Code of Business Conduct |

1. INTRODUCING OUR CODE

Working with global clients and partners, Alegrant is committed to being a good corporate citizen. To ensure compliance with the law and our ethical principles, ou Code of Business Conduct is a way of providing guidelines for all partners, employees, directors and executives.

The purpose of this Code is to provide an ethical framework within which we all must work.

Alegrant directors and executives have a special responsibility for ensuring compliance with this Code. They must take the appropriate measures to ensure that there are no violations of laws, internal guidelines or this Business Code that could have been prevented or hindered by due and proper performance of their supervisory obligations. This does not discharge the employees from their own responsibility. Each employee is answerable for his/her own conduct.

The code of conduct aims at all employees, suppliers, clients, business partners. All employees shall encourage third parties to comply with the aims and objectives of this Business Code.

2. OBEYING THE LAW

2.1 Compliance Policy Statement

Alegrant is committed to meet its legal obligation and comply with national, regional and international regulations. We respect the law at all times and compliance with all applicable laws and regulations must never be compromised.

2.2 Scope

Alegrant requires its staff, and organisations we engage with commercially, to meet their legal obligations and comply with national requirements. The principles contained within this policy apply to both internal and external audiences, including anyone wishing to undertake business or engage with Alegrant.

2.3 Compliance with the law and responsibility

All employees must comply with the laws and regulations. Additionally, employees shall adhere to internal rules and regulations as they apply in a given situation. Those internal rules are specific to Alegrant and may go beyond what is required by the law.

2.4 Foreign Trade

When doing business abroad, we and our partners comply with all foreign trade, tax and customs legislation in force in their countries in question. All employees must comply with these controls when products or services are bought or put into circulation. Export controls generally apply not only to the delivery of goods, but also to the performance of services and the transfer of technology.

2.5 Maintaining Accurate Records

Our customers, business partners as well as government regulators rely on the accuracy and correctness of the information contained within our business records. We therefore have a responsibility to ensure that the information we provide is accurate, timely, complete, fair and understandable. We do not create, or participate in the creation, of records that attempt to mislead anyone or conceal any improper activity. This means, in part, that we must never make false or misleading entries or allow or facilitate improper or insufficient disclosures.

3. PROTECTING OUR TRADE

3.1 Anti-Bribery Policy

3.1.1 Anti-Bribery Policy Statement

Bribery is not only detrimental to global trade but it stifles innovation, competition and it is illegal. Only clean business is sustainable business. Rejecting corruption protects Alegrant reputation as well as customers and business partners confidence. Alegrant has a zero tolerance policy towards corruption of any kind.

3.1.2 Scope¹

Alegrant requires its staff, and organisations we engage with commercially, to act honestly and with integrity. The principles contained within this policy apply to both internal and external audiences, including anyone wishing to undertake business or engage with Alegrant.

3.1.3 Active bribery

Alegrant will not tolerate any internal action which encourages, implies, bestows, tolerates or promises an unfair, unlawful, improper or unethical advantage to any individual, group or organisation, regardless of whether there is financial inducement or not.

3.1.4 Passive bribery

Alegrant will not tolerate the acceptance of bribes to induce a favourable investment or regulatory decision, transaction or other business outcome.

At all times Alegrant expects its Executive Directors, staff and consultants acting on our behalf to conduct their work ethically and to fully comply with their terms and conditions of employment and Alegrant policies and procedures.

3.1.5 Third Parties

When commissioning third parties (e.g. advisers, brokers, sponsors, representatives and other agents) to act for Alegrant in the context of business dealings, care must also be taken to ensure that these persons do not use any unfair business practices. In particular, employees may not use third parties to circumvent the above rules.

3.1.6 Suppliers

Suppliers are to be selected on the basis of objective criteria, such as prices, quality and performance. Relations with suppliers are based on trust and honesty. Offers must be assessed fairly and impartially, and personal and arbitrary considerations may not be factored into the decision-making process.

3.1.7 Donations and Sponsorship

Donations and sponsorships must be transparent and traceable. They may not be abused for unlawful purposes. In particular, it is forbidden to grant unfair advantages to third parties in the guise of donations or sponsorships.

3.1.8 Insider Trading and Insider Recommendations

Insider information is specific information about nonpublic business circumstances or events that are capable of influencing the stock market or market price of securities or other financial instruments.

Insider information may only be disclosed to employees who need it for business purposes. Anyone in possession of insider information of Alegrant, it’s suppliers, clients or partners may neither disclose or make available said information to others without authorisation nor use said information to trade in securities or other financial instruments themselves or recommend or induce others to do so.

3.1.9 Cash Payment

It is prohibited for Alegrant employees and directors to accept any cash payments whatsoever.

3.1.10 Conflict of interest

A Conflict of Interest occurs when personal interests of an employee or the interests of a third party compete with the interests of Alegrant. In such a situation, it can be difficult for the employee to act fully in the best interests of Alegrant. No employee may engage in any professional activities that conflict with Alegrant’s interests. This includes activities for a competitor of Alegrant. However, Alegrant acknowledges that conflicts of interest (and potential conflicts) are sometimes unavoidable. In such circumstances the principles of openness and integrity apply and you are required to disclose and manage the conflicts accordingly.

3.2 Anti-Money Laundering Policy

3.2.1 Anti-Money Laundering Policy Statement

Alegrant is committed to provide a safe environment for Traders and Experts. Accordingly, Alegrant seeks to conduct business only with reputable customers and experts who are involved in legitimate business activities, and whose funds are, to our knowledge, derived from legitimate sources. We adopt a zero tolerance approach to all forms of activities associated with money laundering.

3.2.2 Scope²

Alegrant requires its staff, and organisations we engage with commercially, to act honestly and with integrity. The principles contained within this code apply to both internal and external audiences, including anyone wishing to undertake business or engage with Alegrant.

3.2.3 What could be a Suspicious Activity?

Whilst Alegrant take the starting point that most customers will not launder money we have identified factors that may indicate a higher risk of money laundering. This list is by no means exhaustive but includes:

Reluctance of a customer to provide details of their identity
Customer is trying to use intermediaries to hide their identity or involvement
There appears to be no genuine reason for the customer using the business’s services
Money is paid by a third party who does not appear to be connected with the customer
The expert requests payment to a third party who has no apparent connection with them

3.3 Anti-fraud Policy

3.3.1 Anti-Fraud Policy Statement

Alegrant is committed to provide a secure environment for Traders and Experts and therefore ensures that it has adequate controls to counter fraudulent activities. We adopt a zero tolerance approach to all forms of activities associated with fraudulent or criminal acts.

3.3.2 Scope³

3.3.3 What is fraud?

Definition of fraud

Fraud by false representation
Fraud by failing to disclose information
Fraud by abuse of position

Fraud may occur internally or externally and the purpose of this document is to set out responsibilities with regard to fraud prevention, what to do if fraud or irregularity is suspected and the response action that will be taken by management.

3.3.4 How does fraud look like – Examples of fraud risk:

Changes requested to third party bank details to divert payments
Obtaining our sensitive financial, banking or IT information for fraudulent purposes
False orders or claims for work undertaken or false applications for grants or investment
Fraudulent procurement activities such as bid collusion, bribery or other contract related fraud
Actual or attempted theft of operational assets including high-value equipment
Property fraud including diversion of rent, unauthorised land use and encroachment
Inappropriate disclosure or manipulation of data or information for financial gain
IT / cyber-attacks including installation of ransom ware, viruses and similar malware
Miscellaneous employee related fraud including falsified working hours and expense claims and the misuse of corporate credit cards

3.3.5 Fraud warning signs – please look out for:

Urgent and unexpected requests to approve large payments ahead of public holidays or late on Friday afternoon – this is a common fraud tactic as detection may be delayed for several days
Suspicious activities, uncharacteristic behaviour or unexpected displays of conspicuous wealth
Unexpected requests by email, phone or letter to change payment details or contact details –this is a common fraud tactic and independent checks must be made before making changes
Emails with unexpected attachments and especially from non-work related addresses which contain obvious language or spelling errors
Unsolicited requests for sensitive financial information, banking details or IT information
Documents, data, information or applications that appear odd, altered or tampered with
Unexplained changes to a standard procedure or the way somebody works
Evidence that existing procedures have been bypassed or short-circuited
Unusual requests to provide commercially sensitive, confidential or personal information
The overarching feeling that specific fraud controls are less than effective

3.4 Don’t be afraid of raising concerns

Contact immediately Alegrant Management if you suspect bribery, attempted bribery, fraud or attempted fraud. Don’t convey your concerns to anyone other than authorised persons. There may be a perfectly reasonable explanation for the events that give rise to your suspicion. Spreading unsubstantiated concerns may harm innocent persons.
Don’t approach the person you suspect or try to investigate the matter yourself. There are special rules relating to the gathering of evidence for use in criminal cases. Any attempt to gather evidence by persons who are unfamiliar with these rules may destroy the case.
Make a note of your concerns. Record all relevant details, such as the nature of your concern, the names of parties you believe to be involved, details of any telephone or other conversations with names dates and times and any witnesses. Notes do not need to be overly formal, but should be timed, signed and dated.Timeliness is most important. The longer you delay writing up, the greater the chances of recollections becoming distorted and the case being weakened.
Retain any evidence you may have. The quality of evidence is crucial and the more direct and tangible the evidence, the better the chances of an effective investigation.

3.5 Sanctions

Alegrant will notify the appropriate authorities if bribery, attempted bribery, fraud or attempted fraud has been discovered. This is a potential criminal offence and Alegrant will not hesitate to take appropriate disciplinary action. Alegrant will report to the relevant authorities any knowledge regarding money laundering or the proceeds of crime

4. RESPECTING PEOPLE

4.1. Respecting people policy statement

Alegrant believes that human relations should be based on respect, honesty and fairness. We encourage innovation and employee engagement and are committed to maintaining high standards of quality, health and safety.

4.2. Equal opportunity and non-discriminatory treatment

As a company with multi-country partners and clients Alegrant considers cultural diversity as one of its greatest strengths. We promote and support diversity in race, gender, religion, national origin, political opinion, sexual orientation, social origins, age, physical or mental character and beyond. Therefore, discrimination against protected personal characteristics will not be tolerated. Any form of harassment in the workplace, whether physical, visual or verbal is strictly prohibited.

4.3. Open Dialogue

We promote an open and trusting dialogue with employees at all levels. Employees are strongly encouraged to openly communicate, discuss and clarify their questions or concerns. Any direct or indirect retaliation, or attempted retaliation, against an employee who speaks up in good faith is strictly prohibited and will not be tolerated.

4.4. Health and Safety Management

Alegrant recognises that a high level of commitment to Safety, Health and Wellbeing not only makes good business sense but also benefits the company as a whole. In undertaking its duties Alegrant will seek to create and promote a supportive workplace culture based on trust, support and mutual respect, where staff are able to talk openly about health and safety, their physical and mental health and report difficulties without fear or discrimination or reprisal.

All staff have a duty, in the course of their work, to take reasonable care of their own health and safety and that of others who may be affected by their acts or omissions at work and are required to co-operate with Alegrant in undertaking its statutory duties. In addition they must not interfere with or misuse anything that is provided in the interest of health and safety.

5. ENGAGING IN PARTNERSHIP

5.1 Our Customers, suppliers and partners’ confidential information

5.1.1 Engaging in partnership Policy Statements

Alegrant’s customers, suppliers and other partners often entrust us with their own confidential and proprietary information. To be a trustworthy partner, we must handle third-party proprietary information in accordance with the terms of its disclosure and in strict compliance with all applicable laws and regulations. We value and protect our confidential information and we respect the confidential information of others.

5.1.2 Scope

We must protect the property and confidential information of our stakeholders. Protecting confidential data, keeping accurate records, and adhering to all laws governing our business are key to our long-term success.

5.1.3 Protecting our partners’ Confidential Information

Confidential information can be received from customers, suppliers, employees, business partners and other third parties. Similarly to Alegrant, our partners have an interest in protecting their confidential information.

In case that such partners, suppliers or customers, share with Alegrant confidential information, such information shall be treated with the same care as if it was Alegrant’s confidential information.
Conspicuously label, where possible, such information as being proprietary and confidential information and the property of the Disclosing Party (or such third party as may be appropriate)
In that same spirit, employees shall protect confidential information that they have obtained in the course of their prior employment.

Alegrant do not accept third-party proprietary information unless the owner of such information has agreed to its transfer. If we receive third-party proprietary information without authorisation, it must be promptly reported to the management.

5.2 Supplier Code of Conduct

Operating in several countries, Alegrant is aware of its social responsibility and stands by this. By engaging in responsible sourcing, we aim to achieve long-term relationships with our suppliers. We expect our supplier base to understand, share and adhere to our business ethics standards via our Supplier Code of Conduct.

5.2.1 General Principles, Laws and Statutes

The supplier commits to upholding its social responsibility in all business dealings. In all its business activities and decisions, the supplier shall respect the laws in effect and any other applicable provisions in the countries where it is active.

5.2.2 Prohibition of Corruption and Bribery

Any form of corruption, extortion or embezzlement is prohibited, not to be practiced and not be to tolerated. Either at home or abroad, unethical behaviour may not be used to unlawfully influence others in business dealings by exchanging gifts or offering or granting other benefits. The same applies to the unlawful acceptance of benefits.

5.2.3 Respect for the Basic Human Rights of Employees

The supplier respects and supports compliance of internationally recognised human rights. The supplier rejects every form of forced labor and may not employ any person, who is under the statutory minimum age as stated in the applicable laws.

5.2.4 Equal opportunity and non-discriminatory treatment

The supplier is committed to the principle of equal opportunity when selecting and promoting its employees. In doing so, the supplier refrains from any discriminatory treatment on the basis of age, disability, race, ethnic background, skin colour, gender, pregnancy, sexual identity, nationality, religion, marital status, or other characteristics of its employees. Discriminatory behaviour and sexual harassment will not be tolerated.

5.2.5 Freedom to associate

In accordance with local laws, suppliers will respect the rights of their employees to associate freely. Suppliers will neither advantage nor disadvantage employees who act as workers’ representatives or who are members of labor unions.

5.2.6 Working hours and paid holidays

Suppliers will comply with national provisions and agreements regarding working hours and paid holidays.

5.2.7 Health, Safety and Environmental Protection

In order to act in harmony with the environment and to avoid hazards to humans and the environment, compliance with all applicable health, employment and environment-related guidelines is required.

5.2.8 Foreign Trade

All rules under foreign trade, tax and customs law of those countries in which the supplier does business have to be complied with.

5.2.9 Trade and Business Secrets / Data Protection

Trade and Business secrets as well as all other confidential information must be kept strictly confidential. Such information is to be appropriately protected from disclosure to and inspection by third parties.

When using personal data in business dealings, privacy must be protected and the security of such data must be guaranteed.

5.2.10 Supply Chain

The supplier shall promote the compliance of the content of this Supplier Code of Conduct to the best of its ability among its suppliers and sub-suppliers.

6. Contact

Should there be any questions of interpretation or uncertainties with respect to the topics dealt with in this Business Code, or should employees be aware of any violations of this Business Code, they can contact Alegrant Management in confidence.