Individual Responsibility

Employees of the Company should demonstrate integrity, objectivity and conscientiousness by an honest approach to their various employment and activities, including personal application to Company priorities, mentoring, intellectual contribution and other business activities, by respecting the rights of others, and by ensuring that activities of individuals and groups in the Company are in accord with general ethical principles.

Confidential Information & Restriction on Information Disclosure

GEM Employees are responsible for maintaining the confidentiality of trade secrets and all other information that is of technical or commercial value to the Company. Company confidential information that an employee may have access to or come across in the course of his/her duty is to be used solely in pursuit of the Company's business interests. It must not, therefore, be disclosed (unless otherwise authorized by the Company in writing) by any employee during employment or subsequent to severance of the employee relationship.

Conflict of Interest

It is GEM's policy to ensure that employees do not allow outside interests, if any, to create conflict with the interest of our own company business. Towards this objective, each employee is requested to disclose details of involvement in existing private business, if any, and also details of new business whenever proposed.

All employees are required to devote their full time and attention to the business of the company and should not allow outside interests to divert their efforts or dilute their performance during our business hours. Secondly, outside business interests, if any, including business interests of close family members should not create conflict of interests, particularly in seeking to do business with the company as a supplier, contractor or customer or in competing with the business activity of the company.

Members of Company staff should take all reasonable measures to avoid any situation in which they may have, or be seen to have, a conflict of interest with all other stakeholders. In particular, staff should avoid situations requiring them to supervise, mentor or assess other staff member with whom they have, or have had, an intimate, commercial, familial or other significant relationship.

Business Practice

Business practice varies from country to country and employees of Company should avoid judgmental positions in regard to business practice. Employees should point out the inefficiency and higher cost that accrues from such practice and directly avoid being engaged in any practice whereby favors of any kind are applied in return for consideration from any client or customer group.

Any client demanding or requesting favor is to be referred to the Management.

Loyalty to the Company

It is both reasonable and desirable that all employees of the Company be able to question or criticize the philosophy, statement of intent, economic dealings and other activities of the Company. By reciprocal care staff should not act so as to bring the Company into disrepute through behavior or speech, or through acts which may be emotional, illegal, unjust or inequitable.

Responsibility to Colleagues

Employees of the Company should not behave in ways which might cause discredit or unnecessary disquiet to the area with which they are affiliated. The convergence of loyalties to one's discipline and/or one's affiliation may occasionally conflict with responsibility to the Company. Employees may resolve such conflicts with the help of HR staff, through reasoned informed discourse consistent with both general and Company ethical principles.

The above codes of ethical practice are set out to provide staff with the expected standards of practice and behavior and are set to achieve a positive example within the Company.

Failure to comply with this Code of Professional Ethics can result in an investigation into an employee's conduct and, ultimately, in disciplinary measures.

Against this background, we request all employees sign this Code of Business Ethics as an agreement to abide by aforementioned terms. This document will then be reviewed by the Management for acceptance in principle and thereafter retained with the HR Department.