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Corporate Governance and Ethical Code

Corporate Governance and Ethical Code

Neyaa  is committed to creating value for its stakeholders and to building relationships with its employees, customers, candidates, users, and business partners, based upon integrity, innovation, talent and results.

We strive to operate in a socially and environmentally responsible manner and in accordance with high standards of business ethics. The Neyaa  Ethical Code is a compilation of universal standards that describe Neyaa ’s expectations of its staff, businesses and partners regardless of location and background. It is an integral part of the way Neyaa  does business.

Employees

Neyaa strives towards a non-discriminatory company culture based upon talent, integrity, and respect. We seek to foster the creativity and self-esteem of employees and cultivate a corporate climate in which the individual is free to express an opinion and to address these opinions to all levels of the organisation in a free and open manner. It is the policy of Neyaa  to treat all current or potential employees fairly and without prejudice. All employees will be given the opportunity to progress within Neyaa  based upon their own skills, capabilities and potential without regard to their gender, marital or parental status, ethnic or national origin, sexual orientation, religious belief, political affiliation, age (subject to contractual retirement age), or disability.

Neyaa  is committed to paying fair wages and benefits according to relevant standards wherever we operate. Neyaa  will demonstrate good faith and mutual respect in dealings with employees and their representatives in the workplace. Our practices will be based upon internationally recognised standards. Neyaa  is a global provider of  and services with operations in many countries. We will respect local culture and seek to incorporate the best local customs and practices into our overall Neyaa culture.

Business Practice

Neyaa  will engage in fair, transparent and free competition and ensure our activities conform to high ethical standards by complying, as a minimum, with all applicable legislative and regulatory requirements. It is the policy of Neyaa  to treat all current or potential business partners fairly and without prejudice. Neyaa  requires that all employees, irrespective of their function, grade or standing, observe the following standards of business and personal ethics in the conduct of their duties and responsibilities:

  • Neyaa employees will practice integrity and honesty in every aspect of dealings with other employees, customers, candidates, users, other business partners, communities and government authorities.
  • As a global business Neyaa encounters laws and regulations designed to promote fair competition and encourage ethical and legal behaviour. Antitrust and fair competition legislation generally prohibits activities that restrain free trade or limits competition. Neyaa  shall conduct its business in full compliance with such legislation.
  • Neither Neyaa nor any of its employees shall make illegal or improper payments or bribes and will refrain from participating in any corrupt business practices. Neither Neyaa  nor any of its employees may accept payments, gifts or other kinds of reimbursement from a third party that could affect or appear to affect them, and by inclusion the company’s objectivity, in making business decisions.
  • Neyaa employees should avoid entering into situations where their personal, family or financial interests may be in conflict with that of Neyaa . Where any such potential conflict of interest arises, the employee should disclose this and seek authorization from their Line of Business Managing

Director

Communications and Privacy of Data Neyaa  is committed to open and transparent communications within the bounds of commercial confidentiality. Neyaa  will communicate with employees, shareholders, business partners and society in a fair and transparent way, through timely and appropriate disclosure information. Neyaa  will respect the privacy of data (whether relating to employees, customers or third parties), which it may hold or handle as

part of its information processing activities. No Neyaa employee shall without proper authority access, modify, disclose or make use of any confidential group or personal information for any purpose other than is allowable legitimately.

Health & Safety

Neyaa  actively strives for the continuous improvement of health and safety in the workplace. Neyaa  aims to provide a safe working environment for its employees. All Neyaa operations will, as a minimum, strictly abide by national laws and/or collective agreements. We will enhance health and safety by creating our own standards where necessary.

Respect for Human Rights

Neyaa  respects fundamental human rights and will be guided in its operations by the provisions of the United Nations Universal Declaration of Human Rights. Neyaa  supports and respects the protection of human rights within its sphere of influence.

Community Relations

Neyaa  is committed to making a positive social contribution to the communities in which it operates.

Applicability

All managers within Neyaa  and its subsidiaries are responsible for the ongoing enforcement of and compliance with this policy, including necessary distribution to ensure employee knowledge and compliance. This policy applies to all Neyaa operations and all Neyaa  employees worldwide regardless of function, grade or standing.Neyaa  expects equivalent standards of conduct from all persons acting on its behalf. Neyaa  employees working in a partner company shall strive to achieve compliance with this policy. This policy is not all-inclusive and any Neyaa  employee, who is in any doubt as to whether a proposed course of conduct might infringe should seek the advice of his/her supervisor before taking action. The practical application of this policy will be regularly monitored and openly communicated.

Grievance/Complaint Procedure

Any employee aware of a violation of applicable law or of this policy should report that information immediately to his/her supervisor. If the immediate supervisor is involved in the situation, or is conflicted in any other way, the situation is to be reported to his or her immediate superior as well as to the HR Director. All Neyaa  managers are required to investigate and resolve all such complaints and report progress to the HR Director. If, as a Neyaa  employee, you have raised a concern and the issue has not been resolved, report the issue to the HR Director. The HR Director is also available as an independent source of advice to any employee requiring assistance, advice or clarification on issues pertaining to this policy.