SAM*INK® Business Conduct

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SAM*INK® Business Conduct

"We Work Harder & Do the Right Thing Everyday."

Each SAM*INK® ''Company'' employee has a strong culture of corporate ethics & citizenship:

1. Uncompromising integrity is to stay true to what we believe. We believe in honesty, fairness, and to do the right thing without compromise, even when circumstances make it difficult.

2. Constant respect for people is to treat everyone with dignity, as we would like to be treated ourselves. Constant respect applies to every individual we interact with around the world.

The Code of Business Conduct has provided our employees guidance for their business activities, placing a priority of establishing trust with our stakeholders.

An Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it is established to allows access to the company for any interested party with a concern about SAM*INK®'s accounting, internal control, or audit matters.

Code of Business Conduct:

This Code of Business Conduct is a guide to help staff live up to the SAM*INK®'s high ethical standards -- and their own. It summarizes the philosophy that the Company & its staff are required to conduct themselves in. This Code is neither a contract nor a comprehensive manual that covers every situation our staff throughout the world might encounter. It highlights key issues & identifies policies & resources to help our staff reach decisions that will make SAM*INK proud.

Each staff is responsible for abiding by this Code that apply to our work. If you have questions or concern about illegal or unethical acts, discuss them with your supervisor and contact the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Failure to abide by this Code will lead to disciplinary measures appropriate to the violation, up to & including dismissal. Each staff is expected to read the entire Code of Business Conduct. No code can guarantee ethical behavior. Only we ourselves can.

SAM*INK executives are expected to lead according to our standards of ethical conduct, in both words & actions. Executives are responsible for promoting open & honest two-way communications. Executives must be positive activists & role models who show respect & consideration for each of our associates. Executives must diligently look for indications that unethical or illegal conduct has occurred & report it. If you ever have a concern about unethical or illegal activities, you are expected to take appropriate & consistent action, & inform your supervisor, & the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

To employees: We respect the dignity of each staff.

Constant respect: We will treat each other with respect & fairness at all times, just as we wish to be treated ourselves. We will value the differences of diverse individuals from around the world. Employment decisions will be based on business reasons, such as qualifications, talents, & achievements, & will comply with local & national employment laws.

Harassment: Abusive, harassing, or offensive conduct is unacceptable, whether verbal, physical or visual. Examples include derogatory comments based on racial or ethnic characteristics & unwelcome sexual advances. We are encouraged to speak out if a co-worker's conduct makes us uncomfortable & to report harassment if it occurs.

Safety & health: We are all responsible for maintaining a safe workplace by following safety & health rules & practices. We are responsible for immediately reporting accidents, injuries, & unsafe equipment, practices or conditions to a supervisor or other designated person. SAM*INK® is committed to keeping its workplaces free from hazards.

To protect the safety of all employees, each of us must report to work free from the influence of any substance that could prevent us from conducting work activities safely & effectively.

Threats or acts of violence or physical intimidation are prohibited.

To customers: We earn customer loyalty by delivering on our promises.

Product quality & safety: Maintaining SAM*INK®'s valuable reputation requires complying with our quality processes & safety requirements. We damage our good name if we ship products or deliver services that fail to live up to SAM*INK® standards.

Sales & marketing: We will build long-term relationships with our customers by demonstrating honestly & integrity. Our marketing and advertising will be accurate and truthful. Deliberately misleading messages, omissions of important facts or false claims about our competitors' offering are unacceptable.

We will obtain business legally and ethically. Bribes or kickbacks are unacceptable. Guidance on customer gifts, travel and entertainment is in the Conflict of Interest section of this Code.

Customer information: We must protect customer information that is sensitive, private or confidential - just as carefully as we protect our own. Only those who have a need to know should have access to confidential information.

Government customers: We must take special care to comply with all legal and contractual obligations in dealing with governments. National and local governments around the world have specific and varied procurement laws and regulations that have been established to protect public interest. These laws generally prohibit or put strict limits on gifts, entertainment and travel offered to government officials. Thay also often apply to hiring of current or recently retired officials and their families and to any conduct that may be viewed as improperly influencing objective decision making. Many other laws strictly govern accounting and billing practices for fulfilling government contracts and subcontracts.

These Codes apply to all SAM*INK® staff worldwide. When the Company uses suppliers or subcontractors to fulfill our commitments, we also may be responsible for communicating these unique governmental requirements to those third parties. Staffs who deal with governmental officials and contracts are responsible for knowing and complying with applicable laws and regulations.

To business partners: Building quality relationships with other companies give us a competitive advantage.

Doing business with others: We will not do business with others who are likely to harm SAM*INK®'s reputation. For example, we will avoid doing business with others who intentionally and continually violate the law. These laws include, for example, local environmental, employment, safety and anti-corruption statutes. All arrangements with third parties must comply with SAM*INK® policy and the law. We will not use a third party to perform any act prohibited by law.

Agents & consultants: Commission rates or fees paid to dealers, distributors, agents, finders, or consultants must be reasonable in relation to the value of the product or work that is actually being done, consistent with law, policy and local practice. We will not pay commissions or fees that we have a reason to believe will become bribes.

Purchasing practices: purchasing decisions must be made solely on SAM*INK®'s best interests. Suppliers win the Company's business based on product or service suitability, price, delivery, and quality. Purchasing agreements should be documented and clearly identify the services or products to be provided, the basis for earning payment and the applicable rate or fee. The amount of payment must be commensurate with the services or products provided.

To shareholders: We will treat the investments of our shareholders as if it were our own.

Protecting SAM*INK® assets: We have a responsibility to protect the assets entrusted to us from loss, damage, misuse or theft. Our assets, such as funds, products, or computers, may only be used for business purposes and other purposes approved by executives. Our assets may never be used for purposes that violate the law.

Proprietary information: We will safeguard all proprietary information by marking information accordingly, keeping it secure, and limiting access to those who have a need to know to do their jobs. Proprietary information includes any information that is not generally known to the public and is helpful to SAM*INK® or would be helpful to competitors. It also includes proprietary information that suppliers, customers, and others have entrusted to us. The obligations to preserve proprietary information continues even after employment ends.

Inside information and securities trading: SAM*INK® employees are not allowed to trade in securities or any other kind of property based on material information that comes from their jobs, if that information has not been reported publicly. It is against the laws of many countries, including Singapore, to trade or to 'tip' others who might make an investment decision based on inside job information. For example, using non-public information to buy or sell the stock of a SAM*INK® supplier or customer is prohibited.

Accuracy of company records: To make responsible decisions, we require honest and accurate recording and reporting of information. This includes such data as quality, safety, and personal records, as well as all financial records. All financial books, records and accounts must accurately reflect transactions and events and must conform both to required accounting principals and to SAM*INK®'s system of internal controls. No false or artificial entries may be made. When a payment is made, it can be used only for the purpose spelled out on the supporting document.

Recording and retaining business communications: All business records and communications should be clear, truthful, and accurate. Business records and communications often become public litigation, government investigations, and the media. We will avoid exaggeration, colorful language, guesswork, legal conclusions, and derogatory remarks or characterizations of people and companies. This applies to communications of all kinds, including emails and informal notes or memos. Records must be retained and destroyed according to SAM*INK®'s record-retention policies.

Audits and investigations: SAM*INK® staff are required to fully cooperate with all audits and investigations as requested by the company. We will also cooperate with reasonable requests for information from government agencies and regulators and consult with the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it before responding to any non-routine requests. All information must be truthful and accurate. We will not conceal, alter or destroy documents or records in response to an investigation or other lawful request.

To competitors: We compete aggressively & with integrity.

Competitive information: We must never use any illegal or unethical methods to gather competitive information. Stealing proprietary information, possessing trade-secret information that was obtained without the owner's consent or inducing such disclosures by past or present employees of other companies is prohibited. If information is obtained by mistake that may constitute a trade secret or confidential information of another business, or if we have questions about the legality of information gathering, we should consult the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Fair competition and antitrust: SAM*INK® and all our employees are required to comply with the antitrust and unfair competition laws of the many countries in which we do business. These laws are complex and vary considerably from country to country. They generally concern:

- Agreements with competitors that harm customers, including price fixing, bid rigging and agreements not to compete for customers or contracts.

- Agreements that unreasonably limit the freedom of a customer or supplier to sell a product, including establishing the resale price of a product or service improperly conditioning the sale of products, technologies, or services on an agreement to buy other SAM*INK® products and services.

- Attempts to monopolize, for example, by abusing a dominant position in the market unfairly to prevent others from competing.

SAM*INK® staff who question whether an action may violate competition laws should talk to the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it

To communities: As a global corporate citizen, we provide products & services that benefit people worldwide.

Community service: We serve society by providing life-enhancing products and services at a fair price, and by actively supporting the communities in which we operate. SAM*INK® and its employees throughout the world provide generous financial and voluntary support to worthwhile community programs.

Personal community activities: SAM*INK® employees are free to support community, charity, and political organizations and causes of their choice, as long as they make it clear that their views and actions are not those of SAM*INK®. Employees' outside activities must not interfere with job performance. No staff may pressure another staff to express a view that is contrary to a personal belief, or to contribute to or support political, religious or charitable causes.

Environment: We respect the environment by complying with all applicable environmental laws in all countries in which we conduct operations. SAM*INK® is committed to protecting the environment by minimizing the environmental impact of our operations and operating our business in a way that foster sustainable use of the world's natural resources. Notify management if hazardous materials come into contact with the environment or are improperly handled or discarded.

Communicating with external audience: SAM*INK® will provide fair, accurate, timely and easy to understand information to the public. To ensure professional and consistent handling, request from the media should be forwarded to the ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Unfortunately, many well-intentioned interviewees have had their stories misinterpreted by reporters. Let the experts handle such situations. Request from financial analysts and shareholders must be forwarded to the ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

To governments: As a responsible citizen, it is our obligation to obey the law.

Compliance with the law: SAM*INK® staffs around the world must comply with all applicable laws and regulations wherever we do business. Perceived pressures from supervisors or demands due to business conditions are no excuse for violating the law. When we have any questions or concerns about the legality of an action, we are responsible for checking with management and the ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

SAM*INK political activities: No employee may, except with approval from the ethics committee, make any political contribution for the company or use the Company's name, funds, property, equipment or services for the support of political parties, initiatives, committee, or candidates. This includes any contribution of value. Lobbying activities or government contracts on behalf of the Company, other than sales activities, should be coordinated with the ethics committee.

Anti-corruption laws: SAM*INK® complies withe the anti-corruption treaties and laws of the countries in which it does business. Company employees will not directly or indirectly offer or make a corrupt payment to government officials, including employees of state-owned enterprises.

Crossing national boarders: When importing or exporting products, services, information or technology, SAM*INK® complies with applicable Singapore and other national laws, regulations, and restrictions. When we travel internationally on Company business, we are subject to laws governing what we import and export. Employees are responsible for knowing the laws that pertain to them and for checking with their import/export compliance manager when in doubt.

To prevent conflict of interest: We make business decisions based on the best interests of SAM*INK.

General guidance: Business decisions and actions must be based on the best interests of SAM*INK and must not be motivated by personal considerations or relationships. Relationships with prospective or existing suppliers, contractors, customers, competitors, or regulators must not affect our independent and sound judgement on behalf of SAM*INK®. Employees are required to disclose any situation that my be, or appear to be, a conflict of interest, in accordance with policy. When in doubt, it is best to disclose.

Outside employment: SAM*INK® staff may not work for or receive payments for services from any competitor, customer, distributor or supplier of the Company without approval in accordance with policy. Any outside activity must be strictly separated from Company employment and should not harm job performance at the Company. Skills learned and used at the Company must not be used in a way that could hurt the business of the Company.

Board memberships: Serving on a board of directors or similar body for an outside company or government agency requires advance approval in accordance with policy. Helping the community by serving on boards of non-profit or community organization is encouraged and does not require prior approval.

Family members and close personal relationships: We may not use personal influence to get SAM*INK® to do business with a company in which our family members or friends have an interest. We should disclose any close relationship that might make it appear we could favor another company to the detriment if SAM*INK®'s interests.

Investments: Employees may not allow their investments to influence, or appear to influence, their independent judgement on behalf of SAM*INK®. This could happen in many ways, but it is most likely to create the appearance of a conflict of interest if an employee has an investment in a competitor, supplier, customer, or distributor and his decision may have a business impact on this outside party. If there is any doubt about how an investment might be perceived, it should be disclosed to the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it . We are also prohibited from directly or indirectly buying, or otherwise acquiring rights to any property or materials, when we know that the Company may be interested in pursuing such an opportunity and t he information is not public.

Gifts: Gifts are not always physical objects. They also may be services, favors, loans, or other items of value.

Gifts to SAM*INK® employees: we do not accept kickbacks, lavish gifts or gratitude. We can accept items of nominal value, such as promotional items bearing another company's name. We will not accept anything that might make it appear that our judgement for SAM*INK® would be compromised as a result. We may not accept special or reduced-rate personal loans as a result of our positions with the Company. In rare situations, it would be impractical or harmful to refuse a gift. If this happens, discuss the situation with the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Gifts Given by SAM*INK: Some business situations call for giving gifts. Our gifts must be legal, reasonable and approved by the ethics committee. Company employees never pay bribes. Gift-giving practices vary among cultures. Our local gift policies and guidelines address this. We will not provide any gift if it is prohibited by law or the policy of the recipient's organization. For example, the employees if many government entities around the world are prohibited from accepting gifts. If in doubt, check first.

Entertainment of SAM*INK® employees: We may accept entertainment that is reasonable in the context if the business and that advances the Company's interests. For example, accompanying a business associate to a local cultural or sporting event, or to a business meal would be acceptable in most cases. Entertainment that is lavish or frequent may appear to influence our independent judgement on behalf of SAM*INK. If an invitation seems inappropriate, we must turn down the offer or pay the true value of the entertainment ourselves. Accepting entertainment that may appear inappropriate should be discussed with the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it , in advance if possible.

Entertainment by SAM*INK®: We may provide entertainment that is reasonable in the context of Company business. If we have a concern whether providing entertainment is appropriate, we will discuss it with the ethics committee in advance. Entertainment of government officials may be prohibited by law. Get approval from management in each instance.

Acceptance of Travel Expenses: SAM*INK® employees may accept transportation and lodging provided by a Company supplier or other third party if the trip is for business and is approved in advance by the employee's supervisor. All travel accepted must be accurately recorded in our travel expense records.

Providing Travel: Unless prohibited by law or the policy of the recipient's organization. SAM*INK® may pay the transportation and lodging expenses incurred by customers, agents, or suppliers, if for legitimate business purpose and approved by management. All travel by government officials that is sponsored or paid for by the Company must be approved in advance by the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

How to get help?

Have questions about the SAM*INK® Code of Business Conduct? The first place to turn to is to your supervisor or manager. If you are uncomfortable discussing the issue with your supervisor, please talk to another member of management, Human Resource, or the Ethics committee This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Our open door policy means you can approach any level of management with your concerns.

It would be wonderful if the right thing to do were always perfectly clear. In the real world of business, however, things are not always obvious. If you find yourself in a situation where the 'right-thing' unclear or doing the right thing is difficult, remember our key beliefs & Ask yourself: Does my action reflect SAM*INK®'s beliefs of integrity and respect of employees, to customers, to business partners, to competitors, to shareholders, to governments, and to the public?

If you would not want your actions to be reported in the media...it is probably not the right thing to do.

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