Compliance Principles

The following are the Maloney Compliance Principles that define the standards of conduct and integrity with which all employees to required to comply:

Integrity

Maloney shall operate in a professional, independent and impartial manner in all its activities.

Maloney shall carry out its work honestly and shall not tolerate any deviation from its approved methods and procedures. Where approved test methods make provision for tolerances in results, Maloney Commodity Services shall ensure that such tolerances are not abused to alter the actual test findings.

Maloney shall report data, test results and other material facts in good faith and shall not improperly change them and shall only issue reports and certificates that correctly present the actual findings, professional opinions or results obtained.

Conflict of Interest

Maloney shall avoid conflicts of interest with any related entity in which it has a financial or commercial interest and to which it is required to provide services.

Maloney shall avoid conflicts of interest between Maloney’s companies and/or divisions engaged in different activities, but which may be providing services to either the same client or each other.

Maloney shall ensure that its employees avoid conflicts of interest with the activities of Maloney.

Confidentiality and Data Protection

Maloney respects the confidentiality and privacy of client’s information and ensures processes are in place to adequately protect such information.

All information received in the course of the provision of its services shall be treated as business confidential to the extent that such information is not already published, generally available to third parties or otherwise in the public domain.

Anti-Bribery & Extortion

Maloney strictly prohibits both extortion and the offer or acceptance of a bribe, in any form, including kickbacks on any portion of a contract payment.

Maloney also prohibits the use of any routes or channels for provision of improper benefits to, or receipt of improper benefits from, customers, agents, contractors, suppliers, or employees of any such party, or government officials.

Fair Business Conduct

Maloney shall conduct itself with the highest standards of business ethics and integrity and shall not do anything which would bring its reputation, or the reputation of TIC Council or the TIC industry, into disrepute.

Health & Safety

Maloney shall implement adequate training and procedures to protect the health and safety of employees, customers and third parties, and shall monitor incidents with the view of minimizing risks in the course of business operations.

Fair Labor

Maloney is aware of its social responsibility for its employees and the people, communities and environments in which it works and shall respect human rights.