IDOL Group of Companies (hereinafter referred to as “IDOL”, “we”, “our” or “us”) is committed to maintaining the highest ethical standards in its dealings with all third parties.  As an expression of this commitment, our Board of Directors adopted this Code of Business Conduct and Ethics Policy (“Code”) on June 2, 2016.

I.     The Code

This Code is not intended to provide an exhaustive list of prohibited behaviour. Instead, its purpose is to articulate core principles and values that must guide all members of our team in conducting their day-to-day activities as directors, officers, managers, employees and agents of IDOL Group of Companies. Common sense and sound judgment must be exercised at all times.

II.    Our Core Principles and Values

1.     We treat our customers fairly

We must always keep the best interests of our customers paramount and endeavour to deal with them fairly. No one should take unfair advantage of customers through manipulation, abuse of privileged information, misrepresentation of facts or any other unfair practice.

2.     We shun conflicts of interest

All members of our team should avoid any activity, interest or association outside IDOL that could conflict with IDOL’s interests and impair their ability to perform their work at IDOL objectively or effectively.

3.     We protect IDOL’s confidential information

Confidential information (i.e. information that is not in the public domain) generated and gathered in our business is a valuable IDOL asset. Protecting this information is critical to IDOL’s reputation for integrity and its relationship with its customers. All members of our team must maintain all confidential information belonging to IDOL and its customers in strict confidence at all times.

4.     We protect IDOL’s property

Protecting IDOL’s property against loss, theft, waste or misuse is the responsibility of every member of our team. All IDOL assets are to be used only for legitimate work related purposes.

5.     We look at gifts with suspicion

The purpose of business entertainment and gifts is to engender sound working relationships and should not be used to create inappropriate expectations. Members of our team should not accept or offer gifts and entertainment for the purpose of gaining an unfair business advantage. Gifts and entertainment are only appropriate if provided in the ordinary course of business and their value is modest. Members of our team (and their families) should not accept gifts of cash.

6.     We provide clear, fair and not misleading information

IDOL has a responsibility to communicate clearly and effectively. To the extent they are involved in the preparation of materials for dissemination to third parties, members of our team should ensure that the materials contain information that is clear, fair and not misleading.

7.     We treat others on an equal basis

We are committed to a workplace that promotes equal employment opportunities and prohibits discriminatory practices and harassment. We strive to provide a safe and healthy work environment for employees and to avoid adverse impact and injury to the environment and communities in which we conduct our business.

IV.  Consequences of Violation

Members of our team are encouraged to report observed behaviour, which they believe may be illegal or violation of this Code. We do not allow retaliation for reports made in good faith by employees of misconduct by others.

In case of any doubt about the applicability or interpretation of any provision of law or this Code, the advice of IDOL’s Legal/Company Secretarial advisor should be sought forthwith.

This Code forms part of the terms and conditions of engagement for all members of our team.  Violations may be subject to the full range of disciplinary action. We may also report certain activities to governmental authorities, which could give rise to regulatory or criminal investigations.