EMPLOYMENT POLICY STATEMENT 

The HHB Group and its subsidiary Divisions and businesses (“The Group”) is an Equal Opportunity Employer. The Group recruits and selects applicants for employment solely on the basis of their qualifications and suitability for the position in question. It is the Group’s policy to recruit the most capable person available for each position. The Group recognises the need to treat all employees honestly and fairly, respecting their individual and collective rights. The Group wants its employees to feel respected, valued and able to fulfill their potential and recognises that the success of the business relies on their skill and dedication.

Group personnel practices and procedures, including those relating to compensation, benefits, transfers, promotions, terminations, training and self-development opportunities, comply as a minimum with the relevant legal requirements in each of the countries in which its businesses operate and are administered without discrimination regardless of age, race, colour, religion, gender, national origin, or disability. The Group does not tolerate harassment of any employee.

The Board of Directors of each company within the Group are responsible for this Policy. Divisional and business unit management are responsible for implementing and communicating this policy within their own Divisions and business units.

ETHICS POLICY STATEMENT

The HHB Group believes that high standards of business ethics are critical in today’s business world and therefore places high priority on compliance with all legislative and regulatory requirements, and on the maintenance of high ethical standards, within each of the territories and jurisdictions in which it conducts its business.

The HHB Group, its Divisions and businesses (“The Group”) commits to conducting itself, and expects all employees to conduct themselves, in an honest, ethical manner in all dealings on its behalf and to behave professionally and with integrity and fairness. The Group applies these same standards to all business dealings with customers, suppliers and stakeholders.

The Group’s policy is that businesses should compete enthusiastically and fairly in the marketplace and must comply with the relevant competition laws of each country in which it operates. No employee may, either directly or indirectly, offer, solicit, pay or accept a bribe, or other such payment that may be construed as such, in any form. Corporate hospitality may only be offered to or accepted from a third party if it is modest in value and in compliance with any applicable law. Company contributions to political parties, organisations or their representatives are prohibited. All Group employees must maintain the confidentiality of price sensitive and commercial information and not use such information for their personal gain. Reporting of business performance should be undertaken in such a way that reflects the businesses’ true performance and the risks and opportunities that business may face. The Group recognises that it is important that all employees feel confident that they may freely and confidentially voice genuine concerns relating to possible business malpractice or breaches in ethical behaviour to the appropriate management level, which in the first instance should normally be made via the HHB Group Company Secretary. In such circumstances the Group will respect the confidential nature of any communication and ensure the protection of any individuals acting in good faith from harassment or victimisation.

The Board of Directors of the companies within The HHB Group are ultimately responsible for this Policy. The Group’s executive management are responsible for ensuring that the Policy is enacted through integration into the Group’s normal management systems; Divisional and business unit management are responsible for implementing and communicating this policy within their own Divisions and business units. Against a background of evolving business and legal requirements each unit is expected to adapt their activities where necessary to comply with applicable laws and regulations and be consistent with maintaining the Group’s high standards of ethics.

HEALTH, SAFETY AND ENVIRONMENTAL POLICY STATEMENT

The HHB Group and its subsidiary Divisions and businesses (“the Group”) believes it has made and will continue to make proper provision for the Health, Safety and Welfare of its employees at work and others who may be affected by the Group’s activities. The Group strives to care for the environment through its commitment to good environmental practices.

Continuous improvement will be sought by the setting of objectives and targets based on relevant national and international standards, monitoring performance and auditing against these and other relevant Group measures. As a minimum, the Group seeks to meet legislative and other industry standards relevant to its businesses in the countries in which it operates. All existing activities are subject to Health, Safety and Environmental risk assessment and new activities are also assessed for environmental impact and adequate Health & Safety provision.

The Group is committed to providing a safe working environment for its employees. All employees have a responsibility to take reasonable care of themselves and others while at work, adhere to safety rules and work procedures, use safety equipment provided, and to participate positively in the maintenance of safe and healthy conditions in the workplace and the task of preserving a sound environment. The Group maintains a proactive communications strategy between all employees to stimulate continuous improvement and promote and develop good health, safety and environmental practices.

The Group strives to minimise any adverse environmental impact of its activities, through improving energy and natural resource conservation, pollution prevention, minimising waste, recycling materials, safe and responsible disposal of waste and effluent, and minimising where practicable environmentally damaging emissions.

The Board of Directors of companies within the Group are ultimately responsible for this Policy. The Group’s executive management are responsible for ensuring that it is enacted through integration into the Group’s normal management systems; Divisional and business unit management are responsible for developing, communicating and enacting their own policies, rules and procedures which build on the Group objectives outlined here and which are specific to their own Divisions and business units. The Group recognises that the implementation and achievement of the Health, Safety and Environmental objectives depends on the involvement and commitment of employees at all levels.