Company Integrity Policy

Policy Statement

Bribery  is  the offering,  promising,  giving,  accepting  or  soliciting  of  an advantage as  an inducement for  action  which  is  illegal or  a  breach of  trust.  A bribe is an inducement or reward offered, promised or provided in order to gain any  commercial, contractual, regulatory or personal advantage.

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings  and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption within New Zealand in respect of our conduct. Bribery and corruption are punishable for individuals which includes  imprisonment  and fines, and if we are found to  have taken part in corruption,  we  could  also face prosecution and face damage to our reputation and business.

We therefore take our legal responsibilities very seriously.

Who is Covered by the Policy

In  this  policy, third party means any individual or organisation you come into contact with during the course of your  employment or work for us, and includes actual and potential clients, customers, suppliers, distributors, business   contacts,  agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all ITL Technologies Staff working at all levels, including the Management Team, Directors,  employees (whether permanent, fixed-term or temporary), consultants, contractors, seconded  staff, casual workers,  or any  other  person associated with  us.

This policy covers:

• Bribes;
• Gifts and hospitality;
• Facilitation payments;
• Political contributions;
• Charitable contributions

Bribes

Employees must not engage in any form of  bribery,  either directly or through any third party

Gifts and Hospitality

Employees must not offer or give any gift or hospitality:

• Without express permission from Management
• Which could  be regarded as  illegal  or  improper,  or  which  violates  the recipient’s policies

Employees may not accept any gift or hospitality:

• from our business partners, suppliers or others unless it is approved by Management
• Any gifts are to be handed to Senior Management

Facilitation payments

Facilitation  payments are a form of bribery made for the purpose of expediting or facilitating the performance of a  public official for a routine governmental action, and not to obtain or retain business or any improper business   advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to. Our strict policy is that facilitation payments must not be paid.

Political contributions

We do not make donations, whether  in  cash  or  kind,  in  support  of  any  political  parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

Charitable contributions

Charitable support and donations are acceptable, whether of in-kind services, knowledge, time, or direct financial  contributions.

We only make charitable donations that are legal and ethical under local laws and practices.

No donation must be offered or made on behalf of the business without the prior approval of Senior Management.

What to do if you are a victim of bribery or corruption

It is important that you tell someone from Senior Management as soon as possible if you are offered a  bribe by a third  party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about  possible repercussions.  We  aim to encourage openness  and will support  anyone who raises  genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery  or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

Detrimental treatment includes dismissal,  disciplinary  action, threats  or  other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should raise it formally using the company’s Grievance Procedure.