Business Ethics Policy Statement

General Principles

The company and its employees will at all times demonstrate the highest levels of integrity, truthfulness, and honesty in order to uphold both personal and corporate reputations and to inspire confidence and trust in their respective actions. The company will conduct its business in a competent, fair, impartial, and efficient manner.

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Health and Safety

The company is committed to providing a safe and healthy working environment for all of its employees both on and off its sites. There is a programme of regular health and safety audits and safety training. The company applies its standards to all visitors to its sites.

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Environment

The company respects the environment and the need to protect it and minimise the impact its operations have on it. It is engaged in a continuous programme of improvement on environmental issues and opens itself to independent third party verification, inspection, and certification of its progress.

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Employees

All employees are treated with dignity and respect with equal employment opportunities given to all irrespective of their race, religion, gender, sexual orientation, maternity, marital status, family status, disability, age, or national origin. Employees are offered a safe and healthy workplace and the company will not tolerate any form of harassment.

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Customers

The company will take all reasonable care to avoid misleading statements, concealment, and overstatement in all of its advertising and public statements. It will seek to build long term partnerships with its customers by being honest and straightforward in its dealings at all times. It will respect the confidentiality of any information it may obtain in relation to its customers.

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Suppliers

Suppliers will be chosen on the basis of factors such as price, quality, delivery, service, and integrity. The company’s choice of suppliers will be made objectively. Honesty and openness will be paramount in the company’s dealings with its suppliers.

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Competitors

The company will build its reputation on the basis of its performance alone. It will compete vigorously and lawfully and will not compete unfairly with others. It will not seek to damage the reputation of its competitors either directly or by implication.

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Government, Regulators, and Legislators

The company will seek to comply with all international, national, and local legislation affecting its operations. It will strive to follow the best practice in corporate governance. It will meet its tax obligations. It will not make any financial contributions or offer support to any political party.

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Giving and Receiving Gifts and Entertainment

Employees will neither seek nor accept for themselves or others any gifts, favours, or entertainment without a legitimate purpose from any person or business organisation that does or seeks to do business with, or is a competitor of CloudSmiths. Gifts, favours, and entertainment may be given to others at the expense of the company as long as these are consistent with customary business practice and are not excessive in value.

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Bribes and Corrupt Practice

The company does not allow the direct or indirect offer, payment, solicitation, or acceptance of bribes in any form. The company has a separate Bribery Policy in place which examines the procedures all employees must follow to avoid involvement in any situation which might lead to the offer of bribes. The policy makes it clear that any employee found to be involved in any kind of corrupt practice is likely to be immediately dismissed and may well have committed a criminal act which could lead to prosecution.

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Anti-Money Laundering

The operations of the company and its subsidiaries are and have been conducted at all times in compliance with all applicable financial recordkeeping and reporting requirements, and the applicable anti-money laundering statutes of jurisdictions where the Company and its subsidiaries conduct business, the rules and regulations thereunder and any related or similar rules, regulations or guidelines, issued, administered or enforced by any governmental agency.

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Modern Slavery

The company has established a zero-tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we will look to replace those vendors and where it is not possible, support companies in their efforts to comply with the legislation. We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted.

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