Compliance Activities and Policy

5. Relationship with Employees


(1) Respecting Human Rights and Equality

We shall, at all times, maintain a sound working environment, and respect human rights, equality and personality of each individual.

Equal Opportunities Policy in place - as displayed on Achiever (document PP03-4 dated 28/01/03)

Equal Opportunities training delivered to all management in November 02. Communication ongoing

(2) Prohibiting Sexual Harassment

We shall, at all times, abstain from speeches and behaviours that might give sexual unpleasantness to others.

Equal Opportunities Policy in place - as displayed on Achiever (document PP03-4 dated 28/01/03)

Equal Opportunities training delivered to all management in November 02. Communication ongoing

(3) Protection of Personal Information

We shall, at all times, strictly control the confidentiality of personal information of the employees and other outside personnel and the information that we come to possess in the course of our business activities.

Document & Data Control - as displayed on Achiever (CGB:S4.02 dated 01/08/03)

(4) Maintenance of Safe and Clean Working Environment

We shall maintain a safe and clean working environment with the understanding and observance of related laws and regulations.

Health & Safety Policy as displayed on Achiever - (PP01-4 dated 28/01/03)

(5) Observance of Laws, Rules and Regulations Related to Labour and Workers

We shall observe all laws, rules and regulations related to labour and employment, and maintain a safe and pleasant working environment.

Health & Safety Policy as displayed on Achiever - (PP01-4 dated 28/01/03)

Equal Opportunities Policy as displayed on Achiever - (PP03-4 dated 28/01/03)

(6) Rigid Distinction of Company and Private Matters

We shall make rigid distinction between company and private matters, and shall at no time bring personal interests into, or take company matters out of work.

Employee Handbook as displayed on Achiever (Section 5.15 Other Information)

6. Relationship with Company and Company Properties

(1) Observance of Company Rules and Standards

We shall, at all times, observe company regulations and standards.

As per the Employee Handbook - as displayed on Achiever (CFEN-5GQKUX dated 08/09/03) and all other policies and procedures on Achiever

(2) Following Proper Accounting Procedures

We shall follow proper accounting procedures complying with related laws, regulations, internal rules and standards in order to establish an effective internal cross-check system as well as to comply with external requirements.

External auditors - audit these procedures on an annual basis

Internal auditors may audit this procedure CGB:S4.04 dated 09/06/03

(3) Prohibition of Activities with Conflicting Interests

We shall, at no time, engage ourselves in activities that compete with or conflict with our company’s business.

Total quality management and company procedures

(4) Prohibition of Political and Religious Activities

We shall, at no time, engage ourselves in political and religious activities inside company premises.

(5) Control of Confidential Business Information

We shall, at all times, control confidential business information in an appropriate manner, and in no case, disclose this information to the outside without prior permission from the company.

Employee Handbook as displayed on Achiever (Section 5.15 Other Information)

(6) Proper Administration and Deployment of Company Properties

We shall, at all times, maintain company property in safe working order and properly deploy these assets. Also, in no case shall we misappropriate them for personal purposes.

Total quality management of all company procedures

(7) Proper Use of Information Systems

We shall use the company information system only for business purposes, not for the private purposes.

General company policies and handbook as displayed on Achiever

(8) Proper Administration of Documents and Records

We shall, at all times, administrate documents, records and other information in a proper manner, always maintaining an understanding of their importance.

Document & Data Control - as displayed on Achiever (CGB:S4.02 dated 01/08/03)

(9) Protection of Intellectual Property Rights

We shall, at all times, protect intellectual property rights, acknowledging them as important assets.

7. Additional Rules

(1) Scope of Application of the Principle

This Principle is applied in full to all employees of Clarion GB Limited as a subsidiary of Clarion Co. Ltd. It also applies to the personnel assigned to Clarion under contracts from other companies and to part time workers, where applicable.

(2) Modifications and Abolition of the Principle

This Principle shall be modified or abolished only after the approval at the Clarion Co. Ltd. Board of Directors Meeting.

(3) Consultations and Reports

1) In the event questions arise regarding the content and/or interpretations of the Principle, inquiries shall be addressed to the department administering affairs of compliance at Clarion Co. Ltd.
2) In the event of a violation or threat of violation to the Principle, whether by individuals or groups, employees or outsiders, the individual discovering the violation (“Reporter”) shall report their facts to their departmental supervisor. It is the responsibility of the supervisor to insure that the facts are reported to a senior executive of the company. The Reporter may also report directly to the department administering affairs of compliance.
3) The Reporter, as defined under the preceding clause, shall be protected from any disadvantageous treatment(s) due to the act of reporting.
4) Penal Rules
Anyone in violation of the Principle shall be penalized in accordance with company regulations in force at that time.

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