All employees are expected to behave in accordance with the company's behavioural values, which are shown opposite. These values define who we are and how we do business, both as individuals and as a company.

Policy
The ethical standards we expect each employee to meet are set out in our Ethics policy which is communicated to all employees. The Ethics policy can be viewed on our website at www.spectris.com. The policy prohibits bribery, corruption and similar facilitation payments. Donations to political parties or similar organisations are also prohibited. Any allegations of misconduct are thoroughly investigated. All operating companies are required to comply with export control regulations governing shipment of products and the appropriate compliance procedures are in place.

Reporting
As with all Spectris policies, conformity is monitored by self-certification, on an annual basis, by the Managing Director and Finance Director of each operating company that they have complied with the policy. Any instances of non-compliance must be reported. In particular any known instances of fraud, including bribery and corruption, must be specifically disclosed.

Certification forms an integral part of the company's risk management and corporate governance processes, and is regularly reviewed by the group's internal audit function and the company's external auditors. Compliance testing is a formal part of internal audit reviews. Through a structured review process, the internal audit function undertakes visits to group locations on a rotational basis. These visits involve an assessment of the business's key internal controls as well as compliance with the group's policies and procedures. The scope of the work performed during internal audit visits includes testing to confirm compliance with the group's overall position and policy regarding anti-bribery and corruption measures.

The results of internal audits and any non-compliance events are reported to the Audit Committee.

The company operates a 'Whistleblowing' policy, described above, through which known instances of fraud, including bribery and corruption, may be reported confidentially. This will be strengthened in 2009 to include a telephone hotline and an on-line reporting system which employees will be able to access in anonymity.

Training
Currently a number of Spectris companies provide training to employees, however Spectris intends to formalise this with a group-wide ethics programme which will be introduced during 2009. This formal programme will ensure that the group's ethics policy (which includes statements on anti-bribery and corruption) is communicated to and acknowledged by all employees in local language, and will make training compulsory in all companies, either via the HR department or on-line training modules. All companies will be required to nominate an ethics compliance officer. Compliance with the ethics policy and training within each company will be monitored by the internal audit function as part of the risk assessment process.