JWD-GADTECH JV LIMITED

CODE OF CONDUCT

This Code of Conduct is the policy for the operations and employees of JWD-GADTECH JV
LIMITED. It serves to gui d e the performance of their duties and responsibilities a n d ensures
compliance with JWD-GADTECH JV LIMITED commitment to operate within the bounds of
ethics, legality, and professionalism . It is also in line with our commitment to the tenets of IS0
9001:2008.

1. WORK E N V I R O N M E N T

JWD-GADTECH JV LIMITED will maintain a safe and drug-free workplace. Conduct

between staff members and with customers will be based on mutual respect and free from
discrimination and harassment based on race, color, creed, religion, sex, age, disability,
national origin, ancestry, citizenship, marital or veteran status.

2. INFORMATION RECORDING AND REPORTING

Recognizing that accurate information is essential to JWD-GADTECH JV LIMITED ability

to satisfy legal and regulatory obligations, all employees and directors will record and report
all information accurately and honestly. No employee will sign or submit or permit others to
sign or submit on behalf of JWD-GADTECH JV LIMITED, any document or" statement that
he or she knows or believes is false.

3. USE OF COMPANY’S PROPERTY

Theft, carelessness, and waste have a direct impact on JWD-GADTECH JV LIMITED

profitability. All employees will take appropriate actions to protect JWD-GADTECH JV
LIMITED assets and ensure they are used carefully, efficiently, and for legitimate business
purposes. Our assets include the company's confidential or proprietary information, and
employees must not disclose information about the company to persons outside the
company without proper authorization.

4. LEGAL COMPLIANCE

JWD-GADTECH JV LIMITED will conduct business affairs in compliance with all

applicable laws, rules, and regulations and, additionally, in accordance with JWD-
GADTECH JV LIMITED high ethical standard.

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5. PAYMENTS

JWD-GADTECH JV LIMITED and its employees and directors will not make any
improper payments to government officials, employees, customers, persons, or entities, nor
will JWD-GADTECH JV LIMITED or its employees and directors request or accept any
improper payment from suppliers, customers, or anyone seeking to do business with JWD-
GADTECH JV LIMITED.

6. FAIR DEALING

All employees shall handle themselves in a professional manner. Each employee will deal
fairly with JWD-GADTECH JV LIMITED customers, suppliers, competitors, independent
auditors, and other employees and will not take unfair advantage of anyone through
manipulation, concealment, abuse of privileged information, misrepresentation, or any other
unfair dealing or practice.

7. CONFLICTS OF INTEREST

No employee will engage in any activity or have any outside interest that deprives JWD-
GADTECH JV LIMITED of her loyalty or interferes with the satisfactory performance of
his or her duties. Employees' must immediately disclose in writing any actual or potential
conflict of interest that they may have to a member of Executive Management for resolution. A
conflict of interest occurs when a person's private interest interferes in any way with JWD-
GADTECH JV LIMITED interest s and may also arise when an employee or a member of his
or her family receives improper personal benefits because of his or her position with JWD-
GADTECH JV LIMITED.

8. COMPETITIVE PRACTICES

JWD-GADTECH JV LIMITED will compete for business opportunities vigorously, fairly,

ethically, and legally. JWD-GADTECH JV LIMITED will comply with all antitrust and other
laws regulating competition and trade and will not discuss pricing, cost, busines s strategies,
or any other proprietary or confidential information with its competitors.

Signed:

John Hart
Managing Director

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