Infotek Consulting is committed to conducting all dealings and operations to a high standard of ethical behavior, integrity, honesty, fairness, and professionalism. While reaching profitability and sales goals is critical to Infotek Consulting’s success, equally important is the way Infotek Consulting achieves those goals. Every Infotek Consulting employee and director and any other individual performing services for Infotek Consulting is expected and required to assess every business decision and every action on behalf of Infotek Consulting considering whether it is right, legal and fair.

Staff and independent contractors are required to comply with the Code and may be asked to attest to their ongoing compliance with these provisions.

Respecting the Law

Concern for what is right should be the first consideration in all business decisions and actions, and that includes compliance with the law. No employee or independent contractor should perform any task the might reasonable be considered as legally or morally suspect. Infotek Consulting will not knowingly assist or allow customers, employees or other persons acting with or for Infotek Consulting to take actions which would violate the law. We will not knowingly induce an employee of another organization to breach that organization’s code of conduct or the law.

Infotek Consulting will comply with all the laws applicable to it, its clients, staff and contractors, including but not limited to applicable business laws, child and other labour laws and all the laws relevant to the Services performed by Infotek Consulting.

Preserving Integrity

A key element in developing and maintaining both corporate and personal integrity is ensuring that all information provided to, and distributed by, Infotek Consulting is accurate, complete and correct. Infotek Consulting expects all employees, applicants, independent contractors and clients to be truthful, accurate and complete in the information they provide. Infotek Consulting will make all reasonable efforts to verify critical information before using it or providing it to clients, applicants or independent contractors. Infotek Consulting will not knowingly provide false, inaccurate, or incomplete information to its clients, staff, independent contractors or applicants.

Personal Information

Infotek Consulting collects and holds significant and important personal information and our staff and independent contractors often have access to personal information at clients. Such information must at all times be treated with care, respect, appropriate security and checks against disclosure or misuse. It should never be discussed or disclosed to anyone outside of Infotek Consulting unless for a legitimate purpose and we are permitted or required to disclose by law, are authorized to disclose by the person, or are permitted to disclose in circumstances described in any applicable policies and procedures. We will not disclose or share personal information with anyone who does not have a legitimate need to know the information unless we are authorized to disclose by law. Personal information should only be disclosed to those inside Infotek Consulting on a “need to know” basis where the sharing or disclosing of such information has an appropriate and permitted business use for the client or Infotek Consulting.

Customer Information

Infotek Consulting staff and independent contractors often have access to significant and important customer information. Such information must at all times be treated with care, respect and appropriate security and checks against disclosure or misuse. It should not never be left unattended. It should never be discussed or disclosed to anyone outside of Infotek Consulting unless for a legitimate purpose and we are permitted or required to disclose by law, are authorized to disclose by the customer, or are permitted to disclose in circumstances described in any applicable policies and procedures. We will not disclose or share customer information with anyone who does not have a legitimate need to know the information unless we are authorized to disclose by law. Customer information should only be disclosed to those inside Infotek Consulting on a “need to know” basis where the sharing or disclosing of such information has an appropriate and permitted business use for the client or Infotek Consulting.

Confidential Information

Infotek Consulting may have access to confidential (non-public) information concerning our customer or our customer’s customers, suppliers, employees, or other individuals performing services for our customers. We have an obligation to comply with applicable laws and the policies and procedures of the customer’s business segment and region pertaining to confidential information. We are responsible to safeguard confidential information in our possession from unauthorized access or disclosure.

When it is necessary for Infotek Consulting to take, send or work on confidential information outside of our customer’s premises or systems, including when we are working from a non- customer location, we must ensure it is appropriately protected, regardless of whether the information is in physical or electronic form.

In particular Infotek Consulting acknowledges, and will advise its management, staff, consultants and contractors that securities laws impose restrictions on the communication of material non-public information and on the purchase and sale of securities of our customers by insiders and persons in a special relationship with our customers (i.e., those that may have access to non-public information.)

Intellectual Property

Infotek Consulting will respect the intellectual property of our customers, suppliers and peers. We will only reproduce or use software, videos, music and other copyrighted material licensed for use by Infotek or by our customers for the customer’s use in accordance with applicable copyright laws.

Conflicts of Interest

A conflict of interest can arise when Infotek Consulting takes actions or has interests that may make it difficult for Infotek Consulting to perform our services objectively and effectively. Infotek Consulting, its employees and independent contractors must avoid activities or situations that involve real or perceived conflicts of interests which would interfere with the interests of our customers. Employees and contractors must also avoid activities or situations that involve real or perceived conflicts of interests which would interfere with the interests of Infotek Consulting.

As a representative of Infotek Consulting, employees, consultants and contractors must avoid activities or circumstances that create conflicts between their personal interests and their business responsibilities, as well as complying with policies and procedures that manage potential conflicts between Infotek Consulting’s interests and those of customers.

Gifts and Entertainment

Accepting or providing entertainment, hospitality, gifts or favors that may reasonably be considered to have an influence on a decision by Infotek Consulting on behalf of Infotek Consulting or our customers, or that may be outside of the normal course of a business relationship, constitutes a conflict of interest. Any entertainment, hospitality, gift, or favor made or received by Infotek Consulting or our staff, consultants and contractors while performing services to procure an action or decision, or to recognize or reward an action or decision, is prohibited. Infotek Consulting representatives transacting business for customers should act and should be perceived by others to act, in our customers’ best interest and free of any conflicts of interest.

Do not accept, offer, or give, directly or indirectly for Infotek Consulting, yourself or for anyone else, gifts, loans, services, accommodations, favors, entertainment or other benefits of value (referred to as “Gifts” in this section) having more than nominal value from or to existing or potential customers, suppliers, employees or others doing or seeking to do business with Infotek Consulting or our customers. Furthermore, we must never accept, offer or give, directly or indirectly, gifts of any value where they may be construed as an attempt to bribe or influence a decision or alter the provision or receipt of a service, or where it might otherwise be inappropriate in light of the underlying business relationship or the roles of the individuals involved. We must also never solicit gifts of any size at any time.

Irregular Business Conduct

Specific examples of both correct and incorrect business conduct related to our recruiting services and hiring practices can be found in later sections of this manual. In addition, there are certain types of business conduct that are not acceptable to Infotek Consulting and which will not be supported or condoned. Carrying out such practices could lead to immediate termination and may also lead to criminal prosecution. Examples of these practices include:

• • • Anti-Competitive Behaviour (e.g., fixing prices)
    • Bribery and Corruption
    • Commission Sharing
    • Kick-Backs
    • Forgery, Falsifying Accounts, Documents and Records
    • Insider Trading or Tip-Offs
    • Money Laundering
    • Sales Misconduct (use of false claims concerning Infotek Consulting, our services or our competition)
    • Sanction Breaking
    • Theft and Fraud
    • Tied Selling

Appropriating Customer or Infotek Consulting Assets

Infotek Consulting employees, consultants and contractors must not borrow or make use of Infotek Consulting’s or our customers’ names, properties, goodwill, funds, data or other assets for their personal gain or benefit, or for the benefit of others, except as part of an Infotek Consulting or customer authorized compensation or benefit program. Upon termination of a contract with a customer, Infotek Consulting employees, consultants and contractors must relinquish or return all the customer’s records and equipment. Upon termination of a contract, or employment with Infotek Consulting employees, consultants and contractors must relinquish or return all of Infotek Consulting’s, information, records and equipment.