Code of Business Conduct & Ethics

Our Commitment to Honest and Ethical Conduct

OUR WORKPLACE CONDUCT

a) We are committed to providing a work environment that is free from discrimination or harassment of any type, where the recruitment, employment and development of people is based on qualifications, skills and competency to do the job.

b) We assess the risks and hazards whenever necessary and promote good behaviour in our workplace. We do not permit violence or threatening behaviour in our workplaces.

c) We observe all security and access arrangements at our premises and facilities,

as well as all security policies and regulations.

d) We respect the privacy and personal data of all employees, business partners

and customers, and comply with all applicable laws and regulations on the

collection, use, protection and transfer of personal data.

e) We protect company assets from waste, loss, damage, theft, unauthorized

disclosure, mis-use or infringement.

f) We respect the rights and assets of others, including their proprietary information

and intellectual property.

g) We will maintain accurate, timely and complete records and accounts, and

preserve our financial and business records in accordance with accounting and

record keeping policies, applicable laws and regulations

OUR BUSINESS CONDUCT

a) We will ensure the projects we partake in are executed in a manner that seeks to reduce the risk of hazard to operators, the public, property and the environment.

b) We do not tolerate corruption of any kind whether relating to private individuals, government officials, private companies or public organisations. We comply with all bribery and anti-corruption laws.

c) We must not offer, attempt to offer, authorise or promise any sort of bribe, facilitation payment or kickback to a public official or any person for the purpose of obtaining or retaining business or an improper advantage.

d) We ensure that third party intermediaries are evaluated and appointed in accordance with our policies.

e) We must refrain from any practices or involvement that could lead to, or be perceived as, a conflict of interest.

f) Payments made to government officials to expedite or perform a routine administrative action are not permitted. These payments, sometimes known as “facilitation payments,” are illegal under most local anti-corruption laws, and regardless, these payments are against our policy and will not be tolerated.

g) All gifts and hospitality must be approved in accordance with our policies.

h) Political contributions, donations or sponsorships must be approved and be made inaccordance with high ethical standards and in compliance with all applicable laws; and must not confer a personal benefit, and must not be given to gain a business advantage or to influence a business outcome or an official action.

i) We must ensure that customers, suppliers and business partners whom we do business with are screened in accordance with our policies.

j) We are committed to conduct our business in a fair, honest and ethical manner, in all our dealings with customers, suppliers, partners and competitors in compliance with applicable law.

k) We are committed to conduct ourselves in an environmentally responsible manner in all aspects of our work and business, and to use resources efficiently.

l) We will support, sponsor and contribute to the well-being of our communities through volunteerism, charitable giving and civic activities