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Ethics Policy

, AMB

Ethics Policy

BUSINESS CONDUCT

Honesty and integrity are the cornerstones upon which AMB Co. Ltd was founded and upon which we operate. We are proud that Company employees have always maintained a high standard of behaviour. We intend that the Company always conducts its affairs according to the highest standards of corporate performance, and that its business and the actions of all Company employees comply with the spirit and intent of the law and moral codes under which we operate and live. We expect employees to behave in a manner that is consistent with the highest standards of both corporate and personal behaviour. Form and appearance are important, and employees are expected to cooperate in avoiding even the appearance of impropriety.
Our overriding principle is integrity and we pledge ourselves to be honest in our relationships with each other, with individuals outside the Company, and with other organisations.
In the final analysis, there is no way to insure proper behaviour except through the commitment of the individual employee. There is no way to provide rules of conduct that will apply to every possible situation. This Ethics Policy Statement establishes a broad code of conduct which sets minimum goals and provides guidelines to cover the most common and the most sensitive situations.
Directors and managers of the Company are responsible for the monitoring and enforcement of this policy statement within their specific areas of supervisory responsibility.
Any employee of the Company who discovers any event of a questionable, fraudulent, or illegal nature which is, or may be, in violation of the Company’s policies, is to immediately report such event to their immediate superior. Reports made in good faith may be made without fear of retaliation of any kind.

BUSINESS TRANSACTIONS AND ACCOUNTING CONTROLS

Employees shall at all times strive to be in strict compliance with all laws and regulations and Company policies applicable to the Company’s business.

The use of funds, property, or things of value of the Company for any purpose which would be in violation of any applicable law or regulation or Company Policy is strictly prohibited.

Compliance with accepted accounting rules and controls is required. No false, artificial, or misleading entries on the books and records of the Company shall be made for any reason whatsoever.

No fund or asset which is not fully and properly recorded on the books and records of the Company shall be created or permitted to exist.

No transaction shall be affected and no payment shall be made on behalf of the Company, with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment.

All employees responsible for filing periodic reports shall do so in a manner to ensure that all disclosures contained in such reports are full, fair, accurate, timely, and understandable.

No promise or statement shall be made on behalf of the Company which the author or speaker knows to be false or misleading.

No employee shall engage in any illegal or unethical act to obtain special favours or consideration, or make or authorise payments or promises of payment in order to obtain or retain business for the Company.

All business transactions shall be conducted on an arm’s length basis, with documentation maintained that the Company received the most favourable combination of product, service and price consistent with applicable laws and Company policies.

INTERNATIONAL BUSINESS LAWS

Employees are required to comply with the applicable laws in all countries to which they travel, in which they operate and where the Company otherwise does business, including laws prohibiting bribery or corruption.

Employees are required to comply with UK laws, rules and regulations governing the conduct of business by its citizens and corporations outside the UK

CONFIDENTIALITY AND PRIVACY

Privacy laws require that companies provide individuals with notice about information practices, choices about how personal information is used or disclosed and that companies adequately secure personal information. These laws also define the circumstances under which such information may be disclosed to third parties. Our business requires that we collect, use and sometimes share personal information about our employees & customers. Respect for the privacy of personal information earns trust and confidence. AMB Co. Ltd is committed to safeguarding personal information, which may include information about health-related conditions as well as other sensitive information.

Confidential information refers to all non-public and proprietary information about AMB Co. Ltd, or any other person or company, to which you obtain access as an employee of the Company. Confidential Information may be used by employees only for legitimate AMB Co. Ltd business purposes in accordance with contractual or legal requirements, and may only be discussed within the Company to those employees who have a legitimate business need to know such information. Such information includes, but is not limited to:

• financial information (including customer payments and supplier pricing).
• new business ideas.
• product or service information.
• Company strategies, plans, or marketing.
• Company business process maps or design.
• Company policies and procedures.
• Company research and development.
• information related to potential acquisitions.
• databases and the information in them.
• Supply and customer information that has not been disclosed to the public by, or on behalf of, the owner of such information.
• computer software source codes, and computer/network access codes.
• terms of the Company’s agreements with vendors, suppliers, landlords, consultants, and others doing business with the Company.
• Information that has been identified as confidential or proprietary by the Company.

Employee, customer, and supplier information are to be handled in accordance with Company procedures regarding confidentiality and privacy. All documents containing employee, customer, or supplier information are to be handled and disposed of in accordance with Company privacy procedures.

COMPUTER SECURITY

All employees are required to comply with Company policies and procedures and copyright laws in the use of computer systems and software. Unless the Company has licensed a software program pursuant to an enterprise or other multiple copy licenses, software products are not to be copied. Employees may not access any Company computer system using another user’s password or account, or for purposes unrelated to their employment duties. Employees may not upload, download, or otherwise transmit commercially licensed software or copyrighted materials on any Company system without management authorisation.

FREEDOM FROM CONFLICTING INTERESTS

All employees have a duty to the Company to be free from the influence of any conflicting interest when representing the Company in negotiations, or when making recommendations with respect to dealings with third parties. Employees are expected to deal with suppliers, customers, contractors, landlords, and all others doing business with the Company on the sole basis of what is in the best interest of the Company, without favour or preference to third parties based on personal considerations.

Employees who deal with suppliers, customers, contractors, landlords, or anyone else doing business with the Company–or who make recommendations with respect to such dealings or pass judgment upon them–shall not own any interest in, or have any personal contract, agreement, or understanding of any nature whatsoever with those individuals or entities that might tend to influence the decision of the employee with respect to the business of the Company.

Employees shall not do business on behalf of the Company with a close relative, unless expressly authorised in writing to do so by the Director of the Company after the relationship has been disclosed.

Employees are prohibited from exploiting their positions with the Company for personal gain, or for the gain of any other person or outside organisation. Employees may also not engage in a business that competes with the Company.

Any deviation from the foregoing statements of policy must have the written consent of the Director of the Company who has the final authority and responsibility to determine what steps are to be taken to correct any situation deemed not in the best interest of the Company.

GIFT POLICY

Employees shall not seek or accept, directly or indirectly, payments, loans, services, entertainment, or gifts from any individual or from the representative of any business concern doing or seeking to do business with the Company. Routine loans of reasonable amounts from commercial banks are excluded from this restriction.

Employees may not furnish or offer to furnish any gifts, entertainment, meals, or anything of value to a person who has business dealings with the Company under circumstances that might create the appearance of impropriety. Such items may be provided, other than to governmental officials and employees, if they are reasonable complements to business relationships, of modest value, and not against the law or the policy of the recipient’s company. These items must also be documented on an expense report. Giving or receiving money or a cash equivalent as a business gift is prohibited.

Meals and entertainment are only to be offered or accepted when both the employee and the individual or representative of a business concern are present and a substantial business discussion takes place during, directly before, or directly after the activity.

Travel or lodging for business or personal purposes may not be accepted from any person or business concern doing or seeking to do business with the Company. Exceptions may be made for vendor transportation directly to and from a business meeting, with prior approval of a Director.

EQUAL EMPLOYMENT OPPORTUNITY

The Company is committed to a policy of promoting equal employment opportunity. This policy applies to all decisions in the employment process, including recruiting, hiring, job assignment, training, discipline, scheduling, promotions, wages, and benefits.

The Company also believes that employees have a right to work in an environment free of verbal or physical harassment on account of race, religion, national origin, sex, age, disability, sexual orientation, or any personal characteristic. Such harassment on the part of supervisors or be tolerated.

The Company calls upon and expects every individual within the Company to accept personal responsibility for continuing the successful implementation of this policy. All violations should be reported, without fear of retaliation, through the open-door policy,

EMPLOYMENT LAWS

The Company is committed to compliance with all applicable governing laws and regulations covering the employment relationship. This includes laws regarding payment of wages, minimum wages and overtime compensation, hours of employment, employment of minors, discrimination, non-retaliation, health and safety, eligibility for employment and employment record keeping. All managers and supervisors are expected to fully comply with these requirements and related Company policies.

COMPANY PRINCIPLES ON CHILD AND FORCED LABOUR

AMB Co. Ltd strongly believes it has the responsibility to engage in employment practices that meet the highest legal and ethical standards. Nowhere is this responsibility more important than in the company’s policies governing the minimum age and working conditions of its own employees and the employees of its suppliers.
AMB Co. Ltd will continuously seek to make these principles as relevant and effective as possible. To that end, we may amend these Principles from time to time.
AMB does not engage in or condone the unlawful employment or exploitation of children in the workplace or the use of forced labour.

AMB Co. Ltd fully expect our suppliers to adopt and adhere to the same or similar values and behaviours.

All statements contained in this Policy are intended to reflect general policies, principles, and procedures, do not represent contractual commitments on the part of the Company, and may be changed at any time without notice. Without limiting the generality of the foregoing, nothing in this Policy should be construed to grant to any employee any right to continued employment or benefits under any employee arrangement. Violations of this Policy may result in disciplinary actions, including, if appropriate, termination of employment.

F Crownshaw (MD)