Preserving a Culture of Integrity and

Safeguarding Our Reputation

We, leaders and team members across the APS organization, are individually and collectively responsible and accountable for preserving a culture of integrity and safeguarding the company’s reputation by maintaining APS’s financial, legal and service integrity.We fulfill this goal by upholding our core values in dealing with our key stakeholder groups: our employees, our customers, our business partners and suppliers, our shareholders, and the community at large. 

We strive to build an organizational culture that guides our actions and decision-making in a way that is rooted in what we consider to be fair and honest, and what promotes a dignified life for all people.

To achieve these goals, leaders must ensure that all employees in his/her constituency are made aware of their rights and commitments under this Code of Conduct and that APS’s values are upheld at all times. Each employee is responsible for ensuring that s/he fully understands the principles and ethical

guidelines that are enunciated in the Code and the related APS policies and regulations, in order to deal with ethical dilemmas that may arise. Where policies, procedures and internal controls do not offer clear guidance for a particular course of action, employees and leaders are expected to honor the spirit of the Code and/or to seek advice. 

The Code that follows provides only broad guidelines, and cannot cover all potential issues. It describes the standards of integrity to which we hold ourselves. Further, while these standards strive to establish the highest level of integrity, we recognize that various countries in which we operate may have laws and regulations that establish different requirements for corporate integrity. Whenever that is the case, APS foreign subsidiaries and employees are required to comply with all applicable local laws. 

We, leaders and team members across the APS organization, are individually and collectively responsible and accountable for preserving a culture of integrity and safeguarding the company’s reputation by maintaining APS’s financial, legal and service integrity.

We fulfill this goal by upholding our core values in dealing with our key stakeholder groups: our employees, our customers, our business partners and suppliers, our shareholders, and the community at large.

We strive to build an organizational culture that guides our actions and decision-making in a way that is rooted in what we consider to be fair and honest, and what promotes a dignified life for all people.

To achieve these goals, leaders must ensure that all employees in his/her constituency are made aware of their rights and commitments under this Code of Conduct and that APS’s values are upheld at all times. Each employee is responsible for ensuring that s/he fully understands the principles and ethical

guidelines that are enunciated in the Code and the related APS policies and regulations, in order to deal with ethical dilemmas that may arise. Where policies, procedures and internal controls do not offer clear guidance for a particular course of action, employees and leaders are expected to honor the spirit of the Code and/or to seek advice.

The Code that follows provides only broad guidelines, and cannot cover all potential issues. It describes the standards of integrity to which we hold ourselves. Further, while these standards strive to establish the highest level of integrity, we recognize that various countries in which we operate may have laws and regulations that establish different requirements for corporate integrity. Whenever that is the case, APS foreign subsidiaries and employees are required to comply with all applicable local laws.