GMCS CODE OF CONDUCT

We work in an honest and ethical manner. Each member of our team is committed to acting professionally, fairly and with integrity in all business dealings and relationships.

This Code applies to all persons working for or on behalf of GMCS Group including employees, directors, officers, agency workers, seconded workers, volunteers, interns, contractors, and external consultants.

If you become aware of or suspect violation of this Code, you must report to your manager or GMCS Ethics Officer. All reports will be duly investigated. Any GMCS GROUP employee or contractor who breaches this Code will face disciplinary action, which could result in termination of employment or contractual relationship. No retaliation against any employee who raised a concern in good faith will be allowed or tolerated.

Commitment to Ethical Conduct

We strive to maintain a culture of openness and trust where each employee and business partner is entitled to be treated fairly. We operate in a multi-cultural environment where we treat everyone with respect. In all of our countries of operations we comply with applicable laws, regulations, and ethical norms.

GMCS managers are committed to honest and ethical conduct and are open at all times to discussing concerns or suggestions for our business conduct or any ethical issues that may arise.

No Conflict of Interest

GMCS managers, employees and contractors must disclose all actual or potential conflict of interest that exists or may be expected to arise in connection with their position.

No Bribery

GMCS GROUP has a zero-tolerance approach to bribery and corruption. All forms of bribery are strictly prohibited. Bribery includes offering, promising, giving, accepting or seeking a bribe.

Bribery means any inducement or reward for action which is illegal or unethical in any way. Bribes can be in the form of money, gifts, loans, services, discounts, the award of a contract or any other unfair advantage or benefit, including:

■ offering any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

■ accepting any offer from a third party that is made with the expectation of a business advantage;

■ offering any payment to a government official in any country to facilitate or speed up a routine or necessary procedure.

If you are unsure about whether a particular act constitutes bribery, raise it with your manager or our Ethics Officer.

Gifts

This Code does not prohibit giving or accepting gifts that are reasonable and appropriate for legitimate purposes such as building relationships, maintaining or promoting GMCS image or reputation. In determining whether a gift is appropriate, you must take into account its value and the circumstances.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret.

GMCS promotional goods may be offered freely and you may accept equivalent corporate promotional gifts of appropriate value from our parters.

In all cases, all gifts and hospitality offered or received on behalf of GMCS Group must be recorded and submitted to your manager in accordance with our expenses policy. If you are not sure whether a gift is appropriate, you must ask your manager of contact our Ethics Officer.