The Board has adopted this Code of Conduct to define basic principles of business conduct. The Code requires officers and employees to abide by the policies of the Company and the law. The Code is a set of principles giving direction and reflecting the Company’s approach to business conduct and is not a prescriptive list of rules for business behaviour.

Officers and employees will observe appropriate principles of behavior when conducting company business and interacting with others.

  1. Compliance with laws and regulations – Directors, officers and employees will act in compliance with all laws and regulations that apply to the Company’s business.
  2. Directors, officers and employees should discuss with their manager and if necessary obtain the consent of the Managing Director or Chairman to seek advice from one of the Company’s legal advisors if they are unclear about any laws or regulations relating to their work.
  3. Trading in Shares – Any trading of the Company’s shares must be done in accordance with the Share Trading Policy.
  4. Intellectual property – Each officer and employee is responsible for protecting the intellectual property
  5. Company’s intellectual property rights. All intellectual property that an employee or contractor generates in relation to the Company is the property of the Company.
  1. Openness, honesty, fairness and integrity – Officers and employees will conduct themselves with openness, honesty, fairness and integrity in business transactions and in dealings with others.
  2. Mutual respect – Employees are expected to treat everyone else with whom they interact in their work with courtesy and respect.
  3. Ethical conduct – Officers and employees will act ethically in their approach to business decisions.
  4. Compliance with Laws – Employees are expected to comply with all laws and
    regulations that govern the Company’s business and the policies that the Company adopts from time to time.

Customer service is a top priority of the Webscreations Design. All Webscreations Design customers will be treated promptly and respectfully without regard to age, gender, sexual orientation, race, ethnicity, disability, language proficiency, social or economic status Regulations;
a. Staff members are responsible for providing the best customer service possible and are empowered to make decisions that will ensure the best experience for each customer while balancing the needs of the individual with the overall needs of Webscreations Design customers.
b. When answering the phone, a Webscreations Design employee will identify him or her self and the department in which (s)he works.
c. Staff will assist customers on a first come, first served basis to the extent possible without infringing on the service needs of other customers.
d. A customer with complaints about the service received or about Webscreations Design policy shall be referred to the senior staff on duty at the time or to the Webscreations Design director. The business cards of senior staff and the Webscreations Design director are available.

Webscreations Design employees:
Are committed to a healthy and safe work environment.
Aim to remove or reduce the risks to the health, safety and welfare of all employees, contractors and visitors, and anyone else who may be affected by our business operations.
Aim to ensure all work activities are done safely.
Responsibilities
Management (the supervisor and / or manager) is responsible for providing and maintaining:
• a safe working environment
• safe systems of work
• plant and substances in safe condition
• facilities for the welfare of all employees
• any information, instruction, training and supervision needed to make sure that all employees are safe from injury and risks to their health
Employees are responsible for:
• comply with safe work practices, with the intent of avoiding injury to themselves and others and damage to plant and equipment.
• take reasonable care of the health and safety of themselves and others
• wear personal protective equipment and clothing where necessary
• comply with any direction given by management for health and safety
• not misuse or interfere with anything provided for health and safety
• report all accidents and incidents on the job immediately, no matter how trivial
• report all known or observed hazards to their supervisor or manager.

a. Financial integrity – The Company has stringent financial accounting procedures that are overseen by management, the audit committee and the external auditor. The use of Company funds or assets for any unethical purpose is prohibited.
b. Giving gifts – The Company does not allow the making of payments or payments in kind (gifts, favours etc) to induce individuals to award business opportunities to the company or to make a decision in the Company’s favour. The Company recognises that it is accepted business practice that entertainment and small gifts may be extended to customers and other third parties with whom the Company has a relationship. However, any such gifts must be made for a proper purpose.
c. Accepting gifts – Officers and employees should not accept personal gifts or
extraordinary hospitality, accommodation or travel which may influence, or appear to influence, a business decision.
d. Business agreements and contracts – The Company expects to compete fairly and ethically for all business opportunities. Officers and employees involved in the negotiation of agreements and contracts must ensure that they act in accordance with the law. All appropriate approvals must be obtained before contracts are executed.
e. The Company is committed to meeting its contractual obligations.
f. Confidentiality and privacy – Officers and employees may not at any time, directly or indirectly, profit from confidential information obtained during the course of duties they perform on behalf of the Company.
g. Each employee must safeguard confidential information of the Company by not
transferring, publishing, using or disclosing it other than when necessary in the ordinary course of business, or as specifically directed or authorized. All confidential or proprietary information that has been entrusted to the Company by a third party must be treated as if it was the Company’s confidential information and all officers and employees must adhere to the Company’s privacy obligations.
h. Public Statements – Public statements have the potential to breach the Company’s obligations in respect to confidential information, share trading and continuous disclosure.
i. Officers and employees should not make public statements unless
authorized by the Chairman or Managing Director.
j. Smoking and the use of drugs and alcohol – A safe and healthy work environment is the responsibility of every employee. This obligation includes responsible behavior with respect to the use of alcohol, drugs and tobacco when conducting Company business and at Company sponsored activities.
k. Smoking and the use of recreational or non-prescription drugs is not permitted on Company premises.
l. Gathering information on the Company’s competitors – Information should not be gained through unlawful or deceitful means.
m. Conflict of interest – All officers and employees have an obligation to seek to avoid financial, business or other relationships which might be opposed to the interests of the Company or which may conflict with the performance of their duties. If you have any doubt about conflicts of interest, you should contact your manager or the company Secretary.
n. Use of Company’s resources – Employees must use all Company assets for proper purposes during their employment with the Company. No property of the Company may be sold, loaned, given away, or otherwise disposed of, without proper authorization.
o. Email and Internet – The Company’s email and internet systems have been developed to assist communication with stakeholders, suppliers and between staff. These facilities may not be used for personal gain or in a manner which may breach the law or is inappropriate for an officer or employee of the Company.

Webscreations Design absolutely forbids corruption and the paying or receipt of bribes for any purpose.
Bribery – Bribery is the offering, promising, giving, solicitation or the receipt or agreement to receive any financial or other advantage, or any other inducement from any person or company, (wherever they are situated and whether they are a public official or body, or a private person or company), by an individual employee, agent or other person or body acting on another’s behalf.
Corruption – Corruption is the abuse of entrusted power for a private gain.
The Group prohibits:
Bribery of or by any person or company, in any jurisdiction, wherever they are situated and whether they are a public official or body or private person or company or by any individual employee, agent or other person or body acting on Webscreations Design’s behalf in order to;
a. gain any commercial, contractual or regulatory advantage for Webscreations Design in a way which is unethical or
b. gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual or
c. induce the improper performance of any function that is of a public nature, connected with a business, performed by a body or performed by a person in the course of their employment.
When acting for Webscreations Design, political contributions are not allowed and charitable contributions are allowed only within agreed Corporate schemes and guidelines.
Facilitation payments are any payment made (except where comprised in a lawful and published tariff of general application) as an inducement to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal entitlement. These are not permitted or condoned by Webscreations Design.

It is the responsibility of the Board to monitor and ensure compliance with the Code of Conduct and to record, investigate and, where necessary, take action in respect of suspected breaches.
Ensuring compliance with this Code is not always easy and we therefore ask for your help. If you suspect that any fraudulent or unethical behaviour has occurred, you should contact any member of the Board, the Managing Director or the Company Secretary. The Company does not expect that concerned members of staff (Whistleblowers) will have unquestionable evidence to support their suspicions. It is the Company’s responsibility to investigate and determine whether the suspicions are justified and supported by evidence.
All communications from Whistleblowers will be treated with the strictest confidence and the Whistleblower’s identity will not be revealed without their consent. Provided that the concern is raised in good faith, Whistleblowers will not be at any risk of losing their job or suffering any form of reprisal for coming forward. Furthermore, the Company will take all reasonable steps to prevent the harassment or victimisation of the Whistleblower. However, no assurances are offered to members of staff who maliciously raise matters which they know to be untrue. This will be regarded as misconduct and dealt with accordingly.
The Board, the Managing Director or the Company may refer matters raised by
Whistleblowers to a designated investigating officer. Investigations will be conducted confidentially and, if the Whistleblower requests, without disclosing the Whistleblower’s identity. In rare cases, it may be not be possible to ensure complete confidentiality (eg if legal proceedings take place), however the Whistleblower’s identity will not be revealed without their consent and the Company will do everything possible to support and protect the Whistleblower. The investigating officer will keep the Whistleblower informed with regard to the progress of the investigation and what action, if any, the Company will take in response to the Whistleblower’s concerns.

More information

If you wish to obtain more information regarding any aspect of the Company’s Code of Conduct, please consult the Company Secretary.
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