CODE OF CONDUCT
CCP Technologies Ltd. and its subsidiary companies (“the CCP Technologies Ltd. Group”) are committed to conducting their business affairs ethically and in full compliance with the laws and regulations of the jurisdictions in which they operate.
The policies and practices described in this code are designed to assist directors and employees to conduct the business of the CCP Technologies Ltd. Group with high legal and ethical standards.
Specific circumstances under which this code is applied are set out below.
Should any employee become aware of any breach of this code they should immediately report the occurrence to their manager.
CCP Technologies Ltd. will maintain its financial records such that they fully and accurately report the transactions which they purport to reflect, and fully comply with statutory and stock exchange listing requirements.
CCP Technologies Ltd. will design, manufacture and deliver quality products which meet the needs of consumers and are not harmful to consumers. Operating policies will be implemented which ensure that the products are produced in an environmentally responsible way.
Conflicts Of Interest
A conflict of interest may arise where the interests of a director or employee interferes or appears to interfere with the interests of the company as a whole.
To avoid such conflicts arising, employees are obliged to:
- advise their manager of any material interest or proposed material interest that they may have in a customer, supplier or service provider;
- seek prior approval from the company before agreeing to become a director of any other company;
- not seek or accept offers of gifts, money or favours which might influence or appear to influence the making of any business decisions; and
- not be involved in any other business or position that may result in them not being able to carry out their duties and responsibilities to the company.
Employees are encouraged to raise with their manager any concerns they may have as regards to a conflict of interest as soon as they become aware of the issue.
Directors, executives or staff are not permitted to deal in the company’s securities if they are in possession of material information, which is not available to the share market, but if it were, it may impact the value at which the securities are traded.
A share trading policy has been established to provide detailed guidance on this issue.
Employee Share Options
This policy does not preclude employees from exercising options, but the policy applies to any dealings in the shares issued as a result of the options being exercised.
Compliance With Laws
The board is committed to compliance with all relevant legislation and corporate policies. Employees are expected to be aware of all legislation and policies applicable to their position and be sufficiently familiar with such laws and policies that they are able to comply.
Management and employees are responsible to ensure that they:
- have access to all relevant laws and policies;
- are properly instructed on the relevant laws and policies; and
- maintain their understanding, through continuing education and periodic updates.
Relevant laws include:
- trade practices law
- environment law
- occupation health and safety laws
- banking laws
- corporations law
Confidentiality And Privacy
Any confidential information about CCP Technologies Ltd. or its suppliers, customers, contractors or shareholders must not be used improperly.
Prior to the use of or release of confidential information, written approval must be obtained from an employee’s manager.
Employees must maintain the privacy of customers, other employees and shareholders and only use information for the purpose for which it was collected.
Employees are not to make public comment about CCP Technologies Ltd. in such a way that implies that they are speaking no behalf of the company, unless their position includes such responsibility.
Employees who leave the company continue to be obliged to maintain the confidentiality of information relating to CCP Technologies Ltd. Such information cannot be used or given to others without prior written approval of the company.
Treatment Of Colleagues
Employees must treat other employees, customers, suppliers, contractors and members of the public with respect and courtesy in a fair, honest and open manner.
Employees must ensure that they do not harm, defame, slander or wrongly discriminate against any person. Discrimination or harassment may occur because of a person’s sex, marital status, pregnancy, age, race, colour, ethno-religious background, descent or national identity, disability, homosexuality and transgender.
It is CCP Technologies Ltd.’s policy that equal employment opportunities will be provided to persons with the required qualifications, skills and experience regardless of their race, nationality, religion, gender, sexual orientation, age , marital status, or membership of any other group protected by law.
CCP Technologies Ltd. will not tolerate discrimination or harassment in the work environment.
CCP Technologies Ltd. is committed to providing a safe working environment for directors and employees, and all directors and employees are required to be aware of the safety procedures relevant to their participation in the CCP Technologies Ltd. working environment.
CCP Technologies Ltd. is committed to providing a workplace free from the effects of drug and alcohol abuse.
Political Contributions And Activities
No political donations will be made by CCP Technologies Ltd. without the prior approval of the board of the company. Such donations will only be made if the board determines that it is in the best interests of the shareholders to make such donations.
Employees being involved in political or community activities must ensure that no conflict arises with their position in the company and no confidential company information is used in such political activity without prior written approval of the CEO of the company.
Political activity includes being a candidate for federal, state or local government; being a member, fundraiser or spokesperson for a political part, cause or lobby group, or being publicly involved in a well-publicised community issue.
The Board will not tolerate the payment of bribes to public officials or other persons, companies or government bodies anywhere in the world.
Gifts And Entertainment
Giving Of Gifts
Situations may arise where it is appropriate to give a corporate gift or goodwill gesture, recognising a significant occasion (eg. an overseas delegation). The CEO’s approval is required and in any case the gift should be modest and appropriate for the occasion.
Similarly, entertainment may be appropriate where persons outside the company are involved. If the expense is to be borne by the company, a manager senior to the most senior person attending the function must first approve, in principle, the expenditure and the actual expenditure.
Employees in such situations should be cautious of not compromising the company’s position in any way through attending/organising such functions.
Acceptance Of Gifts
The seeking or acceptance of gifts, gratuities, entertainment or other benefits by directors or employees, or by members of their immediate family from present or potential customers, suppliers or consultants in connection with existing or prospective business with the company is likely to create a conflict of interest.
Directors or employees should not accept such benefits where that is likely to affect their judgement in the performance of their duties, and in any case must only be nominal benefits which are not provided on a regular or frequent basis.