Code of Conduct

1. Introduction

Purpose

This Code of Conduct is a guide for Corintech employees in relation to ethical conduct in all interactions with colleagues, customers and other business partners. It sets forth our core values of honesty, integrity and
respect, our shared responsibilities, and general guidance about the Company’s expectations.

We promote freedom of expression and open communication, but expect all employees to follow our Code of Conduct.

This policy cannot possibly address every situation we face at work. Therefore, it is by no means a substitute for our moral, unbiased judgment, and our honest and considerate actions. If a situation at work arises and you require guidance in addition to this policy, you should seek advice from your Supervisor or Manager.

Scope

This Code of Conduct applies to all Corintech employees regardless of employment agreement, rank, or location. The Code also applies to vendors and third parties providing materials and services to the Company, such as consultants, agents, advisors, institutions and others acting on the Company’s behalf. Third party affiliates are further responsible for reporting any violations of this policy they observe in dealings with the Company.

2. Responsibility

Management

Senior Leaders, Directors, Managers and Supervisors are tasked with providing strong examples of ethical conduct. Managers also have a responsibility to create an open and supportive environment where employees feel comfortable raising ethical concerns and reporting instances of misconduct. Corintech Human Resource personnel responsible for recruitment must ensure that the Company follows the International Labour standards on Child Labour.

Employees

All employees should treat everyone fairly, maintain mutual respect, promote a collaborative team environment, and avoid the performance and/or appearance of unethical or compromising practices.  Employee behaviour should reflect Company values and culture and not adversely affect Company stakeholders.  All employees are responsible for:

• Applying effort and intelligence to performing all job responsibilities in an ethical manner.
• Disclosing any conflict of interests in regard to their position within Corintech.
• Maintaining professional conduct in their interactions with other employees, customers, vendors, agents and any other Company stakeholders.

3. Respect and Ethics in the Workplace

To work effectively, all of us need a healthy and safe work environment. Employees should be familiar with the Corintech Worker Health and Safety policy. We provide a work environment free of coercion, discrimination, and harassment. Therefore, respect, inclusiveness and shared ethical values are at the heart of our core values. Irrespective of your department and level of authority, you should conform with our antidiscrimination and harassment policy in all aspects of the work, from recruitment and performance evaluation,
to interpersonal relations.

All forms of substance abuse, as well as the use or distribution of drugs and alcohol while at work, is strictly prohibited.

4. Compliance with Law

Corintech complies with all local, national or regional laws, rules and regulations where we do business. This includes laws relating to modern slavery and human trafficking.

All our employees, and those acting on our behalf, must protect the Company’s legality. Employees should comply with all environmental, safety and fair dealing laws. Violations of law can result in significant harm to the Company, including financial penalties, denial of government contracting privileges, imprisonment for criminal misconduct and damage to our business relationships and reputation. Employees and those acting on the Company's behalf are expected to be ethical and responsible when dealing with our Company’s finances, products, partnerships, and public image.

5. Fair Competition

Corintech is dedicated to ethical, fair, and vigorous competition. We will sell products and services based on their merit, superior quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase or sales of goods or services that unfairly benefit the Company. Nor will we engage or assist in unlawful boycotts of particular customers.

6. Protection of Company Property

All employees should treat our Company’s property, whether material or intangible, with respect and care. Employees shouldn’t misuse Company equipment or use it frivolously and should respect all kinds of incorporeal property. This includes trademarks, copyright, intellectual property and other assets (reports, information etc.). Employees should use them only to complete their job duties. Additionally, the use of our assets for individual profit or any unlawful, unauthorised personal or unethical purpose is prohibited.

The Company will not tolerate the use of Company resources to create, access, store, print, solicit, or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.

7. Fraud, Financial Integrity and Accounting

No employee or applicant may falsify any application, record, invoice, paperwork, time sheet, expenses reimbursement form, timecard, investigative questionnaires, or any other document. Any employee found to have falsified or made material misrepresentations or omissions on any such document will be subject to disciplinary action.

Accurate and reliable financial and business records are of critical importance. You must not engage in any actions that could result in conveying false or inaccurate financial information about our Company or our clients. You must ensure that all submissions you make to the Company, customers or others on our behalf are complete and accurate.

8. Conflict of Interest

Employees must avoid situations involving an actual or potential conflict of interest so that the integrity of the Company is not brought into question. Numerous situations exist that could give rise to a conflict of interest.
The most common include:

• Accepting gifts from suppliers
• Employment by another company that is a customer, supplier, or competitor to Corintech. We request employees with any other form of employment to inform their Manager and to get written
  consent (which will not be unreasonably withheld) from Corintech.
• Ownership of a significant part of another company or business that is a customer, supplier, or competitor to Corintech
• Close or family relationships with suppliers
• Communications and/or collaboration with competitors

Employees must ensure that decisions are based on the Company’s best interest and that any decisions they make are not in exchange for anything that benefits them personally, either directly or indirectly.

9. Confidential Information

For any Company, its confidential information is a valuable asset and every director, employee, and agent of the Company must protect it. Confidential information includes all non-public information that relates to customers, employees and business partners, as well as personal information obtained from any source in the course of business. Employees should not seek out, accept, or use any confidential company information of or from a competitor.

10. Bribery and Corruption

Bribery is a criminal offence and we have zero-tolerance for inappropriate gifts, business dealings and transactions that may influence business decisions. It is also prohibited for Corintech to make political donations.

We discourage employees from accepting gifts, entertainment, gratuities and services from clients or partners.  Exceptions to this rule include normal business activities such as meals and beverages, gifts that have a minimal token value, or marketing related presents. Retirement awards and contributions to recognised charitable and non-profit organisations are also excluded.

An employee who receives, or whose family member receives, an unsolicited gift prohibited by these guidelines should report it to their Supervisor or Manager.

11. Professionalism

All employees must show integrity and professionalism in the workplace:

• Personal Appearance
  • All employees must follow our dress code and personal appearance guidelines.
• Job Duties and Authority
  • All employees should fulfil their job duties with integrity and respect towards customers, stakeholders, and the community. Supervisors and managers must not abuse their authority. We
    expect them to delegate duties to their team members taking into account their competences and workload. Likewise, we expect team members to follow team leaders’ instructions and complete
    their duties with skill and in a timely manner.
• Absenteeism and Tardiness
  • Employees should follow their schedules. We can make exceptions for occasions/emergencies that prevent employees from following standard working hours or days, but, generally, we expect employees to be punctual when coming to and leaving from work. Always keep your Manager informed of any delays, changes to your work day or absenteeism from work.
• Communication
  • All employees must be open and honest in their communications with their colleagues, supervisors or team members. Corintech values the free flow of thoughts, ideas, questions, and concerns. Employees should be friendly and collaborative. They should try not to disrupt the workplace or present obstacles to their colleagues' work.
  • All employees involved in the sale of our products and services must ensure that all communications, statements and representations to clients are accurate, complete, and truthful.
  • Employees may be approached by reporters and other members of the media with enquiries about the Company. In order to ensure that we speak with one voice and provide accurate information about the Company, employees should direct all media inquiries to the Marketing department. No one may issue a press release without first consulting the Marketing department.
  • Corintech expects employees to use social media and social networking platforms responsibly. We expect you to respect the privacy of other employees, customers and business partners and for you to comply with applicable laws and government guidelines governing social media. When using any form of social media, you must comply with this Code of Conduct. You must not disclose any confidential information about the Company or any of its employees, contractors or third-party vendors. You are not to act on behalf of the Company with any political or social cause unless specifically asked to do so.
• Workplace Violence
  • Corintech strives to provide a safe and secure workplace for employees, customers, vendors, and visitors. Corintech will not tolerate violent acts or threats of violence against our employees, applicants, customers, vendors or business partners. We do not allow fighting, threatening words or aggressive conduct. Weapons of any kind are strictly prohibited and not permitted on Company
    premises, except as allowed by local laws or regulations.
• Benefits
  • We expect employees to not abuse their employment benefits. This refers to time off, insurance, facilities, subscriptions or other benefits our Company offers.
• Policies
  • This policy will be distributed to all employees by the Human Resources department during their induction and/or onboarding and subsequent to any revisions. Other relevant policies will also be distributed so that all employees have access to read and subsequently follow the Company policies.
  • If employees have any queries they should contact the Human Resources department or representative, their direct Supervisor, Manager, or a Company Director.

12. Diversity and Inclusion

Corintech is an equal employment opportunity employer and is committed to providing a workplace that is free of discrimination.

Corintech will not tolerate harassment or discrimination. Any employee or stakeholder who feels harassed or discriminated against should report the incident to their Manager, or to the Human Resources department.

Employees must comply with the Corintech Anti-Discrimination and Harassment Policy.

13. Reporting Concerns and Disciplinary Actions

Violations of this code can result in serious consequences for Corintech, its image, credibility, and confidence of its customers. Violations can further lead to substantial fines and restrictions on future Company operations, as well as potential for fines and prison sentences for individual employees.

Employees are encouraged to report any violations promptly. Reports should be made to the employee’s Supervisor or Manager, or elsewhere as the circumstance dictates. The Company will investigate all reported instances of questionable or unethical behaviour and will not perpetrate or tolerate retaliation against employees, sometimes referred to as ‘whistle-blowers’, who raise genuine ethics concerns in good faith.

Our Company may have to take disciplinary action against employees who repeatedly or intentionally fail to follow our Code of Conduct.  Disciplinary actions will vary depending on the severity of the violation.

Possible Consequences Include:

• Demotion
• Reprimand
• Suspension or termination

We may take legal action in cases of corruption, theft, embezzlement or other unlawful behaviours.

Version 1.1