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Introduction to GeoSpectrum Policies

INTRODUCTION

Conducting our business ethically is one of GeoSpectrum Technology Inc’s (GTI’s) core values. Our policy is to follow best practice compliance standards applicable to the broad range of our global activities. Because of the significance we place on the transparency of our ethical business conduct, the following codes, policies and procedures are all publicly available as provided below.

Code of business conduct and ethics

Conducting our business ethically and consistent with best practices and legal requirements is essential to our success. The Code of Business Conduct and Ethics has been approved by GTI’s Board of Directors.
[March 2019 English Version]

Whistleblower and investigations procedure

As part of our business ethics compliance policy, we encourage reporting of suspected violations of our policies, improper conduct and legal non-compliance.  We are committed to taking such reports seriously, investigating them in a prompt and discrete manner, and we do not tolerate retaliation against employees who report in good faith.
[March 2019 English Version]

Anti-bribery and corruption compliance policy

The international nature of our business and our work with governmental customers and end users around the world, as well as our being a publicly traded company, requires us to follow leading anti-bribery and corruption compliance standards. We have zero tolerance for corruption, and our employees, officers and directors are committed to conducting our business according to applicable anti-bribery and corruption compliance practices.
[March 2019 English Version]

Procedure on anti-bribery and corruption due diligence

An important part of our anti-bribery and corruption compliance policy is the due diligence we conduct with respect to third parties with whom we do business.
[March 2019 English Version]

Business entertainment and gifts policy

Another important aspect of our anti-bribery and corruption compliance policy, as well as our policy for avoiding potential conflicts of interest, is the way in which we provide and receive business entertainment, hospitality and gifts.
[March 2019 English Version]

Supplier code of conduct

We expect our supply chain to meet our ethical standards in all of their activities with us. The Supplier Code of Conduct is incorporated into our procurement agreements.
[March 2019 English Version]

Conflict minerals compliance policy

We support government and industry initiatives to increase supply chain transparency to facilitate the ability of companies to source “conflict-free minerals”.  We are also committed to sourcing materials from companies that share our values with respect to conflict minerals.