Policy Statements

The following Artemis Optical Ltd (AOL) Policies, SOPs and guidelines provide rules and instructions to all employees with respect to this commitment::

Anti-bribery & corruption Policy AOL prohibits bribery and corruption in all its forms in all business dealings and relationships (including the public and private sector), everywhere the company operates. Use of funds or other assets for any unlawful or improper purpose is strictly prohibited. AOL employees are expected to be vigilant in ensuring enforcement of this prohibition and the proper use of company assets. AOL employees are also expected to comply in every respect with all applicable anti-corruption and anti-bribery legislation. A breach of applicable Anti-Corruption Laws is a serious offence, which can result in considerable sanctions for both AOL and AOL personnel.

Duty to Report SOP This SOP outlines that AOL personnel have a duty to report any known or suspected past, actual or potential violation of policies or procedures, applicable anti-corruption and anti-bribery legislation or any observed instances of misconduct, including pressure to compromise AOL ethical standards. AOL does not tolerate retaliation against anyone who reports in good faith or raises genuine concerns in the best interests of the organization.

Facilitation Payments SOP This SOP sets out clear directives that the payment, authorization of payment, direct or indirect offer, or promise to pay any Facilitation Payments or “grease” payments by employees of AOL is strictly prohibited. In the unlikely event that an AOL employee would have no alternative but to provide a payment to protect against an imminent and serious threat to his or her health, safety or welfare, the demanded payment would be considered an extortion payment and would therefore be permissible under these exceptional circumstances.

Antitrust and Competition Policy This Policy promotes and ensures compliance with antitrust and competition laws as well as regulations to preserve fair, honest and vigorous competition. Since it is not possible to cover all the different requirement levels of the applicable antitrust laws and regulations, this Policy promotes compliance with the highest levels of antitrust legal and ethical requirements and helps AOL employees understand the types of conduct that antitrust and competition laws address.

Business Partners SOP This SOP sets out the general principles and procedures to be observed before entering into and over the duration of an agreement with any Business Partner. AOL expects its Business Partners to adhere to its business principles, culture and values, and comply will all applicable laws and regulations. The Compliance Our business partner due diligence process allows us to base our decisions on full transparency and accountability for third-party risk. The depth of necessary compliance due diligence and the required level of authority for management approval are determined by the risks associated with each engagement.. AOL may terminate any business relationship with a third party acting in a way that is inconsistent with the company’s values and practices.

Political Contribution Policy This Policy sets forth the strict applicable guidelines with respect to making Political contributions. The use of AOL funds, property, services or resources for or in aid of political parties or candidates for public office is prohibited. Exceptions are generally not permitted and would require the prior written approval of the Political Contributions Compliance Committee.

Donations, Sponsorships, Employee Involvement and Corporate Membership SOP The SOP provides a framework for the maintenance of a consistent approach to social and community investment by ensuring funding is globally aligned in accordance with the philanthropic and business objectives of AOL.

Gifts & Hospitality SOP This SOP outlines the procedures that employees must observe with respect to giving or receiving gifts and hospitality. The SOP is supported by helpful tools such as web-based and mobile applications to determine when giving or receiving is appropriate and permitted, especially when Government Officials are involved. Hiring Current or Former Government Officials or Their Immediate Family Members SOP This SOP provides guidance with respect to hiring current or former Government Officials or their immediate family members. The applicable laws and regulations are often complex and may place restrictions on entering into discussions with certain government employees, prohibit their hire as employees or consultants for specific periods of time or place restrictions on the role and responsibilities they can have.

Conflict of Interest Disclosure Guidelines The Conflict of Interest Disclosure Form must be completed each time an employee or a member of their family is engaged in activities that constitute actual, potential or perceived conflicts of interest. Employees must complete the conflict of interest disclosure form when joining AOL and everyone must complete a new form for every change of situation that be perceived as an actual, potential or perceived conflict of interest.

Accurate Record Keeping Guidelines Accurate, complete and reliable records are crucial to our business as they guide decision-making and strategic planning. Accordingly, all our records must be prepared in accordance with applicable laws and regulations as well as AOL accounting and reporting policies and standard operating procedures.

Training and Communication Customized training programs have been designed to raise employee awareness on key ethics and compliance issues. All employees and consultants must read the updated Code of Ethics and Business Conduct (Employee Handbook. The Code covers our values, our policies and anti-corruption principles. It provides us with an ethical framework to help guide our response to the sometimes challenging and difficult choices we may encounter. It is designed to help us make the right choices in a variety of situations − such as what to do when the easy way out is not the right way or speaking up, even when it’s uncomfortable − to help protect AOL best interests. An extensive training program is fully implemented to create appropriate anti-corruption awareness at all levels.. Participants include all executive, senior and general management functions as well as all staff in business development, procurement, project management, general management and government relations.

Counterfeit Avoidance Policy

1. Objective: To eliminate counterfeit and fraudulent products into our supply chain through strict avoidance, mitigation, monitoring and disposition processes.

2. Purchase of Product: Counterfeit product has become a growing concern in customers' supply chains as customers or distributors secure low cost alternative sources AOL are committed to supplying only the highest quality products for our customers. AOL purchase products only through Authorized Manufacturers and Suppliers, thereby ensuring that product is new, authentic, and fully warrantable under the direct supplier and that accurate up-to-date technical information is readily available. AOL do not purchase products from sources other than authorized manufacturers and suppliers. AOL do not purchase refurbished products for manufacturing. Authorized manufacturers and suppliers are continually assessed by product alerts and supplier quality data to determine past performance.

3. Traceability of Product: AOL maintain traceability for purchases from Authorized Suppliers, retaining the original purchase orders and other receiving documentation, including Manufacturers’ Certificate of Conformance, for the required document retention periods.

4. Return of Product: AOL follows a strict returns policy that includes:
• Complete supplier product traceability and certification.
• Incoming inspection to assure that all parts are undamaged and in original packaging.
• All products & Materials to conform to the relevant British or International Standards.
• Only parts that meet these rigorous standards are allowed to be returned to inventory.
Reporting: AOL continually look for signs of counterfeit products by stringent checks on incoming products & raw materials by the following.
• Identification Markings
• Alterations, lot or batch numbers missing, incorrect suppliers logo
• Product Condition
• Paperwork/Certificate of Conformity
• Accompanying paperwork has evidence of tampering, missing information or does not relate to the delivered product
• Chain of Ownership
• Unverifiable traceability to source
• Items delivered from a location differing from previous or from prohibited countries
• A price significantly lower than historical pricing data or market norm
• Availability
• Obsolete or scarce items suddenly becoming available
• O.E.M Certification
• Unavailable O.E.M certification or uncertified O.E.M
• Non-approved Supplier

5. Any suppliers who provide counterfeit or fraudulent products to AOL will be removed from our supplier approval database and appropriate actions will be taken.

6. AOL report all occurrences of counterfeit parts, as appropriate to manufactures, customers and to appropriate authorities.