Policies

A. Standards of Business Practice

“SSTC is committed to observe high ethical standards in all business dealings.”

Against Bribery and Corruption

Gifts and Hospitality

• Any payments, gifts, incentives or any form of entertainment offered by or on behalf of SSTC and which stimulate or are intended to induce someone to act improperly or to public officials to influence the performance of their duty (other than fees which they are entitled to demand by written law) are matters which will be investigated and may result in disciplinary action against employees concerned.

• Gifts or entertainment may only be offered to a third party if they are consistent with customary business practice in the relevant territory, are modest in value and cannot be interpreted as incentives to trade.

• As to acceptance, employees should not accept gifts, money or entertainment from third party organizations or individuals if such acceptance may be perceived to influence business transactions. Gifts, other than petty ones with a nominal value, should be returned. Otherwise, if the action of returning might cause offence, the gift should be declared to the company and, if practical, donated to an appropriate charity.

Political Contributions, Donations And Sponsorships

• SSTC does not make contributions to political parties, political candidates or organizations which are politically active unless there is a legal requirement to do so or where there is an established, lawful and generally accepted practice to do so. Even in such circumstances, any payment must be approved by the Board of Directors.

• Charitable contributions, donations and sponsorships on behalf of SSTC may be permitted as part of the company's Corporate Social Responsibility activities.

• All contributions, donations and sponsorships should be approved in accordance with the Financial Authority Policy and should be properly recorded in the company books.

Supplier Relationship

• SSTC works with critical contractors and suppliers, often on a long-term relationship. Their performance is a crucial part affecting SSTC’s performance as well. Thus, the selection of these contractors and key suppliers must comply with various criteria, which include historical performance, price, quality, and delivery of product and service requirements of SSTC.

• In addition, SSTC must also consider the business ethical conduct of these contractors and key suppliers to ensure that SSTC is dealing with those having appropriate business ethics principles.

• Our suppliers and contractors are entitled to fair treatment. It is our policy to pay suppliers and contractors in accordance with agreed terms of trade.

Customer Relationship

• Mutual trust and confidence between SSTC and our customers are vital. All employees should strive to consistently deliver service excellence and value for money, meeting customers’ expectations and anticipating their changing requirements.

• Accurate understanding of both the customer’s expectations and the company’s obligations are vital and depend on open and clear communication with the customer.

• Our goal is to understand the customer’s needs and work jointly to deliver them.

• If there be any customer practices or processes which we believe are contrary to the values of SSTC, this concern will be communicated to the customer.

Free And Fair Competition

• SSTC recognizes that competition should be based on factors of price, quality, and service; not on the abuse of monopoly powers, competitor bashing, and predatory pricing.

• With this, SSTC will always compete in a fair and ethical way by providing good value and product excellence.

• Employees should not discuss confidential information and should not attempt to illegally or improperly acquire competitors’ confidential information and should respect their intellectual property rights.

B. Corporate Governance

“SSTC is committed to protecting the interests of our shareholders and our organization through compliance with the relevant legal and regulatory environments and careful management of business risks.”

Risk Assessment And Management

• SSTC recognizes various risks associated in conducting business which includes compliance risk, financial risk, environmental risk, reputational risk and others. These are influenced by numerous factors, including sales volume, input costs, competition, and the overall economic climate and government regulations.

• It is the responsibility of SSTC and the management at all levels to identify and manage these risks to minimize, if not prevent, adverse effects in the organization.

• Risk assessment consists of focusing on high-risk situations and setting priorities. It also helps in planning the allocation of appropriate and adequate resources and processes to manage identified risks.

• Risks are analyzed by considering: a) causes and sources of potential errors and deficiencies, b) the significance of their consequences (potential impact), and c) the likelihood of occurrence of associated consequences (probability of occurrence).

• Management is responsible for ensuring that policies and procedures are in place to manage risks and for complying with those policies and procedures. Employees should ensure that they are aware of the risks associated with their activities and that they comply with policies and procedures in place to manage those risks.

• Risks are re-assessed periodically so that changes in our activities or significant external changes (such as financial-economic circumstances, market conditions, changes in regulatory environment etc.) are properly captured.

Compliance With The Law

• SSTC will comply fully with all relevant local, national and international laws and regulations.

• It is the responsibility of all managers to ensure, (by getting legal or other expert advice where appropriate), awareness of all local laws and regulations which may affect the area of the business in which they are engaged.

Accounting Standards And Records

• SSTC should comply with the International Accounting Standards (IAS), International Financial Reporting Standards (IFRS), and other accounting standards and regulations in providing fair presentation of the company’s financial position and results.

• All accounting documentation and reporting must clearly identify the true nature of business transactions, assets and liabilities in conformity with relevant regulatory, accounting and legal requirements. No record or entry may be false, incomplete or suppressed.

• Employees must not intentionally falsify or knowingly misstate management information for personal gain or for any other reason. Sanctions will follow based on Employee Code of Conduct.

External Reporting

• SSTC may be required to make statements, answer surveys or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Top management must be made aware of any sensitive disclosure before it is made.

• Care must also be taken when making statements to the media that information given is correct and not misleading. Enquiries from the media should be referred to company media relations experts and statements should only be made by designated and authorized spokespersons.

Internal Audit Indepedence

• Internal Audit department must report to a level within the organization that allows the internal audit activity to fulfill its responsibilities. The Internal Audit Head must confirm to the board, at least annually, the organizational independence of the internal audit activity.

• For effective organizational independence, the internal audit head reports functionally to the board.

• SSTC, being a subsidiary of a parent company, is audited by the Internal Audit established at the parent company level.

C. Commitment To Employees

“SSTC is committed to optimizing individual and business performance through employing the best people at all levels. SSTC has a duty to ensure that individual employees are treated fairly and with dignity and respect.”

National Regulation And Labor Law

• In dealing with its employees, SSTC will act in compliance with national regulatory requirements and employers’ obligations to employees under labor or social security laws and regulations must be respected.

Rights Of Work

• SSTC is against forced or child labor and discrimination. Employment should be open to all and should not discriminate on the basis of gender, color, ethnicity, culture, religion, sexual orientation or disability and will abide by all anti-discrimination legislation in the jurisdiction where SSTC operates.

Health And Safety

• SSTC places the highest priority on protecting the health and safety of employees while at work. In particular, we will constantly review the effectiveness of our methods of operation to best protect those who work in a high-risk environment. This includes evaluating, mitigating and managing risks where they occur and enforcing robust procedures that safeguard our employees and the people, property and assets they look after. We expect our leaders to be outstanding role models, setting the highest standards for health and safety and fostering a culture where, in line with our values, health and safety is the first consideration in everything we do.

Security Program

• A security Program should be designed to implement policies and procedures that will protect the company's personnel, material assets and intellectual property, and which will ensure a safe business environment for clients and company personnel. It is designed to assist the company in establishing minimum standards for the installation and operation of all security devices, and to implement procedures to both discourage crimes and to assist in the identification of individuals who commit such acts.

• It is the responsibility of the Management to ensure that a written Security Program for the company's main office, departments and offices be developed and implemented. The continued research, development and implementation of the company's Security Program involve the participation and approval of each department within the company.

D. Employee Commitments

“Employees have a duty to promote the interests of the company and are expected to exercise good ethical judgment to circumstances which might conflict with SSTC’s ethical standards.”

Confidential Information

• Employees must not make use of confidential information obtained through their employment for personal gain. The disclosure of confidential information to any third party during or after employment is not permitted unless the disclosure has been appropriately authorized, is for a legitimate business reason and the information is being communicated securely.

• The term ‘confidential information’ does not include information in the public domain or information which the individual concerned is required by law to disclose.

Conflicts Of Interest

• Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the Company, or which divides his or her loyalty to the Company. Any activity which appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is confirmed in writing that the activity does not constitute a conflict of interest and is not detrimental to the reputation and standing of the Company.

Social Networking

• Employees who engage in social networking on websites or in groups which show any association with, or make reference to SSTC are expected to be have in ways that are consistent with SSTC values and policies. Employees must therefore ensure that the company is not exposed to legal or reputational risks and the safety and security of employees, customers and the general public are not undermined.

E. Corporate Social Responsibilty

“SSTC is committed to being a good corporate citizen, taking account of the economic, social and environmental impact of our business and aiming to maximize the benefits and minimize any negative impact of our operations.”

The Environment

• SSTC will conduct its business with respect and consideration for the environment. We will strive actively to reduce the company’s overall impact on the environment through management of waste, water, vehicle emissions and energy consumption.

Local Communities

• SSTC is fully committed to supporting and assisting the communities in which it operates through a variety of means including sponsorship of community projects and activities. We conduct our business with respect and consideration for the good of local communities, taking steps to minimize any unfavorable impact resulting from our operations. We will also serve local interests by providing good employment opportunities and effective services and products and paying a fair wage which supports a reasonable standard of living for our employees and their families.

F. Implementation

This policy shall be implemented in all activities and processes, sections and departments, and to all employees of South Seas Tuna Corporation Limited. This policy shall be cascaded to all employees through the Human Resource Department to ensure awareness and acknowledgment of this policy