(b) Conduct of Business and

        Fair Dealings

The Company should maintain a reputation for fairness and integrity in dealings with legitimate and reliable firms and promote sound relationships with such firms. Hence, Directors, Senior management, officers and employees involved in the purchasing function shall:

* maximize competition among reputable firms;
* conduct impartial selection of qualified sources of goods and services, and maintain high ethical standards;
* Deal fairly by not divulging information obtained from suppliers and contractors, in recognition of the competitive environment among them.

The policy of the Company is to avoid the receipt of gifts, in cash or in kind, commissions, share in profits, loans or advances, materials and services at reasonably low prices, excessive or extravagant entertainment, paid travel from
any firm doing or seeking to do business with the Company; except those which are customarily accepted in usual course of business and allowed by Management.

If Employee is uncertain about what constitutes nominal or reasonable gift or “lunch”, the employee should discuss the matter with his/her immediate superior.

 (e) Respect for Trade Secrets/Use of

Non-public Information

Directors, Senior Management/Officers and Employees shall maintain and safeguard the confidentiality of information entrusted by the Company, customers, business partners or other parties with whom the Company relates, except when disclosure is authorized or legally mandated.

Officers and employees are enjoined to avoid using, divulging or releasing to anyone, any data or information which could adversely affect the Company in any way right then and there, or in the future; or whether or not it is for personal gain or any gratification, material or otherwise (e.g. to do a favor to another).

The Company also enters into confidentiality agreements with third parties.

(f) Use of Company Funds, Assets

and Information

Use of company funds

The Company thru its Corporate Finance and Treasury Dept (CFTSD) shall ensure at all times that all its business activities are in conformity with the provisions of the Company’s Anti- Money Laundering Operating Manual.

Use of company assets

To be in step with the rest of the local business community as well as for survival in this global economy - the Company has invested heavily in communications and computer systems & facilities.

* These facilities are made available to specific officers and employees primarily for official business use i.e. to enhance their effectiveness and efficiency in the performance of their respective functions in this age of
technology.
* Our major and primary concern therefore is that these systems and facilities be used – first and foremost - to the greatest business advantage of the Company.

Use of information

The Company policy requires that all employees should protect the integrity of the company’s proprietary and confidential information as well as the proprietary and confidential information of others.

* Officers and employees must exercise a greater degree of caution in transmitting company trade secrets or other confidential information on the electronic media and related communications facilities because of the
reduced effort required to redistribute such information.
* Electronic transmission of confidential information should be avoided or minimized.

(g) Employment & Labor Laws &

Policies