Code of Conduct

Code of Conduct:

Brasia (“Company) is committed to the highest standards of social and environmental responsibility and ethical conduct. This Code sets out the basic standard of conduct expected of all staff (including company directors, full-time staff, part-time staff and temporary workers) employed by the Company and its subsidiaries, and the Company’s policy on acceptance of advantage and handling of conflict of interest when dealing with the Company’s business.

Prevention of Bribery

The Company prohibits all forms of bribery and corruption. All staff are prohibited from soliciting, accepting or offering any bribe in conducting the Company’s business or affairs.

(a) Solicit or accept any advantage from suppliers, business partners or any third parties as a reward for or inducement to doing any act or showing favor in relation to the Company’s business or affairs, or offer any advantage to an agent of another for this purpose;

(b) Offer any advantage to any public servant (including Government / public body employee) as a reward for or inducement to his performing any act in his official capacity or his showing any favor or providing any assistance in business dealing with the Government / a public body; or

(c) Offer any advantage to any staff of a Government department or public body while they are having business dealing with the latter.

Acceptance of Advantage

It is the Company’s policy that staff should not solicit or accept any advantage for themselves or others, from any person, company or organization having business dealings with the Company or any subordinate.

A staff member should decline an offer of advantage if acceptance could affect his/her objectivity in conducting the Company’s business or induce him/her to act against the interest of the Company, or acceptance will likely lead to perception or allegation of impropriety.

If a staff member has to act on behalf of a client in the course of carrying out of Company’s business, he/she should also comply with any additional restrictions on acceptance of advantage that may be set by the client (e.g. staff members performing any duties under a government or public body contract will normally be prohibited from accepting advantages in relation to that contract).

Offer of Advantage
Staff are prohibited from offering advantages to any director, staff member or agent of another company or organization, for the purpose of influencing such person in any dealing, or any public official, whether directly or indirectly through a third party, when conducting the Company’s business. Even when an offer of advantage carries no intention of improper influence, it should be ascertained that the intended recipient is permitted by his employer/principal to accept it under the relevant circumstance before the advantage is offered.

Fraud & Theft
Theft is characterized as taking what doesn’t belong to you without permission. It can include physically taking something like money or property, or it can be done through other means like forgery, embezzlement and fraud.

Fraud can take many forms, but it always involves dishonesty. It involves making someone believe (by words or conduct or by concealing important information) something that is not true, with the intent ofhaving them take (or refrain from taking) some action in reliance on the misrepresentation with the result that they suffer economic harm.

When employees steal or commit fraud, it damages the Company`s reputation. Regardless of whom benefits, any act that involves theft, fraud, embezzlement or misappropriation of property, money, or services, include that of the Company or any of its employees, vendors, suppliers, or clients is strictly prohibited.

Any employee who engages in or assists others with theft or fraud will be subject to disciplinary action up to and including termination and will also be subject to prosecution.

Employees must report suspicious activity immediately.

Entertainment
Although entertainment is an acceptable form of business and social behavior, a staff member should avoid accepting lavish or frequent entertainment from persons with whom the Company has business dealing (e.g. suppliers or contractors) or from his/her subordinates to avoid placing himself/herself in a position of obligation.

Records, Accounts and Other Documents
Staff should ensure that all records, receipts, accounts or other documents they submit to the Company give a true representation of the facts, events or business transactions as shown in the document. Intentional use of documents containing false information to deceive or mislead the Company, regardless of whether there is any gain or advantage involved, may constitute an offence.

Compliance with Laws
Staff must comply with all local laws and regulations when conducting the Company’s business, and those in other jurisdictions, when conducting business there or where applicable.

Conflict of Interest

A conflict of interest exists whenever business or personal circumstances impair professional judgment or the ability to act in the interests of the Company or its clients.

Staff should avoid any conflict of interest situation (i.e. situation where their private interest conflicts with the interest of the Company) or the perception of such conflicts. When actual or potential conflict of interest arises, the staff member should immediately inform management of the Company.

Staff must not misuse their official position in the Company to pursue their own private interests, which include both financial and personal interests and those of their family members, relatives or close personal friends.

Staff in charge of or having access to any Company assets, including funds, property, information, and intellectual property, should use them solely for the purpose of conducting the Company’s business. Unauthorized use, such as misuse for personal interest, is strictly prohibited.

Staff should not disclose any classified information of the Company without authorization or misuse any Company information (e.g. unauthorized sale of the information). Those who have access to or are in control of such information, including information in the Company’s computer system, should protect the information from unauthorized disclosure or misuse.

Special care should also be taken in the use of any personal data, including directors’, staff’s and clients’ personal data, to ensure compliance with local Privacy laws.

Staff should not ask for or accept personal favors from subordinates, or ask subordinates to perform personal errands.

Compliance with the Code

It is the responsibility of every staff member of the Company to understand and comply with this Code. Managers and supervisors should also ensure that the staff under their supervision understand well and comply with this Code.

Any staff member in breach of this Code will be subject to disciplinary action, including termination of appointment. Any enquiries about this Code or reports of possible breaches of this Code should be made to the Company`s management and CEO. In cases of suspected corruption or other criminal offences, a report should be made to the appropriate authority.