Kaertech Business Ethics Program
DEDICATION
It is the intent of KAERTECH to have all employees conduct themselves in ways that demonstrate
uncompromising ethical standards in all of their dealings with customers, suppliers, government officials
and agencies. In other words, the integrity of the company rests on the integrity of its employees.
As the Company continues to expand globally, we must be sensitive to cultural differences while ensuring
continued adherence by our employees to the Company’s high ethical standards.
PURPOSE
Our business must be judged by the highest standards of ethical behavior. The message is simple and
clear: Diligent observance of the laws and regulations is a requirement from which there can be no
exception. The same is true about observance of company policies and practices.
However, rules can’t guarantee ethical conduct; only people can.
Therefore; the purpose of this policy is as follows:
• To affirm in a comprehensive statement the ethical standards required of all Company Employees.
• To encourage all employees to put the applicable ethical standards into daily practice.
RESPONSIBILITIES
The Company
• Provide all employees with clear guidelines on matters of everyday business conduct.
• Implement the KAERTECH Business Ethics Program contained in this Policy.
• Ensure through communication and training programs that all employees are aware of and
understand this Policy.
• Provide continuing counsel on Company Policies and Procedures to all employees.
All Employees
• Review regularly their knowledge and understanding of the Policy
• Uphold the policies, procedures and practices that support them in their daily business conducts.
• Contribute to a workplace that is conductive to the maintenance of this Policy.
• Seek help when the proper course of action is unclear or unknown.
GENERAL ETHICAL STANDARDS
• Below are the General standards that shall be met by all employees. However, these standards
are not necessarily the only obligations that apply to employee’s conduct.
• In General, all employees shall take care to avoid any conduct that could reasonably appear to be
improper or might injure the Company’s reputation for honesty and integrity in its activities.
• If in doubt, consult with your supervisor or one of the Management Team.
BUSINESS INTEGRITY
The highest standards of integrity are required in all business interactions. Any and all forms of corruption,
extortion and embezzlement are strictly prohibited resulting in immediate termination and legal actions.
CONFLICT OF INTEREST
No employee may have a personal, business or financial interest that is incompatible with the loyalty and
responsibility owed to the Company. It is not possible to identify every particular activity that might give
rise to a conflict of interest.
DEALING WITH COMPETITORS
Similarly, disclosure shall be made to the Company if an employee or any of his/her immediate family
members has an ownership interest in a competitor’s business or performing services of any kind, or is
otherwise compensated by, a competitor.
OUTSIDE DIRECTORSHIP AND CONSULTING
A company employee, if asked to serve as a director or consultant of another business, shall first receive
clearance from the KAERTECH Management or from the Company’s Chief Executive Officer.
COMPENSATION FROM OTHERS
An employee or member of his/her immediate family shall not accept compensation, loan, entertainment
or gift, property or anything else of personal financial or other advantage, from outside parties in
connection with any transaction in which the company might have an interest, without making full
disclosure to the company.
SOCIAL RESPONSIBILITY; EQUAL EMPLOYMENT OPPORTUNITY, ANTI & SEXUAL HARASSMENT
KAERTECH considers employee welfare and fulfilment to be key success factor in achieving sustainable
business excellence throughout the company. Employees are treated with respect and dignity, with the
aim of developing their understanding and encouraging their participation in the Company’s business
activities. We are committed to a policy of equal employment opportunity so as to assure that there shall
be no discrimination or harassment against an employee or applicant on the ground of race, color,
religion, sex, sexual orientation, gender, identity, age, disability, immunization status, national origin, or
any other factor made unlawful by applicable laws and regulation.
HEALTH, SAFETY AND ENVIRONMENT
KAERTECH is committed to compliances with all local laws and regulations that apply to its operations,
including those concerning health, safety and environment anywhere in the world. Employees will make
every reasonable effort to ensure that the Company’s products and places of business are safe for the
public and its employees.
PROPRIETARY DATA
KAERTECH’s trade secrets and proprietary data are part of the Company’s valuable intellectual property.
An employee shall not use such information for personal benefits or for the benefits of anyone other than
the Company. All customer information and proprietary data needs to be treated with the same
precaution and protection of their confidentiality as well.
ANTITRUST / COMPETITION LAWS
Generally, an employee shall not enter into an understanding, agreement or plan, expressed or implied,
formal and informal, written or oral with a competitor in regard to prices term or conditions of sale or
service, production, distribution, territories and customers. He/she shall not exchange or discuss with a
competitor’s prices, term or conditions of sale or services, or other competitive information, nor engage
in other conduct that violates any of these laws.
ACCOUNTING SYSTEMS, BOOK & RECORDS
No false, artificial or misleading statement or entries shall be made in the Company Books and records
including, but not limited to, time cards, accounts and financial statement. No unrecorded off-the-books
funds or secret assets of any kind shall be maintained for any purpose whatsoever.
COERCION OF AUDITORS
The integrity of the company’s audited financial statements is critical. No employee shall take any action
to fraudulently influence, coerce, manipulate, or mislead the Company’s accountant to engage in the
performance of an audit of the company’s financial statement for the purpose for rendering the resulting
financial statements and make it misleading.
PROTECTION & PROPER USE OF COMPANY ASSETS
Protecting company assets against loss, theft and misuse is the responsibility of every employee. Any
suspected theft, fraud or inappropriate use of company assets should be reported to an employee’s
supervisor or someone from the Management. Assets may only be used in accordance with company
policies. It may not be sold, loaned, given away or disposed of without proper authorization.
SUPPLIERS, CONSULTANTS & AGENTS
Suppliers, Consultants and Agents may be able to assist the company in achieving its legitimate business
objectives. However, company personnel must take step to ensure that THEY comply with the relevant
laws and regulations, company’s’ policies and terms of agreements, including requirements concerning
procurement information and conflict of interest. Agreements with the suppliers, consultant or agents
shall require such compliance by both parties.
POLITICAL PAYMENTS
No funds and assets of the Company shall be used to aid any candidate or nominee for any political parties
or committees unless otherwise permitted by law and approved in advance by the Governmental/Public
Affairs Department.
REPORTING & EVALUATING A POTENTIAL CONFLICT OF INTEREST
If you believe that you have a potential conflict of interest situation, you should report it to your
supervisor, to HR, or to any of the Management team. All reported potential conflicts of interest will be
evaluated by the Management which will be determined whether a conflict of interest really exists.
If any indication of violation of this Business Ethics Policy, you may reach with confidentiality our email
hotline allears@kaertech.com.