UN GLOBAL COMPACT & ANTI-BRIBERY POLICY

Hereby, the company, aligned with the ten principles of the UN Global Compact, guarantees:

• The well-being of employees and the balance of power equation via the use of organograms, while firmly condemns any sort of human rights infringement.
• A safe working environment for all employees, in respect of the legal age of employment and gender equality. Therefore, Swiss Approval effectively contributes to the abolition of child labour, the elimination of force labour and gender discrimination.
• An environmentally-friendly operation policy. In association with its clients, the company is orientated towards eco-friendly methods and guidelines, empowering sustainability. As a notified organisation, Swiss Approval seeks to ensure that certain environmental standards are met.
• Transparency in business practice. The company’s profile and its long-term history are clear indicators of long-lasting trust. Swiss Approval’s strategy on decision-making, involving pluralism and fruitful criticism in projects’ progress and execution, constitutes an efficacious way of fighting against corruption and extortion.

Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity.

As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. We must not, and we must ensure that any third party acting on our behalf does not, act corruptly in our dealings with any other person.

This anti-bribery and corruption policy sets out SWISS APPROVAL Policies to prevent acts of bribery and corruption. These policies and procedures have been designed to comply with legislation governing bribery and corruption on a global basis.

This policy provides guidance on the standards of behavior to which SWISS APPROVAL PERSONNEL adhere and most of these reflect the common sense and good business practices that we all work to in any event. This policy is designed to help all involved people to identify, when something is prohibited, so that bribery and corruption is avoided, and provide Personnel with help and guidance.

Who this policy applies to

The fundamental standards of integrity under which SWISS APPROVAL operates, do not vary depending on where we work or who we are dealing with.

This policy applies to all officers, employees (full and part time) and temporary workers (such as consultants or contractors) (together referred to as “employees” in this document) across the SWISS APPROVAL Group, no matter where they are located or what they do. It is the responsibility of each of us to ensure that we comply with these standards in our daily working lives. This policy sets out a single standard that all employees must comply with, regardless of whether local law or practices might permit something to the contrary.

Part of commitment to prevent bribery and corruption is to ensure that the people acting on behalf of SWISS APPROVAL, also do so in compliance with effective anti-bribery and corruption policies. Accordingly, where we engage third parties such as agents, distributors or joint venture partners, we have obligations to complete sufficient due diligence when entering into arrangements, to ensure that they are not acting corruptly, and to periodically monitor their performance to ensure ongoing compliance.

Failure to comply with this policy, whether or not this is intentional, may lead to disciplinary action (up to and including dismissal), and criminal liability for the individual involved (up to and including imprisonment). Employees will be required to confirm that they have read and understood the policy and that they comply with its terms as part of their ongoing employment assessment processes. In addition, relevant employees will be required to attend training to support the guidance in this policy.

Getting help

If you are unsure about your obligations under this policy, you should contact one of the following people for help:

• in the first instance, SWISS APPROVAL Ombudsman, acting as anti-bribery and corruption officer: Via G. Corti 5, CH6828, Balerna, Switzerland.

What is Bribery? Bribery involves the following:

• when a financial or other advantage is offered, given or promised to another person with the intention to induce or reward them or another person to perform their responsibilities or duties improperly (it does not   have to be the person to whom the bribe is offered that acts  improperly); or

• when a financial or other advantage is requested, agreed to be received or accepted by another person with the intention of inducing or rewarding  them or another person to perform their responsibilities or   duties inappropriately (it does not have to be the person who receives the bribe that acts improperly).

It does not matter whether the bribe is:

• given or received directly or through a third party (such as someone  acting on SWISS APPROVAL behalf, for example an agent, distributor, supplier, joint venture partner or other intermediary); or

• for the benefit of the recipient or some other person.

Bribes can take many forms, for example:

• money (or cash equivalent such as shares); • unreasonable gifts, entertainment or hospitality; • kickbacks; • unwarranted rebates or excessive commissions (e.g. to sales agents or marketing agents); • unwarranted allowances or expenses; • “facilitation” payments/payments made to perform their normal job more quickly and/or prioritise a particular customer; • political/charitable contributions; • uncompensated use of company services or facilities; or • anything else of value.

This policy applies to both the public and private sectors. Dealing with public officials poses a particular high risk in relation to bribery and corruption and specific guidance when dealing with public officials is set out below.

A breach of bribery laws can result in fines for both the company and the individual involved and in some jurisdictions could also result in imprisonment.

Appropriate due diligence should be undertaken before any third parties are engaged. The appropriate level of due diligence will vary depending on the circumstances and you should use your judgement on a case by case basis.

Dealing with public officials

Although this policy applies to both public and private sectors, dealing with public officials poses a particularly high risk in relation to bribery due to the strict rules and regulations in many countries.

Public officials include those in government departments, but also employees of government owned or controlled commercial enterprises, international organizations, political parties and political candidates.

The provision of money or anything else of value, no matter how small, to any public official for the purpose of influencing them in their official capacity is prohibited.

In accordance with the SWISS APPROVAL Code of Ethics, political donations by or on behalf of SWISS APPROVAL are also prohibited. Compliance with the policy It is the responsibility of your local anti-bribery and corruption officer to ensure compliance with this policy in each business. Ultimate responsibility for compliance with this policy throughout the group is taken by the Group Ombudsman Officer. However, each of Swiss Approval Personnel has an obligation to act with integrity and to ensure that we understand and comply with the policy. Ongoing compliance will be monitored and reported by Internal Audit.

Training will be provided to relevant employees throughout the group to support them in complying with their responsibilities. In addition, all employees will be required to confirm that they have understood and complied with the policy annually. Whistleblowing SWISS APPROVAL is committed to ensuring that employees can speak up with confidence if they have any concerns or need to ask for help. If Swiss Approval Personnel suspect or observe anything that they think might be in contravention of this policy, they have an obligation to report it. Everybody should raise his/her concerns with our local anti-bribery and corruption officer in the first instance. Alternatively, everybody can report the concerns to the Corporate Ombudsman.

SWISS APPROVAL will not tolerate retaliation in any form against anyone for raising concerns or reporting what they genuinely believe to be improper, unethical or inappropriate behavior. All reports will be treated confidentially.

It is illegal to offer, promise, give, request, agree, receive or accept bribes – this anti-bribery policy can help protect SWISS APPROVAL business.