Policy Statement

In keeping with the Code of Business Ethics and Professional Conduct Policy, Cassiopeia General Trading operates with a zero-tolerance policy towards bribery or any other form of corruption in its practices.

Neither Cassiopeia General Trading, nor any employee, person or entity associated with Cassiopeia General Trading , shall offer, pay, promise, authorize or receive any bribes, other illicit payment or benefits to or from any person or entity with whom Cassiopeia General Trading conducts its business. This includes, but is not limited to government officials, clients, vendors, subcontractors, suppliers, sub-consultants, partners, consultants or associates.

Cassiopeia General Trading’s Board of Directors and Executive Management will set the example in fostering a culture of compliance with respect to this policy.

Purpose

The purpose of this policy is to give very clear guidelines on what constitutes bribery, and to distinguish bribery from accepted business practices for the promotion of Cassiopeia General Trading

Scope

This policy applies to all officers and employees, temporary employees, agents, sub-contractors or sub-consultants of Cassiopeia General Trading whether employed in the parent company, branch office, subsidiary, joint venture or any other entity to which Cassiopeia General Trading belongs or is engaged.

Definition

Bribery: is committed when an inducement or reward is offered, promised, provided, accepted or solicited to gain any commercial, contractual, regulatory or personal advantage for Cassiopeia General Trading, the employee or person or entity associated with Cassiopeia General Trading

Responsibility

The Board of Directors holds primary responsibility for implementing this policy and for reporting on its compliance to the Board of Directors. The Board of Directors nominates the Chief Executive Officer (CEO) to be the care-taker of this policy, who in turn has delegated the responsibilities of managing compliance with this policy to Cassiopeia General Trading’s Compliance Officer.

With the assistance of Cassiopeia General Trading’s Compliance Officer, all offices of Cassiopeia General Trading and its subsidiaries must establish appropriate mechanisms and procedures within their operations to prevent, detect, investigate and report any violations of Cassiopeia General Trading’s Anti-Corruption and Anti-Bribery Policy.

All employees throughout Cassiopeia General Trading, its branches, subsidiaries and joint ventures, are individually responsible to prevent, detect and report any violation of Cassiopeia General Trading’s AntiCorruption and AntiBribery Policy and shall sign an Anti-Corruption and Anti-Bribery Undertaking and participate in regular Anti-Corruption and AntiBribery Compliance Training (as may be facilitated by Cassiopeia General Trading from time to time).