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Ethics and Compliance at HardwareMart

ETHICS AND COMPLIANCE

HardwareMart conducts business fairly, honestly, truthfully, respectfully, responsibly and in full compliance with the law. Our Business Conduct and Compliance policies are foundational to how we do business and how we put our values into practice every day and must be followed by all our employees. Violations of this Code may result in disciplinary action up to and including discharge.

1. Our Core Business Principles

Our Core Business Principles sets out our ethical requirements for our employees. Each of our employees must certify that they have read and understood the policy when they join HardwareMart, and again each year. Violations of the policy are taken seriously and may result in disciplinary action, up to and including termination of employment.

1.1 Honest and Ethical Business Conduct

Our reputation as an ethical company is one of our most valuable assets and crucial to our continued success. Our policy is to comply with all applicable laws and regulations of Sri Lanka and to conduct our business activities in an honest, ethical and responsible manner. We value fairness and integrity and respect each other. We have a responsibility to understand and follow legal and internal policy requirements that apply to our jobs.

1.2 Relationship with Stakeholders

It is the core corporate responsibility of HardwareMart to society to pursue its corporate value enhancement through innovation and sound business practices and contribute to developing a sustainable society. We will all give due consideration to the impact of our business activities on the interests of our stakeholders including shareholders, customers, employees, suppliers, business partners, local communities and other organizations.

1.3 Respect for Human Rights

HardwareMart believes that all human beings should be treated with dignity and respect. HardwareMart is committed to upholding the internationally recognized human rights of all people. We will all use reasonable efforts to avoid causing or contributing to adverse human rights impacts that may arise from our operations, products, services and/or business relationships and will act diligently to help remediate any impacts that may occur.

1.4 Appreciating Diversity

Diversity is in HardwareMart’s DNA and the diversity of our businesses, employees, business partners and other stakeholders serves as the foundation of our competitive advantage. We recognize that conduct that is socially and professionally acceptable in one culture may be viewed differently in another. We will give careful consideration to such differences when performing our duties.

2. Fair Labour and Employment Practices

2.1 Equal Employment Opportunity / Non-Discrimination

We strive to promote diversity. We seek to create a culture that allows all HardwareMart Personnel to contribute their unique talents and skills to provide the best services to our customers. We are committed to recruiting, hiring, training, promoting and otherwise treating applicants and employees without discrimination based on factors that are unrelated to HardwareMart’s legitimate business interests.

2.2 No Forced Labor / Child Labor

HardwareMart will not use any form of forced or involuntary labour where people are forced to work against their will, including forced labour to work off a debt, prison labour or human trafficking.

In addition, HardwareMart will not use child labour. “Child” means a person younger than 15 years old (or younger than 14 years old where a local law provides for a lower age) or the local legal minimum age for labour, if it is higher.

2.3 Sound Labor and Employment Practices

HardwareMart has adopted sound labour and employment practices and endeavours to ensure our Personnel are treated under the applicable laws and regulations of Sri Lanka.

2.4 Work Environment - Anti-Harassment / Anti-Discrimination / Health & Safety

HardwareMart is committed to maintaining a healthy, safe and productive work environment that is free from discrimination or harassment, in which all individuals are treated with respect and dignity. HardwareMart complies with all applicable local laws that prohibit discrimination and harassment. HardwareMart will not tolerate any form of discrimination, or harassment of any kind, including sexual harassment, bullying or other behaviours that create a hostile work environment. We will also adhere to all applicable health and safety laws and regulations as well as internal rules and policies to help ensure workplace safety.

3. Compliance at HardwareMart

Many compliance functions are deeply integrated into our business organization. HardwareMart’s Business Conduct and Compliance team focus on Business Conduct, Security Compliance, Political Compliance, Health Compliance, Antitrust Compliance, and Anti-Corruption Compliance.

3.1 Personal Information

HardwareMart respects the privacy of individuals, such as customers, employees of suppliers and business partners and HardwareMart Personnel, and has developed and implemented policies and internal rules regarding personal information. We will observe and comply with all applicable laws and regulations as well as applicable internal rules and policies whenever collecting, maintaining, using, disclosing or disposing of personal information.

3.2 Information Security

HardwareMart recognizes the importance of information security both in achieving financial success and maintaining the trust of our stakeholders and has established policies and procedures to help protect our information resources and information resources and/or systems. We must all help keep our information resources and information systems safe by following our information security policies and procedures.

3.3 Bringing Policy to Life

Every HardwareMart employee is required to complete mandatory annual Business Conduct training. We offer a range of additional resources for employees to address questions and concerns.

3.4 Being Accountable

We conduct internal and third-party independent assessments of our programs to ensure they are effective. We make changes to our policies and our training to reflect emerging trends. HardwareMart’s Chief Compliance Officer provides regular updates to the Audit and Finance Committee of the Board of Directors.

4. Fair Business Practices

4.1 Fair Competition

HardwareMart’s policy is to comply with all applicable antitrust, competition and fair trade laws and regulations of Sri Lanka. These laws and regulations are designed to prohibit agreements or practices that fix prices, divide markets, impede or destroy fair competition in markets. We must know and comply with those laws and regulations applicable to our jobs. When any doubt exists as to the legality of any proposed action or agreement, we must promptly discuss the matter with our legal department.

4.2 Fair Procurement

HardwareMart selects its suppliers and contractors based on competitive price, quality, delivery and other objective standards.

HardwareMart expects its suppliers and contractors to adhere to our ethical values and comply with applicable HardwareMatrt policies concerning compliance with laws, respect for human rights, fair labour and employment practices, environmental conservation and the safety of products and services.

4.3 Anti-Corruption

HardwareMart prohibits corrupt practices in any form, including bribery, kickbacks, and other unlawful payments, in both the public (government) and the private (commercial) sectors. HardwareMart Personnel may not make any payment or provide any gifts, entertainment or other business amenities to individuals employed by current or prospective HardwareMart customers, suppliers or other business partners for improperly influencing them to obtain or retain business, or to secure any improper business advantage. In addition, HardwareMart Personnel may not accept any payment or any gifts, entertainment or any other business amenity that appears to influence their business decisions.

Great care must be taken in dealing with government officials. HardwareMart has established internal policies and rules that prohibit gifts and payment of anything of value to government officials, directly or indirectly, for or that appears to be for seeking favourable arrangements or actions by such officials.

We will observe applicable laws and regulations, as well as our internal rules and policies concerning giving and receiving gifts, entertainment and other benefits.

5. Responsible Business Conduct

5.1 Sound Decision Making

Business decisions must be made on an informed basis, in good faith, and the honest belief that the action is taken is in the best interest of HardwareMart. We will check and ensure that the decision to be made will satisfy at least the following preconditions:

(i) It will not violate any applicable law, regulation or internal rule or policy;

(ii) No personal interest or self-dealing is involved;

(iii) It is made within individual authority levels given by the corporation;

(iv) It is made with due care following a reasonable effort to become familiar with the relevant and available facts; and

(v) It is made in good faith based upon a reasonable belief that the best interests of HardwareMart are served by the decision.

The design of the organizational structure and personnel assignments are important factors that help ensure sound decision making. When structuring an organization or making personnel assignments, managers at HardwareMart will pay reasonable attention to introducing appropriate measures such as segregation of duties and checks and balances, depending upon the nature and size of its operations, to help ensure sound business decisions.

5.2 Recording and Reporting of Information

We must ensure that all records and reporting of information, including but not limited to books and other financial records, will be accurate, complete, honest and timely and will be a fair representation of facts. We should never cause records to be inaccurate or create records that are misleading or artificial.

5.3 Tax Compliance

It is our policy to comply with all applicable tax laws and regulations of Sri Lanka as well as the common rules and guidance regarding international taxation. We must know and comply with those laws and regulations applicable to our job.

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