Code of Business Conduct and Ethics

Code of Business Conduct and Ethics

Business Conduct & Ethics Directors Senior Management Employees
Conflict of Interest A director should not use his position to profit or gain some benefit or advantage for himself and/or his related interest. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest. An employee should disclose any relationship or association to the proposed supplier or contractor or its authorized representative to avoid possible conflict of interest.
Conduct of Business and Fair Dealings A director should not use his position to profit or gain some benefit or advantage for himself and/or his related interest. If an actual or potential conflict of interest may arise on the part of a director, he should fully and immediately disclose it and should not participate in the decision-making process. They are prohibited from using their authority or position to favor a supplier or contractor in anticipation of a personal gain or benefit. They are prohibited from using their authority or position to favor a supplier or contractor in anticipation of a personal gain or benefit.
Receipt of gifts from third parties Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees. Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees. Must not solicit or accept any gift, regardless of value, from any supplier, contractor or business partner, except gifts of minimal value. If it is not practical to return, such gift must be shared with other employees.
Compliance with Laws & Regulations Ensure through their functions, the Company’s faithful compliance with all applicable laws, regulations and best business practices. Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices. Ensure the Company’s faithful compliance with all applicable laws, regulations and best business practices.
Respect for Trade Secrets/Use of Non-public Information Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position.  Should not reveal confidential information to unauthorized persons without authority of the Board. Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board. Keep secure and confidential trade secrets and all non-public information acquired or learned by reason of position. Should not reveal confidential information to unauthorized persons without authority of the Board.
Use of Company Funds, Assets and Information Observe discretion in use of funds and assets.  Be mindful of eliminating unnecessary consumption and wasteful practices.  Confidential information must not be disclosed to unauthorized persons. Observe discretion in use of funds and assets. Be mindful of eliminating unnecessary consumption and wasteful practices. Confidential information must not be disclosed without the proper authority. Observe discretion in use of funds and assets. Be mindful of eliminating unnecessary consumption and wasteful practices. Confidential information must not be disclosed without the proper authority.
Employment & Labor Laws & Policies Ensure the Company’s faithful compliance with employment and labor law & policies. The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security. The Company seeks to reasonably assist its and its subsidiaries and affiliates’ employee and his family in providing for their economic security.
Disciplinary action The Company observes the provisions on disqualification and temporary disqualification of directors as provided in the Company’s Manual of Corporate Governance. Rules and regulations shall be enforced fairly and consistently. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side. Rules and regulations shall be enforced fairly and consistently. Violations shall result in disciplinary actions depending on frequency, seriousness and circumstances of the offense. The employee shall be given the opportunity to present his side.
Whistle Blower Reports of wrongdoing may be made directly to the Chairman for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. For each subsidiary or affiliate, reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower. For each subsidiary or affiliate, reports of wrongdoing may be made directly to the Chairman or President for proper disposition to ensure confidentiality of information and protection of the identity of the whistle blower.
Conflict Resolution Amicable settlement through alternative dispute resolution. Amicable settlement through alternative dispute resolution. Amicable settlement through alternative dispute resolution.