Code of Conduct Policy

GAPCORP fosters a culture of ethics, integrity and compliance with relevant laws and regulations in the conduct of its business.  GAPCORP implements a Code of Conduct Policy which serves a source of guiding principles for its directors, officers and employees (the “Representatives”).

Compliance with Laws and Regulations
All Representatives shall adhere to relevant local and national laws and regulations applicable to the territories where the relevant business unit conducts business.

Conflicts of Interest
All Representatives shall always act in the interests of GAPCORP while performing their duties. A conflict of interest occurs whenever personal interests interfere with the interests of GAPCORP as a whole. All Representatives must, therefore, avoid conflicts of interest.

Representatives are advised not to engage in any business relationship or activity which conflicts with their ability to perform their role in the company as it would impair their judgment as to what is best for GAPCORP. A Representative shall not accept a position of responsibility in any other company or non-profit organization without specific permission or consent from GAPCORP.

Corporate Opportunities
Each Representative shall not use corporate property, proprietary information or position for improper personal gain.

Each Representative shall not compete against GAPCORP, either directly or indirectly.

Competition and Fair Dealing
Each Representative shall endeavor to deal fairly with GAPCORP’s customers, suppliers, competitors and their representatives, in compliance with relevant competition and antitrust laws and regulations.

Equal Opportunities Employer
GAPCORP shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, religion, marital status, gender, age, nationality, ethnic origin or disability.

GAPCORP’s policies and procedures shall promote diversity and equality in the workplace, as well as compliance with all local labor laws, while encouraging the adoption of international best practices.

Safe Working Environment
All employees shall be treated with dignity and in accordance with GAPCORP’s policy of maintaining a work environment free of all forms of harassment, whether physical, verbal or psychological.

Employee policies and practices shall be administered in a manner consistent with applicable laws and other provisions of the Code of Conduct Policy, respect for the right to privacy and the right to be heard, among others.

Environmental Health and Safety
GAPCORP shall strive to provide a safe, healthy and clean working environment for its Representatives.

GAPCORP shall ensure that individual consumer information is adequately protected. GAPCORP is committed to protecting personal information that is collected from customers and any other parties.

Each member of GAPCORP’s management is responsible for the detection and prevention of fraud, misappropriation and other irregularities or improprieties that may occur within their area of responsibility.

Protection of GAPCORP Assets
Employees must be committed to the proper allocation and use of GAPCORP assets. For these purposes, assets include tangible assets such as equipment, supplies, tools, all vehicle parts and other inventories, lifts, computer systems and equipment, vehicles, records or reports, machinery, systems, facilities, materials and resources as well as company funds in any form; and, include intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers.

Each Representative has a duty to protect the assets from loss, damage, misuse, theft or sabotage.

Bribery and Corruption
GAPCORP and its Representatives shall neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits that are intended, or perceived, to obtain uncompetitive favors for the conduct of its business. GAPCORP shall cooperate with governmental authorities in efforts to eliminate all forms of bribery, fraud and corruption. However, GAPCORP and its Representatives may, with full disclosure, accept and offer nominal gifts, provided such gifts are customarily given and/or are of a commemorative nature.

Reporting Illegal or Non-compliant Conduct
Employees should report violations of laws, rules, regulations or this Policy to supervisors or other appropriate personnel.