Code of Business Conduct

ConnectedSky Legal & Corporate Consultants Limited (hereinafter referred to as “ConnectedSky”), including its representative offices and affiliates, will conduct its business in an ethical and proper manner at all times and in full compliance with all laws and regulations. We view these as the fundamental standards underlying our approach to doing business.

A good reputation is difficult to earn, easy to lose and almost impossible to regain. We must not lose sight of this.

We strive for the highest level of integrity and ethics in our dealings with each other, our clients, our partners, public and government establishments. We are relying on your integrity, continued dedication and adherence to the requirements in this Code of Conduct to help keep us there. Consequently, each director, officer and employee is expected to read and become familiar with the ethical standards described in this Code.

The Company's Chief Executive Officer is responsible for setting the standards of business conduct contained in this Code and updating these standards as it deems appropriate to reflect changes in the legal and regulatory framework applicable to the Company, the business practices within the Company's industry, the Company's own business practices, and the prevailing ethical standards of the communities in which the Company operates. While the Company's Chief Executive Officer will oversee the procedures designed to implement this Code to ensure that they are operating effectively, it is the individual responsibility of each director, officer and employee of the Company to comply with this Code.

Compliance with Laws and Regulations

Every Service Provider must comply with all laws and regulations that apply to that Service Provider, its employees and its business activities (“applicable laws and regulations”).

Conflicts of interest; corporate opportunities

Except as provided below (disclosure and approval) directors, officers and employees should not be involved in any activity, which creates or gives the appearance of a conflict of interest between their personal interests and the Company's interests. In particular, except as provided below (disclosure and approval) no director, officer or employee shall:

  • be a consultant to, or a director, officer or employee of, or otherwise operate an outside business:
    • that markets services in competition with the Company's current or potential services;
    • that supplies services to the Company; or
    • that purchases services from the Company;
  • have any financial interest, including stock ownership, in any such outside business that might create or give the appearance of a conflict of interest;
  • be a consultant to, or a director, officer or employee of, or otherwise operate an outside business if the demands of the outside business would interfere with the director's, officer's or employee's responsibilities with the Company;
  • accept any personal loan or guarantee of obligations from the Company, except to the extent such arrangements are legally permissible;
  • use the Company's property, information or position for personal gain.

Employees who are not directors or officers shall notify their immediate supervisor of the existence of any actual or potential conflict of interest providing full disclosure of the circumstances.

Directors and officers shall notify the Company's Chief Executive Officer of the existence of any actual or potential conflict of interest providing full disclosure of the circumstances.

No Bribery or Money Laundering

The Company has no tolerance for bribery or corruption in any aspect of its business or in any country in which we operate. Our Company policy prohibits engaging in any form of corruption, bribery, kickback, extortion, embezzlement or money laundering. We are committed not only to complying with all applicable laws and regulations regarding such activities, including but not limited to the U.K. Bribery Act and the Anti-corruption conventions adopted by Cyprus Law, but also to acting with integrity and the highest ethical standards.

We shall not participate in, facilitate or permit any form of corruption, bribery, kickback, extortion, embezzlement or money laundering, with respect to any other legal or physical person.

The Company is committed to promoting the values of honesty, integrity and fairness in the conduct of its business and sustaining a work environment that fosters mutual respect, openness and individual integrity. Directors, officers and employees are expected to deal honestly and fairly with the Company's customers, suppliers, competitors and other third parties. To this end, directors, officers and employees shall not:

  • make false or misleading statements to customers, suppliers or other third parties;
  • make false or misleading statements about competitors;
  • solicit or accept from any person who does business with the Company, or offer or extend to any such person,
    • cash of any amount; or
    • gifts, gratuities, meals or entertainment that could influence or reasonably give the appearance of influencing the Company's business relationship with that person or go beyond common courtesies usually associated with accepted business practice;
  • solicit or accept any fee, commission or other compensation for referring customers to third party vendors; or
  • otherwise take unfair advantage of the Company's customers or partners, or other third parties, through manipulation, concealment, abuse of privileged information or any other unfair-dealing practice.

Accounting

It is our Company policy to comply with accepted accounting rules, controls and disclosures at all times and to ensure that the auditors are provided accurate information. ConnectedSky will not knowingly participate in any scheme to avoid such accounting rules, controls or disclosures. To this end, the Company shall:

  • comply in a timely manner with its disclosure obligations;
  • comply with generally accepted accounting principles at all times;
  • maintain a system of internal accounting controls that will provide reasonable assurances to management that all transactions are properly recorded;
  • maintain books and records that accurately and fairly reflect the Company's transactions;
  • prohibit the establishment of any undisclosed or unrecorded funds or assets;
  • maintain a system of internal controls that (1) will provide reasonable assurances to management that material information about the Company is made known to management, particularly during the periods in which the Company's public disclosure documents (including interim and annual financial results or other public announcements) are being prepared, and (2) will ensure that such information is not disclosed to any third party before it is publicly disclosed; and
  • present information in a clear and orderly manner.

Confidential and Proprietary Information

We shall safeguard our clients’ confidential and proprietary information. This obligation includes using commercially reasonable means to safeguard information technology systems on which Company information is stored or transmitted.

In addition, we shall refuse any improper access to confidential or proprietary information of any other company, including competitors or others.

Directors, officers and employees shall maintain the confidentiality of all information entrusted to them by the Company or its suppliers, customers or other business partners, except when disclosure is authorized by the Company or legally required.

Confidential information includes (1) information marked "Confidential," "Private," "For Internal Use Only," or with other similar legends, (2) sensitive information relating to current and future services, (3) business or marketing plans or projections, (4) earnings and other internal financial data, (5) personnel information, (6) supply and customer lists, and (7) other non-public information that, if disclosed, might be of use to the Company's competitors, or harmful to the Company or its suppliers, customers or other business partners.

To avoid inadvertent disclosure of confidential information, directors, officers and employees shall not discuss confidential information with or in the presence of any unauthorized persons, including family members and friends.

Directors, officers and employees are personally responsible for protecting those Company assets that are entrusted to them and for helping to protect the Company's assets in general.

Directors, officers and employees shall use the Company's assets for the Company's legitimate business purposes only.

Directors, officers and employees shall respect the intellectual property rights of our clients and partners, and shall comply with applicable laws and regulations related to patents, copyrights, trademarks and business/trade secrets.

Accurate Information

It is our Company policy to provide all legal information that is as accurate as possible to guide our clients in the proper way. Directors, officers and employees shall never knowingly provide or use any false information.

Suspected Noncompliance

We shall promptly evaluate and resolve any suspected instances of noncompliance with applicable laws and regulations, and we reserve the right to undertake to report such noncompliance matters affecting the Company to any relevant establishment.

The Company will not allow any retaliation against a director, officer or employee who acts in good faith in reporting any such violation and will ensure this in accordance with an internal enforcement mechanism put in place for this purpose.

Employment Practices

ConnectedSky shall never discriminate in hiring or employment practices on the basis of race, national origin, gender, age, sexual orientation, citizenship, marital status, disability, veteran status or religion. ConnectedSky shall provide a workplace free from unlawful harassment.

ConnectedSky shall maintain a safe and sanitary workplace that includes appropriate protective equipment, and is in compliance with applicable environmental, health and safety laws, rules and regulations.

ConnectedSky shall comply with all applicable laws and regulations regarding employment, including but not limited to such laws and regulations related to minimum wage, maximum work hours, overtime and benefits.

Environmental Practices

ConnectedSky shall maintain and operate its business in an environmentally responsible manner. We recognize the importance of our environment and natural resources, we embrace the responsibility to society for prudently using natural resources and preventing harm to the environment, and therefore, we shall comply with applicable environmental laws and regulations.

Communication

ConnectedSky shall communicate the standards set forth herein to its employees and monitor their conformity to them.

 

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