Swiss Water Decaffeinated Coffee Income Fund - Code of Business Conduct

This Code of Business Conduct applies equally to all Trustees, Directors, officers and employees of Swiss Water Decaffeinated Coffee Income Fund (the “Fund”) and Swiss Water Decaffeinated Coffee Company (the “Company”, and together with the Fund, “Swiss Water”) regardless of their position within the organization.

Throughout this document the term “employees” refers to individuals employed by Swiss Water and also refers to Directors and Trustees. Officers are senior management personnel holding such titles as President and Chief Executive Officer and Chief Financial Officer.

This Code of Business Conduct has been approved by the Trustees of the Fund.

Respecting the rights of others

Rights of Swiss Water’s Employees

Management of Swiss Water makes decisions regarding hiring and promotion of employees on the basis of merit and in accordance with applicable provisions contained in collective agreements and human rights legislation.

Employees have the right to pursue their careers at Swiss Water free from discrimination and harassment based on any ground prohibited by law, including age, sex, race, colour, religion, creed, national origin, citizenship, language, marital status, family status, pregnancy or childbirth, sexual orientation, disability or political belief.

No personal relationship between an employee and any other employee shall compromise, or appear to compromise, the principles defined by this policy.

Swiss Water has developed specific policies which address employee rights. These include specific policies addressing diversity and harassment in the workplace.

Property rights

Swiss Water’s assets may, subject to limited approved exceptions, only be used for business purposes. Employees have a responsibility to ensure that Swiss Water’s assets are put to good use in enhancing unitholder value. All employees entrusted with managerial or supervisory responsibility are responsible for ensuring that appropriate policies, procedures and controls are put in place to safeguard these assets.

Customer rights

Customer relationships are critical to the continuing success of Swiss Water. In dealing with customers, employees will conduct themselves with fairness, courtesy and good faith. Employees must respect and ensure the confidentiality and privacy of customer personal information unless disclosure is required by law or order of a regulatory agency.

Suppliers rights

Relationships with suppliers must always be arms length, consistent with accepted business practices, Swiss Water policies and in accordance with applicable laws. In dealing with suppliers, employees of Swiss Water must conduct themselves with fairness, courtesy and good faith. All interactions with suppliers must conform to the requirements of the section of this policy addressing conflict of interest.

Environmental rights

Swiss Water is committed to environmental responsibility and stewardship.

Obeying the law

Swiss Water operates within a complex framework of federal, provincial, state and municipal laws. In addition to Canadian laws, Swiss Water is also subject to the laws and regulations of foreign countries in which it does business. Directors and employees are expected to comply with applicable laws and regulations of every jurisdiction where Swiss Water carries on business.

Confidentiality and Privacy

All assets, liabilities and transactions must be accurately and completely reported in Swiss Water’s books and supported by necessary documentation. No asset, liability or transaction is to be concealed from management or Swiss Water’s external auditors.

All transactions must be authorized and executed in accordance with the instructions of management. Appropriate accounting and financial policies, procedures, controls and audit processes must be maintained.

Employees, regardless of their position in the organization, are expected to follow internal policies and procedures designed to protect the integrity of corporate data and the confidentiality and privacy of all personal information to which they have access by reason of their employment with Swiss Water. This includes adherence to procedures related to security of computer systems.

Financial reports which are made available to the shareholders and the public are prepared in accordance with generally accepted accounting principles as well as applicable laws and regulations.

Swiss Water may have access to corporate or personal information which is sensitive or confidential. Information such as personnel records, payroll records, customer information, financial and competitive information is all confidential and in some cases, subject to protection by applicable privacy laws. Employees are required to use extreme care when dealing with confidential, personal or sensitive information. As a general rule, such information shall not be released to anyone inside or outside of Swiss Water who is not authorized or legally entitled to receive it, and shall not be used or disclosed for any reason except for legitimate business purposes.

Swiss Water will not disclose personal information about an employee to third parties without the employee's permission, unless required by law or order of a regulatory agency.

Avoiding conflicts of interest

A conflict of interest arises when an employee must choose between Swiss Water’s best interests or their own. Any situation where an employee's judgment may be compromised, where they show undue favouritism to any party, or where he or she receives a benefit of some kind is potentially a conflict of interest. All employees will strive to avoid situations that create a conflict, create the appearance of a conflict, or have the potential to create a conflict.

Use of insider information

The Fund’s Units are traded publicly. Trading of publicly listed securities on the basis of insider information is against the law, and can result in significant fines and even jail sentences. Insider information is generally considered to be any corporate information that has not been made public which, if known to the market, will likely cause share prices to either rise or fall. In the course of performing their duties, employees may become aware of or have direct access to such information. Sharing this information with anyone inside or outside Swiss Water or using it for personal gain by buying or selling Units of the Fund or any other publicly traded company is a serious breach of company policy and Canadian law. Supplying such information to other people is an offence, even if there is no personal gain to the employee.

Gifts and benefits

Receiving and giving gifts and benefits in a business context is a sensitive area which requires the exercise of good judgment and common sense. Employees should not accept gifts or benefits from any person, including customers, suppliers, business associates or companies who wish to do business with Swiss Water, if such gifts might be perceived as a bribe or appear to influence business decisions. The same principle applies to giving gifts or benefits on behalf of Swiss Water and to gifts given to, or received by, family members and spouses.

Abuse of position

Employees must not inappropriately use their position for personal benefit or to the detriment of other employees.

Serving as a director of another organization

Trustees and Directors and employees may serve as a director of another organization, such as a corporation, a non-profit or a religious organization, provided that it does not interfere with their ability to perform their duties at Swiss Water. Where serving as a director creates a conflict of interest, it must be disclosed and, where appropriate, remedied. Employees must not state or give the impression that, in acting as a director of such an organization, they are doing so as a representative of Swiss Water

Compliance with this policy

It is critical to Swiss Water’s success that employees conduct themselves ethically and legally in every aspect of their business activities. Every employee of Swiss Water and its controlled subsidiaries is required to comply with this Code of Business Conduct.

Employees in leadership positions must assume a responsibility for the actions and conduct of other employees who report to them

Reporting violations

Anyone who believes a violation of this policy has occurred including concerns regarding questionable operating, accounting, auditing, financial reporting, or internal control matters, is required to report the violation to an appropriate Swiss Water official. Where a person is uncertain as to how a violation of this policy should be reported, they should consult directly with the Chief Financial Officer. All concerns regarding questionable accounting, auditing, financial reporting, or internal control matters should be brought directly to the attention of the Chair of the Audit Committee.

All reported violations will be investigated. Where an investigation determines that a violation has occurred, appropriate action will be taken.


INVESTORS About the Fund Performance History Tax Information Press Releases FAQ Trustees Contact Us		Swiss Water Decaffeinated Coffee Income Fund - Code of Business Conduct This Code of Business Conduct applies equally to all Trustees, Directors, officers and employees of Swiss Water Decaffeinated Coffee Income Fund (the “Fund”) and Swiss Water Decaffeinated Coffee Company (the “Company”, and together with the Fund, “Swiss Water”) regardless of their position within the organization. Throughout this document the term “employees” refers to individuals employed by Swiss Water and also refers to Directors and Trustees. Officers are senior management personnel holding such titles as President and Chief Executive Officer and Chief Financial Officer. This Code of Business Conduct has been approved by the Trustees of the Fund. Respecting the rights of others Rights of Swiss Water’s Employees Management of Swiss Water makes decisions regarding hiring and promotion of employees on the basis of merit and in accordance with applicable provisions contained in collective agreements and human rights legislation. Employees have the right to pursue their careers at Swiss Water free from discrimination and harassment based on any ground prohibited by law, including age, sex, race, colour, religion, creed, national origin, citizenship, language, marital status, family status, pregnancy or childbirth, sexual orientation, disability or political belief. No personal relationship between an employee and any other employee shall compromise, or appear to compromise, the principles defined by this policy. Swiss Water has developed specific policies which address employee rights. These include specific policies addressing diversity and harassment in the workplace. Property rights Swiss Water’s assets may, subject to limited approved exceptions, only be used for business purposes. Employees have a responsibility to ensure that Swiss Water’s assets are put to good use in enhancing unitholder value. All employees entrusted with managerial or supervisory responsibility are responsible for ensuring that appropriate policies, procedures and controls are put in place to safeguard these assets. Customer rights Customer relationships are critical to the continuing success of Swiss Water. In dealing with customers, employees will conduct themselves with fairness, courtesy and good faith. Employees must respect and ensure the confidentiality and privacy of customer personal information unless disclosure is required by law or order of a regulatory agency. Suppliers rights Relationships with suppliers must always be arms length, consistent with accepted business practices, Swiss Water policies and in accordance with applicable laws. In dealing with suppliers, employees of Swiss Water must conduct themselves with fairness, courtesy and good faith. All interactions with suppliers must conform to the requirements of the section of this policy addressing conflict of interest. Environmental rights Swiss Water is committed to environmental responsibility and stewardship. Obeying the law Swiss Water operates within a complex framework of federal, provincial, state and municipal laws. In addition to Canadian laws, Swiss Water is also subject to the laws and regulations of foreign countries in which it does business. Directors and employees are expected to comply with applicable laws and regulations of every jurisdiction where Swiss Water carries on business. Confidentiality and Privacy All assets, liabilities and transactions must be accurately and completely reported in Swiss Water’s books and supported by necessary documentation. No asset, liability or transaction is to be concealed from management or Swiss Water’s external auditors. All transactions must be authorized and executed in accordance with the instructions of management. Appropriate accounting and financial policies, procedures, controls and audit processes must be maintained. Employees, regardless of their position in the organization, are expected to follow internal policies and procedures designed to protect the integrity of corporate data and the confidentiality and privacy of all personal information to which they have access by reason of their employment with Swiss Water. This includes adherence to procedures related to security of computer systems. Financial reports which are made available to the shareholders and the public are prepared in accordance with generally accepted accounting principles as well as applicable laws and regulations. Swiss Water may have access to corporate or personal information which is sensitive or confidential. Information such as personnel records, payroll records, customer information, financial and competitive information is all confidential and in some cases, subject to protection by applicable privacy laws. Employees are required to use extreme care when dealing with confidential, personal or sensitive information. As a general rule, such information shall not be released to anyone inside or outside of Swiss Water who is not authorized or legally entitled to receive it, and shall not be used or disclosed for any reason except for legitimate business purposes. Swiss Water will not disclose personal information about an employee to third parties without the employee's permission, unless required by law or order of a regulatory agency. Avoiding conflicts of interest A conflict of interest arises when an employee must choose between Swiss Water’s best interests or their own. Any situation where an employee's judgment may be compromised, where they show undue favouritism to any party, or where he or she receives a benefit of some kind is potentially a conflict of interest. All employees will strive to avoid situations that create a conflict, create the appearance of a conflict, or have the potential to create a conflict. Use of insider information The Fund’s Units are traded publicly. Trading of publicly listed securities on the basis of insider information is against the law, and can result in significant fines and even jail sentences. Insider information is generally considered to be any corporate information that has not been made public which, if known to the market, will likely cause share prices to either rise or fall. In the course of performing their duties, employees may become aware of or have direct access to such information. Sharing this information with anyone inside or outside Swiss Water or using it for personal gain by buying or selling Units of the Fund or any other publicly traded company is a serious breach of company policy and Canadian law. Supplying such information to other people is an offence, even if there is no personal gain to the employee. Gifts and benefits Receiving and giving gifts and benefits in a business context is a sensitive area which requires the exercise of good judgment and common sense. Employees should not accept gifts or benefits from any person, including customers, suppliers, business associates or companies who wish to do business with Swiss Water, if such gifts might be perceived as a bribe or appear to influence business decisions. The same principle applies to giving gifts or benefits on behalf of Swiss Water and to gifts given to, or received by, family members and spouses. *Abuse of position* Employees must not inappropriately use their position for personal benefit or to the detriment of other employees. Serving as a director of another organization Trustees and Directors and employees may serve as a director of another organization, such as a corporation, a non-profit or a religious organization, provided that it does not interfere with their ability to perform their duties at Swiss Water. Where serving as a director creates a conflict of interest, it must be disclosed and, where appropriate, remedied. Employees must not state or give the impression that, in acting as a director of such an organization, they are doing so as a representative of Swiss Water Compliance with this policy It is critical to Swiss Water’s success that employees conduct themselves ethically and legally in every aspect of their business activities. Every employee of Swiss Water and its controlled subsidiaries is required to comply with this Code of Business Conduct. Employees in leadership positions must assume a responsibility for the actions and conduct of other employees who report to them Reporting violations Anyone who believes a violation of this policy has occurred including concerns regarding questionable operating, accounting, auditing, financial reporting, or internal control matters, is required to report the violation to an appropriate Swiss Water official. Where a person is uncertain as to how a violation of this policy should be reported, they should consult directly with the Chief Financial Officer. All concerns regarding questionable accounting, auditing, financial reporting, or internal control matters should be brought directly to the attention of the Chair of the Audit Committee. All reported violations will be investigated. Where an investigation determines that a violation has occurred, appropriate action will be taken.