Code of Ethics

Halasa Establishment for Clearance and Services (the "Establishment") has adopted this Code of Ethics (the "Code") for all of the Establishment's employees, directors, and drivers ("Employees"). All Employees are required to be familiar with the Code, comply with its provisions and report any suspected violations as described below in the section entitled "Internal Reporting".

This Code outlines the ethical principles that are to govern the decisions and behavior of the Establishment’s Employees and is designed to help Employees conduct business honestly, respectfully and with integrity. This Code outlines the core values of the Establishment, with respect to how Employees are generally supposed to approach problems.
1. Conflicts of Interest
A conflict of interest occurs when an Employee's private interests interfere, or even appears to interfere, with the interests of the Establishment as a whole. Employees must never use or attempt to use their position with the Establishment to obtain improper personal benefits. Any Employee who is aware of a conflict of interest, or is concerned that a conflict might develop, should discuss the matter with his direct manager immediately.
2. Corporate Opportunities
Employees owe a duty to advance the legitimate interests of the Establishment when the opportunities to do so arise. Employees may not take for themselves personally opportunities that are discovered through the use of corporate property, information or position.
3. Confidentiality and Privacy
It is important that Employees protect the confidentiality of Establishment and clients information. Employees may have access to proprietary and confidential information concerning the Establishment's business, clients and suppliers. Confidential information includes such items as non-public information concerning the Establishment's business, financial results and prospects and potential corporate transactions. Employees are required to keep such information confidential during employment as well as thereafter, and not to use, disclose, or communicate that confidential information other than in the course of employment. The consequences to the Establishment and the Employee concerned can be severe where there is unauthorized disclosure of any non-public, privileged or proprietary information.

The Establishment respects and takes seriously the protection of the personal data of all natural persons who use the Establishment’s facilities, and services. The Establishment also strives to take all appropriate technical and organizational measures required to protect the personal data it collects and processes.
4. Honest and Fair Dealing
Employees must endeavor to deal honestly, ethically and fairly with the Establishment's customers, suppliers, and other Employees. No Employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. Honest conduct is considered to be conduct that is free from fraud or deception. Ethical conduct is considered to be conduct conforming to accepted professional standards of conduct.
5. Freedom from discrimination and harassment
Our Establishment is committed in creating an environment in which all individuals are able to make the best of their skills, free from discrimination or harassment and bullying. The Establishment is committed to providing a working environment free from discrimination against staff on the basis of sex or sexual orientation, marital or civil partner status, gender reassignment, race (which includes color, nationality, ethnic or national origin), religion or belief, disability, age and pregnancy or maternity (collectively known as “protected characteristics”), as well as one where harassment and bullying does not occur. It should be noted that all Employees are required to work in a manner that facilitates the fostering of such a working environment and to report any known or suspected breaches or violations as described below in the section entitled "Internal Reporting". Discrimination, harassment and bullying are violations of the Establishment’s ethical principles, and may subject the Establishment and any Employee guilty of such behaviors to liability, both criminal and civil. Complaints of discrimination, harassment and bullying will be investigated promptly, sensitively and confidentially.
6. Health and Safety
The Establishment strives to provide its Employees with a safe and healthy work environment. Each Employee has the responsibility to maintain a safe and healthy workplace for all Employees by following all applicable safety and health rules, regulations and laws and by reporting accidents, injuries and unsafe equipment, practices or conditions.

Threats or acts of violence and physical intimidation are not permitted. As further explained in the section below, the use of illegal drugs in the workplace will not be tolerated.
7. Drugs and Alcohol
Establishment policy prohibits the illegal use, sale, purchase, transfer, possession or consumption of controlled substances, other than medically prescribed drugs, while on the Establishment premises. Establishment policy also prohibits the use, sale, purchase, transfer or possession of alcoholic beverages by Employees while on Establishment premises, except as authorized by the Establishment. This policy requires the Establishment to abide by applicable laws and regulations relative to the use of alcohol or other controlled substances. The Establishment, in its discretion, reserves the right to randomly test Employees for the use of alcohol or other controlled substances unless prohibited by prevailing local law.
8. Environmental Compliance
All Employees hereby agree to comply with the Establishment’s policy for environmental compliance and to work towards achieving continual environmental protection improvement. No violation of prevailing local or national environmental rules, regulations or laws whatsoever is to the benefit of the Establishment and therefore the Establishment has zero tolerance against any such violations.
9. Anti-corruption, Gifts and Hospitality
The Establishment is committed to complying with all applicable anti-corruption laws, to denying any form of bribery and to conducting its worldwide business in an ethical, fair and transparent manner.

It is strictly prohibited for Employees to offer to pay, pay, authorize payment or promise to pay money or anything of value, directly or indirectly, to a government official, an existing or potential business partner or any other party, when such payment is intended to influence latter’s act or decision, to award or retain business, or to induce or reward unethical or illegal behavior or a breach of duty.

Employees are not to request, receive, solicit, agree to receive, directly or indirectly, money or anything of value that may reasonably be regarded as a bribe or as an improper incentive for the Establishment’s business activities.
Gifts and hospitality must never be offered or provided with a purpose of trying to improperly influence business conduct.
10. Protection and Proper Use of Establishment Assets
The Establishment's assets are only to be used for legitimate business purposes and only by authorized Employees or their designees. This applies to tangible assets (such as office equipment, telephone, copy machines, etc.) and intangible assets (such as trade secrets and confidential information). Employees have a responsibility to protect the Establishment's assets from theft and loss and to ensure their efficient use. Theft, carelessness and waste have a direct impact on the Establishment's profitability. If you become aware of theft, waste or misuse of the Establishment's assets you should report this to your manager.
11. Compliance with Laws, Rules and Regulations
It is the Establishment's policy to comply with all applicable laws, rules and regulations. It is the personal responsibility of each Employee to adhere to the standards and restrictions imposed by those laws, rules and regulations, and in particular, those relating to accounting and auditing matters.

Any Employee who is unsure whether a situation violates any applicable law, rule, regulation or Establishment policy should contact the Establishment's legal consultant (LCDR law centre)
12. Corporate Communications Policy
Only certain designated Employees may discuss the Establishment with the news media, securities analysts and investors. All inquiries from regulatory authorities or government representatives should be referred to the Establishment management.
13. Electronic Communication
“Electronic communications” include all aspects of voice, video, and data communications, such as voice mail, e-mail, fax, and Internet. Employees should use electronic communications for business purposes and refrain from personal use while on Establishment premises or when performing Establishment duties. Among other things, Employees should not participate in any online forum where the business of the Establishment or its customers or suppliers is discussed; such participation may give rise to a violation of the Establishment’s confidentiality policy or subject the Establishment to legal action for defamation.
14. Procedures Regarding Waivers
Because of the importance of the matters involved in this Code, waivers will be granted only in limited circumstances and where such circumstances would support a waiver. Waivers of the Code may only be made by the management and will be disclosed by the Establishment.
15. Internal Reporting
Employees shall take all appropriate action to stop any known misconduct by fellow Employees or other Establishment personnel that violate this Code. Employees shall report any known or suspected misconduct to the management or the Establishment's legal consultant (LCDR law centre). The Establishment will not retaliate or allow retaliation for reports made in good faith.