Intent

The West Egg Group has adopted this policy to ensure the ongoing success of our organization, and to protect the best interests of all of our employees, vendors, customers, and the company from illegal or damaging actions committed by individuals either knowingly or unknowingly. This policy is to ensure that our staff refrain from and are prepared to identify bribery, fraudulent activity and corruption in order to report these activities appropriately. These procedures are intended to supplement the Global Code of Conduct Policy and to provide general guidance with respect to the prevention, investigation and remediation of bribery, fraud, and corruption.

The West Egg Group will not tolerate any wrongdoing or impropriety, and will immediately take the appropriate disciplinary actions to correct the problem.

Guidelines

Unethical Behaviour

• The West Egg Group will not be a party to the intent or appearance of unethical or compromising practices in its business relationships by means of bribery, fraud or corruption.
• Harassment or discrimination will not be tolerated.
• Improper use of company trade secrets (as outlined in the Confidentiality Agreement) will not be tolerated.
• Employees shall not use corporate assets or business relationships for personal use or gain.

Prevention and Detection of Bribery, Fraud and Corruption:

Mechanisms used in the prevention and detection of these prohibited activities include, but are not limited to:

• • Process monitoring;
  • Random auditing;
  • Supervision and review;
  • Provision of appropriate training for new and existing staff;
  • Written policies and procedures;
  • Segregation of duties;
  • Reconciliation of accounts; and
  • Review of audits and financial records.

Bribery, Fraud, and/or Corruption Response Plan

In the event that any The West Egg Group employee encounters or suspects bribery, fraudulent activity or corruption, he/she is required to report this information immediately to The West Egg Group Management or the Human Resources Department. The report shall be investigated thoroughly and maintained confidential.

The investigator shall apply disciplinary actions, up to and including termination of employment and/or report the incident(s) to the appropriate authorities.

Employee Expectations

Management & Executives

• In all business dealings, Company officials are required to set a prime example showing honesty and integrity.
• Shall have an open door policy allowing for the free discussion of suggestions and concerns from employees.
• Must report any conflicts of interest regarding their position at The West Egg Group.
• Must report suspected violations.

Employees

• All employees are expected to work together to promote a workplace built on trust, accountability, and openness.
• Disclose any conflicts of interest.
• Report suspected violations.

*Retaliation against employees who use these reporting mechanisms to raise genuine concerns will not be tolerated.

Violations

In the event that a violation of this policy occurs, The West Egg Group will employ disciplinary measures that reflect the severity of the offense up to and including termination of employment.

Some violations may indelibly affect our business in a negative fashion. In this case, punitive measures, including legal action may be pursued.