Code of Ethics

CODE OF CONDUCT 2020

Independence

Asire Consulting LLP (“Asire”) works in a regulated profession and is expected to comply with applicable laws and local and international standards and obligations around maintaining independence with respect to assurance clients. Asire proactively avoids and addresses circumstances that create or might be seen to create threats to its independence. Adherence to the fundamental principles of integrity and objectivity is important when providing all professional services, and being independent supports compliance with those principles when Asire provides assurance services to its clients. Asire defines independence as freedom from interests and relationships that impair, or may appear to impair, Asire’s objectivity in providing assurance services.

Conflicts of interest and sensitive situations

Asire is committed to identifying and addressing real and potential conflicts of interests and sensitive situations that may arise in the conduct of its business before accepting, commencing or continuing services. Asire defines conflicts of interests as any circumstance that could cast doubt on Asire’s ability to act with objectivity when providing services or in connection with Asire’s business. Asire defines a sensitive situation as any circumstance that could create a serious commercial, reputational or client relationship issue for Asire.

Competing Fairly

Asire is committed to fair competition and does not tolerate anti-competitive activity in any form.

Combatting corruption and bribery

Asire does not tolerate corruption or bribery in any form. Soliciting, accepting, offering, promising, paying bribes or making other improper payments, including facilitation payments, is strictly prohibited, whether directly or through any third party. Asire defines corruption as making improper payments or other inducements, illegal/criminal conduct, the abuse of entrusted power for private gain or the provision of an improper advantage. Asire defines bribery as offering, promising, giving, accepting or soliciting money, a gift or anything of value (including non-monetary value e.g., the offer of an internship or training) as an inducement or reward for doing something that is illegal, unethical, improper, a breach of trust or designed to corruptly influence the recipient’s judgment or decisionmaking. Asire defines a facilitation payment as a payment of any value, even if small, provided, in cash or kind, to active or former government officials to perform routine functions that they are otherwise obligated to perform (e.g., to expedite obtaining permits, licenses, visas, mail, or utilities).

Economic Crime and Money Laundering

Asire does not tolerate economic crime, including money laundering and terrorist financing activities. Asire defines economic crime as illegal acts carried out for financial or economic gain. Asire defines money laundering as the process by which proceeds from illegal activities are disguised so they appear to be from legitimate sources. This includes concealing, acquiring, using or possessing such proceeds or facilitating the acquisition, use, retention or control of such proceeds.

Insider dealing/ trading

Asire does not tolerate trading on, or the inappropriate disclosure of, inside information. Asire defines inside information as information about an entity (e.g., financial forecasts, merger and acquisition proposals, and key personnel changes) that has not been made public. Inside information can come from any source, not just Asire.

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