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Ethics & Conduct Policy

It is the policy of the company to provide our Code of Ethics and Business Conduct, which will serve as a guide to proper business conduct for all employees of the company and contractors acting on behalf of the company. At the heart of this document is a sense of what Time Technology stands for, which we identify as our core business values. In addition to our business values, this code describes ethical rules for how our employees should operate within the business, internally and externally. We expect everyone working for Time Technology to observe the highest standards of ethics and demonstrate their commitment to our values. This means following a basic code of ethical behaviour and embracing the company’s values in everything we do.

Business Values

Customer Empathy

At the heart of our service, we believe that it is critical to gain an absolute understanding of customer needs, their challenges and concerns. To do this effectively we need to work hard to achieve empathy with the customer such that we are no longer operating as a vendor but are truly partnering with them. So, some questions we should be asking ourselves are: “Do I truly understand what is driving the customer's needs and concerns?” “Am I clear on what the customer is expecting to achieve out of this activity or project?”

Integrity

The success of our business is dependent on the trust and confidence we earn from our customers. We gain credibility by displaying honesty and integrity and reaching company goals solely through honourable conduct. So, some questions we should be asking ourselves are: “Will this build trust and credibility for Time Technology?” “Does this feel like I am doing the right thing by the customer?” “Is the commitment I am making one I can follow through with?”

Continuous Improvement

Continuous improvement is a concept that the team at Time Technology should embrace with a passion. We are always learning, through our experiences with customers, partners, and indeed with each other, but applying these learnings is the key to building a truly great company. In addition, Time Technology is working within a world of technology that is constantly changing. Not all of these changes will yield opportunities for improvement in our business, but we must be open to the idea that they could. So, some questions we should be asking ourselves are: “What lessons did we learn and how can I apply these to ensure we are better next time?” “Am I carrying out this activity or project based on the premise that ‘we have always done it this way’, and if so, is there now a better way to do this?” “Have there been advances in technology that we could leverage to enhance the solutions we provide our customers or the manner in which we deliver our services?”

Collaboration

Working together as a team with our colleagues, partners and customers, maximising the contribution that all parties can bring to the table is essential in maximising the chances of a great outcome. Not only does this approach provide the best opportunity for the best ideas to surface, but it also promotes a culture of inclusiveness within teams and our business. This means that a collective ownership can occur such that team members will go out of their way to achieve a great outcome. So, some questions we should be asking ourselves are: “Have all team members contributed their ideas to this challenge we are facing?” “Does it feel like any team members have disengaged themselves from the success of this project, and if so, how can we bring them back into the fold?”

Respect for the Individual

We all deserve to work in an environment where we are treated fairly, with dignity and respect. Time Technology is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success.

Equality and Diversity

Time Technology is an equal opportunity employer and is committed to providing a workplace that is free of discrimination and all types of abusive, offensive or harassing behaviour. Our aim is to create a diverse and balanced workforce. That is to say one free of discrimination and prejudice whether that be in the recruitment process or as part of the on-going individual review processes or the way in which the team works together. Everyone will be treated with respect and will be given equal opportunity in every aspect of their working role irrespective of their race, religion, gender, sexual orientation or background.

So, some questions we should be asking ourselves are:

“Is an idividuals race, religion, gender, sexual orientation or background influencing my judgement in any way as to their abilities?”

“Am I explaining the way an individual is reacting to me based on their race, religion, gender, sexual orientation or background?”

Fairness

Paying a fair wage is something we strongly believe in. Whilst as a small business we will not be able to pay in the upper quartile of salaries, we aim to try and pay close to, or above the average salary for the roles that our people are performing. We are also keen to work with suppliers who have a similar attitude. At the extreme end of this, we are aware that modern slavery exists and that it is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and expect the same high standards from all of our contractors, suppliers and other business partners.

Ethical Behaviour

Uphold the Law

Our commitment to integrity begins with complying with the laws, rules and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or company policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see a possible infringement.

Competition

We are dedicated to ethical, fair and vigorous competition. We will sell Time Technology products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Time Technology or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information

It is important that we respect the property rights of others. We will not acquire or seek to obtain by improper means a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorised use, copying, distribution or alteration of software or other intellectual property.

Confidential Information

Integral to our business success is our protection of confidential company information, as well as non-public information entrusted to us by employees, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names, addresses or non-public information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and non-public information without a valid business or legal purpose and then not without proper authorisation.

Avoid Conflicts of Interest

We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions taken on behalf of Time Technology may conflict with our own personal or family interests. This is because the course of action that is best for us personally may not also be in the best interest of Time Technology or our customers. We owe a duty to Time Technology to advance its legitimate interests when the opportunity to do so arises. We must never use Time Technology property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with the company. Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, employees must seek review from their managers or directly with the Managing Director.

Business Courtesies

Most business courtesies offered to us in the course of our employment are offered because of our positions at Time Technology. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies. Employees who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favouritism or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when Time Technology is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Time Technology business.

Meals, Refreshments Entertainment and Gifts

We may accept occasional meals, refreshments, entertainment, gifts and similar business courtesies that are customary and conform to reasonable ethical practices of the marketplace, provided that: • They are not inappropriately lavish or excessive. • The courtesies are not frequent and do not reflect a pattern of frequent acceptance from the same person or entity. • The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future. • The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public. Customary business entertainment is proper however, impropriety results when the value or cost is such that it could be interpreted as affecting an otherwise objective business decision. Employees with questions about accepting business courtesies should talk to their manager or the Managing Director.

Offering Business Courtesies

Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Time Technology. An employee may never use personal funds or resources to do something that cannot be done with company resources. Accounting for business courtesies must be done in accordance with approved company procedures. Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e. company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that: • The practice does not violate any law or regulation or the standards of conduct of the recipient’s organisation. • The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish. • The business courtesy is properly reflected on the books and records of Time Technology.

Use of Company Resources

Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace. Employees and those who represent Time Technology are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use. Generally, we will not use company equipment such as computers, copiers and fax machines in the conduct of an outside business or in support of any religious, political or other outside daily activity.

In order to protect the interests of the Time Technology network and our fellow employees, we reserve the right to monitor or review all data and information contained on an employee’s company-issued computer or electronic device, the use of the Internet or Time Technology’s systems. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit, racist, or otherwise offensive or inappropriate.

Summary

Accountability At Time Technology, everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. Each of us is responsible for knowing and adhering to the values and standards set forth in this code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the code, we must contact our manager or the Managing Director. We take seriously the standards set forth in the code, and violations are cause for disciplinary action up to and including termination of employment.

Open and Honest Communication

Managers have a responsibility to create an open and supportive environment where employees feel empowered to raise such questions. We all benefit tremendously when employees exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right time.

Leadership through example

Management has the added responsibility for demonstrating, through their actions, the importance of this code. In any business, ethical behaviour does not simply happen; it is the product of clear and direct communication of behavioural expectations, modelled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our code work, managers must be responsible for promptly addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal with such issues. Managers should not consider employees’ ethical concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. We want the ethics dialogue to become a natural part of daily work.

Further Clarification

Should any employee need further clarification on any section of this code, the company would encourage you to speak to your manager or the Managing Director.