Code of conduct

CSR BootIQ hereby adopts the following Code of Conduct with respect to all commercial transactions, whether local or international:

Local and foreign laws: Neither CSR BootIQ, nor anyone acting on behalf of CSR BootIQ may, directly or indirectly, break or seek to evade the laws or regulations of any country in, through, or with which CSR BootIQ seeks to do business. That an illegal act is a 'customary business practice' in any country is not sufficient justification for violation of this provision.

Bribery and facilitating payments: Neither CSR BootIQ, nor anyone acting on behalf of CSR BootIQ may, directly or indirectly, offer or provide a bribe, and all demands for bribes must be expressly rejected.

Bribery includes any offer, promise or gift of any pecuniary or other advantage, whether directly or through intermediaries, to a public official, political party, political candidate or party official or any private sector employee, in order that the official or employee act or refrain from acting in relation to the performance of their duties, in order to obtain or retain business or other business advantage.

Neither CSR BootIQ, nor anyone acting on behalf of CSR BootIQ shall offer or make facilitating payments to government officials in order to encourage them to expedite a routine governmental task that they are otherwise required to undertake. CSR BootIQ or anyone acting on behalf of CSR BootIQ shall have discretion to deviate from this prohibition if he/she believes that there is an immediate threat to his/her or another's health or safety. The circumstances of such payment must be reported as soon as possible after the event and the payment properly recorded. CSR BootIQ recognizes that extortion is widespread and that the participation by the business community increases demand for facilitating payments.

Kick-backs: Neither CSR BootIQ, nor anyone acting on behalf of CSR BootIQ may offer or accept a 'kick-back' of any portion of a contract payment to employees of other parties to a contract or use other vehicles such as subcontracts, purchase orders or consulting agreements to channel payments to government officials, political candidates, employees of other parties to a contract, their relatives or business associates.

A 'kick-back' is a particular form of bribe which takes place when a person entrusted by an employer or public function has some responsibility for the granting of a benefit and does so in a way that secures a return (kickback) of some of the value of that transaction or benefit for that person without the knowledge or authorization of the employer or public body to which the person is accountable.

Conflicts of interests: CSR BootIQ and anyone acting on behalf of CSR BootIQ, shall avoid any relationship or activity that might impair, or appear to impair, the ability to render objective and appropriate business decisions in the performance of our jobs.

Political contributions: Neither CSR BootIQ, nor anyone acting on behalf of CSR BootIQ may make a political contribution in order to obtain an unlawful business advantage. CSR BootIQ shall comply with all public disclosures requirements.

Philantropic contributions: CSR BootIQ, and anyone acting on behalf of CSR BootIQ, may make contributions only for bona fide charitable purposes and only where permitted by the laws of the country in which the contribution is made. Contributions made in order to obtain an unlawful business advantage are prohibited.

Extortion: CSR BootIQ, and anyone acting on behalf of CSR BootIQ, shall reject any direct or indirect request by a public official, politicla party, party official, or private sector employee for undue pecuniary or other advantag, to act or refrain from acting in relation to his/her duties.

Gifts, hsopitality and entertainment: CSR BootIQ, and anyone acting on behalf of CSR BootIQ, shall avoid the offer or receipt of gifts, meals, entertainment, hospitality or payment of expenses where these could materially affect the outcome of a business transaction, are not reasonable and bona fide expenditures, or are in violation of the laws of the country of the recipient.

Reporting requirements: All officers and employees of CSR BootIQ and anyone acting on behalf of CSR BootIQ shall promptly report any actual or potential violation of the Code of Conduct, including any instance in which he/she is subjected to any form of extorsion or is asked to participate in any way in a bribery scheme, to CSR BootIQ senior corporate management, without fear that his/her business relationship or employment will adversely affected. Reports shall be treated confidentially to the extent possible, consistent with the need to conduct a thorough investigation.

Company response: No employee will suffer demotion, penalty, or other adverse consequences for not paying bribes even when CSR BootIQ may loose business as a result of the employee's refusal to do so. Employees are required to report alleged violations of this Code of Conduct to senior management and no employee will suffer demotion, penalty or adverse consequences for reporting.

CSR BootIQ shall, where appropriate, sanction employees, suppliers or other business partners for violations of this Code of Conduct.

Accounts: CSR BootIQ shall maintain complete and accurate financial records, ensuring that all transactions are properly, accurately and fairly recorded in a single set of books.

Communications and training: CSR BootIQ consultants participated in anti-corruption training, and will make annual training available for all principals and for all key employees involved in sales, marketing and procurement.