Business Conduct & Ethics

1. Our Code of Business Conduct and Ethics reflects the standards that must guide our actions. While covering a wide range of business practices and procedures, these standards cannot and do not cover every issue that may arise, or every situation where ethical decisions must be made, but rather set forth key guiding principles that represent Company policies and establish conditions for employment at the Company.

We strive to foster a culture of honesty and accountability. Our commitment to the highest level of ethical conduct reflects in all of the Company’s business activities including, but not limited to, relationships with employees, customers, suppliers, competitors, the government and the public, including our shareholders. All of our employees, officers and directors conduct themselves according to the culture and spirit of inspired by this Code and avoid even the appearance of improper behavior.
One of our Company’s most valuable assets is our reputation in terms of ethical behavior, integrity, professionalism and fairness. We all recognize that our actions are the foundation of our reputation and adhering to this Code and applicable law is imperative.

2. Compliance with Laws, Rules and Regulations We are strongly committed to conducting our business affairs with honesty and integrity and in full compliance with all applicable laws, rules and regulations. No employee, officer or director of the Company is disposed to committing an illegal or unethical act, or indulge others to do so, for any reason.

If you believe that any practice raises questions as to compliance with this Code or applicable law, rule or regulation or if you otherwise have questions regarding any law, rule or regulation, please contact the Legal Adviser. The Company also holds information and training sessions to promote compliance with the laws, rules and regulations that affect our business.

3. Protection of Confidential Proprietary Information Confidential proprietary information generated and gathered in our business is a valuable Company asset. Protecting this information plays a vital role in our continued growth and ability to compete, and all proprietary information belonging to us or our partners are maintained in strict confidence, except when disclosure is authorized by the stakeholders or required by law.

Proprietary information includes all non-public information that might be useful to competitors or that could be harmful to the Company, its customers or its suppliers if disclosed. Intellectual property, such as trade secrets, patents, trademarks and copyrights, as well as business, research and new product plans, objectives and strategies, records, databases, salary and benefits data, employee medical information, customer, employee and suppliers lists and any unpublished financial or pricing information must also be protected.

4. Conflicts of Interest. Our employees, officers and directors act in the best interest of the Company. All employees, officers and directors do not engage in activities that present a potential or actual conflict between their interest and the interest of the Company.

5. Protection and Proper Use of Company Assets Protecting Company assets against loss, theft or other misuse is the responsibility of every employee, officer and director. Loss, theft and misuse of Company assets directly impact our profitability.

The sole purpose of the Company’s equipment, vehicles and supplies is the conduct of our business. They are only used for Company business consistent with Company guidelines.

6. Corporate Opportunities Employees, officers and directors are prohibited from taking for themselves business opportunities that arise through the use of corporate property, information or position. No employee, officer or director engage in using corporate property, information or position for personal gain, and no employee, officer or director may compete with the Company. Competing with the Company may involve engaging in the same line of business as the Company, or any situation where the employee, officer or director takes away from the Company opportunities for sales or purchases of products, services or interests.

7. Fair Dealing Each employee, officer and director of the Company deals fairly with customers, suppliers, competitors, the public and one another at all times and in accordance with ethical business practices.

8. Compliance with This Code and Reporting of Any Illegal or Unethical Behavior All employees, directors and officers are in compliance with all of the provisions of our Code. The Code is strictly enforced throughout our Company and violations are dealt with immediately, including subjecting persons to corrective and/or disciplinary action such as dismissal or removal from office. Violations of the Code that involve illegal behavior will be reported to the appropriate authorities.

9. Waivers and Amendments Any waivers of the provisions in this Code for executive officers or directors are only granted by the Board of Directors and promptly disclosed to the Company’s shareholders. Any waivers of this Code for other employees are only granted by the Management Committee. Amendments to this Code are approved by the Nominating and Corporate Governance Committee Board of Directors and amendments of the provisions in this Code applicable to the CEO and the senior executive officers will also be promptly disclosed to the Company’s shareholders.

10. Equal Opportunity, Non-Discrimination and Fair Employment The Company’s policies for recruitment, advancement and retention of employees forbids discrimination on the basis of any criteria prohibited by law, including but not limited to race, sex and age. Our policies are designed to ensure that employees are treated, and treat each other, fairly and with respect and dignity. In keeping with this objective, conduct involving discrimination or harassment of others are not tolerated. All employees comply with the Company’s policy on equal opportunity, non-discrimination and fair employment, copies of which were distributed and are available from the Legal Adviser.

11. Environment, Health and Safety The Company is committed to conducting its business in compliance with all applicable environmental and workplace health and safety laws and regulations. The Company provides a safe and healthy work environment for our employees and avoids adverse impact and injury to the environment and communities in which we conduct our business. Achieving this goal is the responsibility of all officers, directors and employees.