Ethical Policy Statement

Purpose

Sunbeam Consulting Ltd is committed to responsible corporate behavior. This governs the way we interact with our key customers, employees, suppliers and the setting in which we operate, including governments, society, local communities, and the environment.

The Company's reputation, together with the trust and confidence of those with whom it deals, is one of its most valuable assets. It is therefore essential that all employees accept responsibility for maintaining Sunbeam Consulting Ltd’s excellence in this area.

Sunbeam Consulting Ltd’s corporate values, which include Integrity and Responsibility, must underpin all that we do. The policies that we have in place, which provide guidance on the ethical standards by which we operate, must be adhered to. This code is not expected to cover every ethical circumstance so we ask employees to seek advice from their Team Leader/ Manager if they are in any doubt. We require our Suppliers to share with us annually their Ethical Policy Statements and update us with how they have developed this from the previous year.

Our Customers

We believe that integrity in dealing with customers is a prerequisite for a successful and sustained business relationship. This principle governs all aspects of our approach. We value our customers and the trust that they place in us. We will safeguard the information provided to us by our customers in accordance with relevant laws and contractual commitments. We are honest about the products and services we provide and would never intentionally misrepresent these.

Our Employees

Relations with our employees are based on respect. We are committed to a working environment where there is mutual trust and respect and where everyone is accountable for their own actions and believes themselves to be responsible for the performance and reputation of our Company.

We aim to recruit, employ and promote employees on the sole basis of their ability and are committed to developing and enhancing each employee's skills and capabilities. Our policies are designed to provide employees with safe and healthy working conditions and practices, and to enable everyone to work free from discrimination, harassment or bullying of any kind.

In return we expect our employees to act with integrity and maintain high ethical standards.

Conflicts of Interest

The receipt of gifts or favours can give rise to embarrassing situations and may be unlawful. Employees must not compromise either themselves or the Company in the conduct of Company business.

The following principles should be applied:

Gifts or favours must not be solicited

Gifts of money must never be given or accepted

Reasonable small tokens and hospitality may be accepted provided they do not place the recipient under any obligation, do not breach any applicable law and are not capable of being misconstrued.

If an employee receives a gift or offer of hospitality their Team Leader/Manager must be notified to ensure that acceptance is appropriate.

Employees cannot engage in an activity for personal gain that is in conflict with the Company's business interests or applicable law, and must disclose to the Company any personal interest, or interests of their immediate family that could create a potential conflict of interest.