Code of Conduct

The Code of Business Conduct serves as the primary means by which our organization communicates its commitment to the ethical and legal conduct of our employees.

This is a set of organizational standards regarding ECSP values, beliefs, ethics as well as the matters of legal compliance that governs the conduct of the Company.

OBJECTIVE

The Code of Conduct is intended to provide an effective and comprehensive guidepost regarding the Company’s expectation for ethical behaviour. It is not meant to cover all possible situations that may occur. It is designed to provide a frame of reference to measure any activity.

SCOPE

This Code applies to all individuals working at ECSP, whether regular employees, contract staff, daily wages staff or trainess. Employees should seek guidance when they are in doubt about the proper course of action in a given situation, as it is the ultimate responsibility of each employee to do the right thing.

RESPONSIBILITIES

This Policy belongs to ECSP Administration Department and it is the responsibility of Administration to ensure this document is always updated and ensure that the Code is being followed by employees of the company.

GENERAL PRINCIPLES

1. Confidentiality

ECSP is commiteed to maintain the highest degree of integrity in all its dealings with potential, current and past clients, both in terms of normal commercial confidentiality and protection of all personal information received in the course of providing the business services. Confidential information consists of any information that is not or not yet public information. It includes trade secrets, business, marketing and service plans, consumer insights, engineering and manufacturing ideas, designs, databases, records, salary information and non-published financial or other data. Our success depends on the use of confidential information and its non-disclosure to third parties. Unless required by law or authorized by the managment of the Company, employees shall not disclose confidentail information or allow any such disclosure. We respect that our clients, suppliers and associates have a similar interest in protecting their confidential information.

2. Business Ethics

We always conduct our services honestly and honourably and expect our clients, associates and suppliers to do the same. We will never deliberately mislead and will not make deceptive promises on behalf of the company. Our advice and assistance shall follow our ethical considerations together with the protection and improvement of moral position of our clients and suppliers. We will be open and direct in our communication and responsive/receptive to influence. We will honor and value the abilities and contributions of others and accept responsibility and accountablity for our actions in this regard. We will maintain an awareness of the needs of others and act to meet those needs whenever possible. We will act in ways that are consistent with our commitment to social responsibility. We will live up to ECSP’s ethical principles, even when confronted by personal, professional and social risks, as well as economic pressures.

3. Duty of Care

Our actions and advice will always confirm to relevant law, and we beleive that all businesses and organizations, including this consultancy house, should avoid causing any adverse effect on the human rights of people within or outside the organization we deal with, and well being of society at large.

4. Conflict of Interest

A Conflict of Interest arises when personal interest of an employee or interest of a third party compete with the interest of ECSP. We must avoid any relationship or activity that might impair or even appear to impair our ability to make fair decisions. Any such situation may make it difficult for the employee to act in the best interest of ECSP. Employees shall avoid Conflict of Interest whenever possible. If a Conflict of Intetest situation occurred or if an employee faces a situation that may involve or lead to a Conflict of Interest, the employee shall disclsose it to his/her Head of Division and /or to HR Department to resolve the situation in a fair and transparent manner.

5. Contracts

Our contract will usually be in the form of a detailed proposal, including aims, activities, costs, timescales and deliverables. The quality of our service and the value of our support provide the only true basis for continuity. We always try to meet our clients’ contractual requirements, and particularly for situations requiring more official parameters and controls.

6. Fees

Our fees are always competitive to what we provide, which is high quality specialised services. Generally we do not offer discounts, however a reduction in price is only enabled by reducing the level or extent of services to be delivered. We always try to accomodate our clients’ budgets and timelines. Wherever possible, we agree our fees and basis of charges clearly before signing of contract so that we and our clients can plan reliably for what lies ahead, and how it is to be achieved and financially justified.

7. Intellectual Property and Moral Rights

We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clents’ intellectual property.

8. Quality Assurance

We maintain the quality of what we do through constant ongoing review with our clients. This review includes all activities, outcomes and the cost effectiveness of every activity.

9. Professional Conduct

We conduct all of our activities professionally with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.

10. Health and Safety

ECSP is dedicated to maintain a helathy and safe working environment. HSE Policy is in place.

11. Political Contributions

Election laws prohibit political contributions by corporations to political parties or candidates. ECSP has adopted a policy not to make such contributions.

12. Bribery and Corruption.

Employees must never, directly or through intermidiaries, offer or promise any personal or improper financial or other advantage in order to obtain or retain a buisness or other advantage from a third party, whether public or private. Nor must they accept any such advantage in return for any preferential treatment of a third party. Improper benefits may consist of anything of value for the receipient, including employment or contracts for close relatives. Employees should be aware that offering or giving of improper benefits in order to influence the decision of the recipient may not only entail disciplinary actions but also result in criminal charges.

13. Gifts, Meals, Entertainment etc.

Employees shall not be influenced by receiving favours nor shall they try to influence others by providing favours. Employees may only offer or accept reasonable meals and symbolic gifts which are appropriate under the cicumstances and they shall not accept or offer gifts, meals or entertainment if this could create the impression of improperly influencing the respective business relationship. No employee shall offer or accept from any third party gifts taking the form of any of the following, whatever the value involved: • Money • Loans • Kickbacks • Other monetray advantages

14. Equality and Discrimination

We always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issue of religion, sect, gender, race, colour, age or personal disability.

15. Legal Compliance

We respect law at all times. Compliance with all applicable laws and regulations must never be compromised. Additionally, employees shall adhere to internal rules and obligations as they apply in a given situation. These internal rules are specific to the Company and may go beyond what is reuired by law.

COMPLIANCE WITH THE POLICY

Employees shall report any practices or actions believed to be inappropriate under this Code to their respective Head of the Divisions. If it is appropriate, in view of the nature of the reported matter, reports of violations may be made directly to Managing Director. Please note that the procedures and policies outlined in this policy, and in any related policy, may be reviewed or changed at any time.