Netpremacy Ltd, 2  Wellington Place, Leeds LS1 4AP

Netpremacy has always recognised that its own long-term interests and those of its various stakeholders(1) depend on compliance with the highest standards of ethical conduct and applicable law. The code of conduct has been approved by Netpremacy Group Executive Board and is introduced and reinforced to Netpremacy  employees through induction, training and internal communications. It is reflected in the Netpremacy Values and Netpremacy Way of working, and every Netpremacy employee is expected to conduct himself or herself, and his or her business, in line with this code without exception. Stricter guidelines or more detailed instructions may be appropriate for certain regions or countries, but they should not contradict this Code. Netpremacy periodically reviews this code of conduct and is committed to making changes in its content and implementation when changes or further clarification so demand.

1 The term "stakeholders" refers to employees, customers, suppliers, shareholders, governmental and non-governmental organizations, the communities in which it does business, and other parties that have influence over or are influenced by Netpremacy.

Ethics and Law

Netpremacy is strongly committed to the highest standards of ethical conduct, and full compliance with all applicable national and international laws. This includes, for example, those relating to antitrust and promoting fair competition, corporate governance, preventing bribery, illicit payments and corruption, publicly traded securities, safety in the intended use of the products and services Netpremacy delivers to customers, labor laws and practices, the environment, human rights laws and internationally recognized standards, and protecting copyright, company assets and other forms of intellectual property. Netpremacy  goal is not mere minimum legal compliance, but as an industry leader to be among the world’s best in corporate responsibility, practicing good corporate citizenship wherever it does business.

Netpremacy respects the privacy and integrity of its stakeholders and endeavors to adhere to strict standards when processing personal data and product information. All personal data collected and held by Netpremacy  will be processed fairly, lawfully and carefully and in a way that protects the privacy of individuals.

Human Rights

Netpremacy will respect and promote human rights. Netpremacy recognizes, with the international community, that certain human rights should be considered fundamental and universal, based on accepted international laws and practices, such as those of the United Nations’ Universal Declaration of Human Rights, International Labour Organization and Global Compact principles. Among those rights that Netpremacy views as fundamental and universal are: freedom from any discrimination based on race, creed, color, nationality, ethnic origin, age, religion, gender, gender reassignment, sexual orientation, marital status, connections with a national minority, disability, or other status; freedom from arbitrary detention, execution or torture; freedom of peaceful assembly and association; freedom of thought, conscience and religion; and freedom of opinion and expression. Netpremacy will not use child or forced labor. Netpremacy will not tolerate working conditions or treatment that are in conflict with international laws and practices.

Conflicts of Interest. Gifts & Bribes

Netpremacy employees must avoid activity that leads to a conflict of interest. This includes, but is not limited to acceptance and giving of personal gifts or hospitality, to or from Netpremacy  stakeholders holders, other than gifts of nominal value or reasonable hospitality given in the ordinary course of business. Any agreement or understanding regarding favors or benefits in exchange for the gifts must be avoided. Gifts of other than nominal value may not be accepted without full disclosure to and prior relevant clearance from the employee’s supervisor. Netpremacy and its employees will not pay or offer to pay bribes or illicit payments to government officials or candidates, or other parties, in order to obtain or retain business. Netpremacy does not provide financial support to political parties or other political groups.

Workplace Practices

Netpremacy employees must respect and encourage Netpremacy Values at work, promoting teamwork, individual responsibility, and the strength that comes from diversity. Netpremacy will strive to pay fair compensation, and provide a safe and healthy workplace for employees. Netpremacy is committed to equality of opportunity in all its employment practices, policies and procedures. Job requirements fulfilled, no employee or potential employee will, therefore, receive less favorable treatment due to their race, creed, colour, nationality, ethnic origin, age, religion, gender, gender reassignment, sexual orientation, marital status, connections with a national minority, opinion, disability, membership or non-membership of a trade union. Netpremacy will continue to invest in the personal and professional learning and growth of Netpremacy's employees. Netpremacy will encourage its employees to lead balanced personal and professional lives.

Environment

Netpremacy environmental activities are based on life-cycle thinking. The goal is to reduce environmental effects during our product life cycles. This is done by managing our own operations and our supplier network, incorporating Design for Environment (DfE) into our product development, processes and service design and supporting sound End-of-life practices. Netpremacy does not use any endangered species for any business purpose and furthermore requests that its suppliers avoid raw material procurement from an origin where there are clear human or animal rights abuse, or the method of procurement or distribution is illegal. In marketing and other company activities, Netpremacy will depict animals in a dignified manner.

Suppliers

Netpremacy will do its utmost to contract only with subcontractors or suppliers who themselves adhere to international human rights and environmental laws and practices. Netpremacy commits to monitoring the ethical performance of its suppliers and to taking immediate and thorough steps in cases where the ethical performance of its suppliers comes into question.

Implementation

The compliance commitment in this Code extends to all matters, including decisions relating to trade, investment, subcontracting, supplying, business development, and in all other business and employment relationships. Netpremacy approach to implementing this Code of Conduct will be active, open and ethically sound. Although difficult questions of interpretation may arise in specific instances, particularly regarding the need to sensitively balance local customs and requirements with global standards and guidelines, Netpremacy recognizes that the above commitment means that Netpremacy will do its utmost to identify ethical, legal, environmental, employment, and human rights issues and resolve matters consistent with this Code of Conduct.

It is the responsibility of each Netpremacy employee to promote this Code. Questions about the application or meaning of any provisions of this Code, or potential violations of the Code are to be reported to superiors. Where serious allegations are concerned, fair and comprehensive investigations will be conducted by those senior Human Resources, Security and line management closest to the issue. If this is inappropriate, more senior managers or global heads of these functions should be notified. Acts inconsistent with this Code must be promptly corrected and are subject to disciplinary action up to and including termination of employment. Netpremacy will ensure that there will be no adverse work-related consequences as a result of an employee bringing complaints of violations of this Code.