyed.
• Seek advice from the Legal department if you
have any questions or concerns about document
retention or destruction issues.
• Ensure all records are complete, accurate,
understandable and timely.
• Follow all internal control procedures.
• Ensure all financial transactions are authorized by
management.
• Accurately record all expenses, assets, liabilities and
revenues.
• Never hide, alter, falsify or disguise the true nature
of any record or transaction.
• Cooperate fully with audits and investigations.
• Report immediately any accounting or auditing
irregularities, incidents of fraud or other
information that could make Company reports
inaccurate.

28 | CODE OF ETHICS 2018 | ABS

 COMPLIANCE COUNTS
COUNT US IN

FOCUSING ON SAFETY AND

ENVIRONMENTAL AWARENESS
Safety is core to our mission as a Company. We are committed to protecting the safety
of our employees and promoting the safety of our customers and the public at large in
all of our business practices. The Company has robust policies and procedures regarding
the importance of safety. We expect that everyone who works on behalf of the Company
will not only follow safety rules and policies at all Company and client locations but also
comply with all health and safety laws and regulations.

SAFETY IS EVERYONE’S RESPONSIBILITY

When it comes to safety, simply following the rules is not enough. We must constantly be
aware of safety concerns and committed to safe practices for everyone around us. If you
ever have concerns regarding a safety issue, report it to your supervisor or file an online
safety report. You may also consult with your Divisional Safety Director or assigned safety
liaison. Stop work immediately if continuing would be unsafe.

TAKEAWAYS

• Comply with the Company’s safety policies and procedures.

• Complete all assigned safety training.
• Stop work immediately if you encounter an unsafe working condition.
• Report all unsafe working conditions to your supervisor, file an online safety
report or consult with your Division Safety Director or assigned Safety liaison.

ABS | CODE OF ETHICS 2018 | 29

I have heard on numerous
occasions that employees
PREVENTING WORKPLACE VIOLENCE
should feel empowered to
“stop work” if concerned Maintaining a safe workplace also includes ensuring
about workplace safety or a workplace that is free from violence. The Company
environmental conditions, will not tolerate threats (whether implicit or explicit),
but I am worried about intimidation or violence in the workplace. The Company
repercussions. Can you also prohibits the possession of weapons and firearms,
offer some advice? including concealed licensed weapons, in the workplace.
Possession of firearms or unauthorized weapons in
Company or client offices may result in disciplinary
The Company considers action, up to and including termination, as well as
the safety and health of potential civil and criminal charges.
our personnel to be of the
utmost importance. We ask AVOIDING SUBSTANCE ABUSE
for your full cooperation Committing to safe business practices also means
in making this policy and avoiding substance abuse in the workplace at all times.
program truly effective. The Company strictly forbids the use of alcohol and
Under no circumstances illegal drugs in the workplace as these substances can be
are personnel who extremely harmful to the workplace and job performance.
exercise their stop-work Employees who take prescription medications must make
obligation to be subjected sure that they do not interfere with their job performance
to repercussions. or the safety of others.

If you observe a condition SUSTAINABLE ENVIRONMENTAL PRACTICES

or an act that could affect
Helping our customers reduce the environmental
the safety of personnel
impact of their businesses is core to our mission and
and/or the environment,
our business success. In addition, we must demonstrate
you should take the
this commitment in all of our business activities. That
following steps:
extends beyond complying with environmental laws and
• Take action and stop regulations and includes respecting the neighborhoods
work immediately and communities in which we work.
• Notify the supervisor in
charge and complete the
internal reports
• Discuss and/or
determine corrective
measures with all
involved
• Once the situation has
been corrected, you may
resume work

30 | CODE OF ETHICS 2018 | ABS

 COMPLIANCE COUNTS
COUNT ME IN

INVESTING IN OUR COMMUNITIES

We promote responsible business practices at every level of the Company and strive to
conduct business ethically and honestly. We believe integrity goes beyond complying with
applicable laws and regulations around the world. Even if something is technically legal, it
may not be the right thing to do.

CIVIC AND CHARITABLE ACTIVITIES

Part of our commitment to good corporate citizenship includes individual and corporate
participation in civic and charitable activities. We encourage everyone who works for the
Company to become involved in civic and charitable causes and applaud those who do so.
But it is important to make sure that the time devoted to these activities does not affect
your ability to fulfill your work responsibilities. It is also important, as with personal
political activities, to make sure that you do not represent your personal support of civic
and charitable activities as an endorsement by the Company.

Our Company does support charitable initiatives. All charitable contributions made on
the Company’s behalf are carefully reviewed and approved by the appropriate levels of
senior management, the Legal department and Ethics and Compliance consistent with
the Charitable Contributions Policy located on the Company intranet under Ethics and
Compliance.

ABS | CODE OF ETHICS 2018 | 31

My department would
like to donate surplus
POLITICAL ACTIVITIES AND LOBBYING
Company furniture and
equipment to a local We encourage everyone who works for the Company to
primary school. Are these fulfill their civic responsibilities, but we ask that you do
donations allowed? so on your own time and as permitted by local law. You
must be aware of and comply with all of the complex
laws, regulations and Company policies that govern
both corporate and individual political activities in the
It depends. Contributions
countries in which we operate. When engaging in political
to schools or local
activities, avoid any suggestion that your personal political
governments are the types views are the views of the Company.
of donation that play a
part in our community As a general rule, the use of Company facilities or
relations. However, they resources to conduct political activities is prohibited.
might be subject to Exceptions must be approved in advance by the Legal
local regulations. Before department. Any political contributions the Company
making or offering such a makes must be approved in advance by the appropriate
donation, you must always Company officers and the Legal department.
obtain approval from the
appropriate Company Lobbying activities are regulated. Although we may
engage in lobbying to support or oppose pending
officers as well as the Legal
legislation or other action to serve the Company’s best
department and Ethics and
interests, only certain individuals are authorized to
Compliance.
lobby on the Company’s behalf. Lobbying activities must
be monitored and approved by the appropriate senior
management.

32 | CODE OF ETHICS 2018 | ABS

 COMPLIANCE COUNTS
COUNT US IN

ETHICS AND COMPLIANCE RESOURCES

If you have questions about this Code or ethics and compliance in general, or if you want
to report a concern pertaining to suspected illegal or unethical behavior, please contact
Ethics and Compliance. The Company encourages open communication and the reporting
of concerns.

KNOW THE RULES

Make sure that you know and follow the Company’s requirements and comply with all
applicable laws and regulations.

MAKE THE RIGHT DECISIONS

Make sure you have all the facts needed to make the right decision. The goal is to
be as fully informed as possible. Discuss the problem with your supervisor. This is
the basic guidance for all situations. Your supervisor will be more knowledgeable
about the question or issue in many cases and will appreciate being brought into the
decisionmaking process. Remember, it is your supervisor’s responsibility to help solve
problems.

SPEAK UP AND VOICE YOUR CONCERNS

You may report ethical violations in confidence and without fear of retaliation. If your
situation requires that your identity be kept secret, your anonymity will be protected
to the fullest extent possible. The Company prohibits retaliation of any kind against
employees for reporting suspected illegal or unethical behavior in good-faith.

ABS | CODE OF ETHICS 2018 | 33

 EMAIL
Send an email to the following account:
[email protected].
Each message will be addressed by a member
of Ethics and Compliance.

PHONE
The EthicsPoint Hotline is a toll-free number
(1-866-293-1461), managed by EthicsPoint, Inc.
It is available 24 hours-a-day, seven days-a-week.
If you are calling from outside the United States
and Canada, please visit the EthicsPoint website
(www.abs.ethicspoint.com) for a list of toll-free
numbers for other countries.

ONLINE
Submit a concern electronically on the EthicsPoint
website (www.abs.ethicspoint.com).

MAIL
Send a message by mail to:
Ethics and Compliance
ABS Plaza
16855 Northchase Drive
Houston, TX 77060 USA

Confidentiality will be maintained

to the fullest extent possible.

34 | CODE OF ETHICS 2018 | ABS

THE SPIRIT OF ABS
We are guided by shared beliefs:

SAFETY
Our job is critical. What we do matters to the lives of people, the quality of the
environment, and commercial success around the world. We are vigilant in our
goals to improve safety practices, and minimize risk exposure and downtime.

INNOVATION
Solving problems is good. Anticipating problems is better. We do both through
continuous research and development focused on staying ahead of the curve.

INTEGRITY
Reputation matters. Clients depend on us as an impartial, objective resource.
In everything we do, we are honest, ethical and trustworthy.

TEAMWORK
The best safety solutions are achieved together. We work closely with our
stakeholders as a dependable, flexible and efficient partner. We are dedicated
to sharing our experience, and to contributing to the education of future
industry leaders.

PEOPLE
We have a global scope and a local presence. Our international workforce is
continuously trained to the highest level. We empower our people to make
local decisions.

QUALITY
Expect the best. When we set out to solve a problem, we do it right. We are
thorough and relentless perfectionists in the pursuit of safety.

RELIABILITY
You can count on us. We’re easy to reach and quick to respond. We deliver
practical, tailored solutions that exceed expectations.
CONTACT
INFORMATION
NORTH AMERICA REGION
16855 Northchase Drive
Houston, Texas 77060, USA
Tel: +1-281-877-6000
Email: [email protected]

SOUTH AMERICA REGION

Rua Acre, nº 15 - 11º floor, Centro
Rio de Janeiro 20081-000, Brazil
Tel: +55 21 2276-3535
Email: [email protected]

EUROPE AND AFRICA REGION

ABS House, No. 1 Frying Pan Alley
London E1 7HR, UK
Tel: +44-20-7247-3255
Email: [email protected]

MIDDLE EAST REGION

Al Joud Center, 1st floor, Suite # 111
Sheikh Zayed Road
P.O. Box 24860, Dubai, UAE
Tel: +971 4 330 6000
Email: [email protected]

GREATER CHINA REGION

5th Floor, Silver Tower
No. 85 Taoyuan Road, Huangpu District
Shanghai 200021, P.R. China
Tel: +86 21 23270888
Email: [email protected]

NORTH PACIFIC REGION

11th Floor, Kyobo Life Insurance Bldg.
7, Chungjang-daero, Jung-Gu
Busan 48939, Korea, Republic of
Tel: +82 51 460 4197
Email: [email protected]

SOUTH PACIFIC REGION

438 Alexandra Road
#08-00 Alexandra Point, Singapore 119958
Tel: +65 6276 8700
Email: [email protected]

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All rights reserved.

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