Code of Business Ethics

Our Code of Business Ethics

We at BTB set out how we will achieve and maintain our high ethical standards in our Code of Business Ethics. The Code, which summarizes our company’s basic policies and directives, is accessible to all employees. It covers the importance of following laws and statutes that concern our operations and financial reporting. It also gives details on how to protect information about our operations, customers and suppliers.

 
The Code is periodically reviewed and acknowledged by all employees. The Code, which is a reminder of each employee’s responsibilities, is a tool to help everyone deal with situations in which they are unsure how to act. The process of acknowledging the Code is a way to raise awareness and ensure the business is run with integrity so that the company can maintain credibility with customers, partners, employees, shareholders and other stakeholders.

 
We at BTB share the commitment to the highest level of integrity and ethics in the conduct of business. Integrity and ethics have always characterized the way we conduct business. Operating with a strong sense of integrity is critical to maintaining trust and credibility with our customers, partners, employees, shareholders and other stakeholders. Creating an environment of transparency in the conduct of business is a high priority for all of us. Our Code of Business Ethics is our promise to operate with truthfulness in our dealings and communications to the marketplace. We expect that the company will be operated in accordance with the principles set forth in this Code and that everyone, from the director and the executive team to each individual employee, will be held accountable for meeting these standards.

 
Our Code of Business Ethics contains rules regarding individual and peer responsibilities, as well as responsibilities to our employees, customers, suppliers, shareholders and other stakeholders and includes:

  • Compliance with laws, rules and regulations (including insider trading laws)
  • Protecting confidential and other proprietary information and that of our customers and vendors
  • Protection and proper use of company assets
  • Respecting human rights throughout our business operations
  • Dealing with conflicts of interest
  • Promoting full, fair, accurate, timely and understandable disclosure in financial reports and other public communications
  • Protecting the environment
  • Supporting the reporting of any unlawful or unethical behavior

 

1. COMPLIANCE

Each of us is required to review and follow this Code, as well as to comply with all applicable laws and policies and directives. Failure to do so may result in civil and criminal liability and may result in disciplinary actions including termination of employment.

 
We place additional responsibilities on our managers. They must, through their actions, demonstrate the importance of compliance. Leading by example is critical, as is being available for employees who have ethical questions or wish to report possible violations. Managers must ensure that this Code is enforced through appropriate disciplinary measures. Managers may not turn a blind eye toward unethical conduct. Waivers of this Code of Business Ethics may be granted on a case-by-case basis but only in extraordinary circumstances. Waivers of this Code for employees may be made only by a Director. Any waiver of this Code for our managers with financial reporting responsibilities may be made only by Director.

 
Employees, managers, suppliers, customers and others are encouraged to report any conduct that they believe, in good faith, to be a violation of laws or the Code of Business Ethics to Director. If the manager is involved in the situation or cannot or has not adequately addressed the concerns, employees are advised to report to a Director. Managers are expected to seriously address a reported issue and work to ensure a satisfactory resolution in alignment with our Code of Business Ethics and values and with any regulatory obligations. BTB will not accept any discrimination of or retaliation against the individual reporting the violation for having in good faith reported alleged violations.

 

2. LABOR

BTB is committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. The recognized standards, as set out in the annex, were used as references in preparing the Code and may be a useful source of additional information.

 
Our labor standards are:

 
1) Freely Chosen Employment – Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers will not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.

 
2) Child Labor Avoidance – Child labor is not to be used in any part of conducting business. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs,which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.

 
3) Working Hours – Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-day week.

 
4) Wages and Benefits – Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.

 
5) Humane Treatment – There is to be no harsh and inhumane treatment including any sexual harassment, sexualabuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements are clearly defined and communicated to workers.

 
6) Non-Discrimination – BTB is committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age,gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions,rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.

 
7) Freedom of Association – Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers’councils in accordance with local laws shall be respected. Workers are able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.

 

3. HEALTH AND SAFETY

BTb holds adhering to health and safety standards as basic human rights:

 
1) Occupational Safety – Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are controlled through proper design, engineering and administrative controls, preventative maintenance and safety training. Additionally, BTB shall participate more than 80% in covering expenses for yearly health check for its each and every employee.

 
2) Emergency Preparedness – Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

 
7) Sanitation, Food, and Housing – Workers are provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by BTB or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.

 

4. ENVIRONMENT

Environment is an area of importance to us and our stakeholders and BTB has for many years been actively working to minimize its environmental footprint. One of the our main environmental goals is to reduce the energy consumption and waste production within its operation processes by:

  • Continuously reducing the environmental impact of our own operations
  • Increasing the knowledge and awareness about sustainability among employees
  • Engaging in selected activities that, in addition to promoting BTB’s business, have positive socio-economic impacts and promote the vision of communication for all
  • Engaging our suppliers to ensure adequate sustainability standards in our supply chain
  • Actively engaging with our stakeholders about our sustainability performance

 

5. ETHICS

At BTB, we make business decisions based on the best interests of the company rather than personal considerations or relationships. A conflict of interest arises when anything interferes with or influences the
exercise of an employee’s independent judgment in the best interests of BTB. We must avoid situations in which our personal interest may conflict with, or even appear to conflict with, the interests of BTB.

 
BTB sets out a set of rules considering dealing with conflicts of interest. The following are examples of situations to be particularly aware of:

  • Business opportunities – You may not take business opportunities for yourself that are discovered in your duties for BTB if this could be contrary to the interests of BTB. Nor may you otherwise use BTB property or information or your position at BTB for personal gain.
  • Other Employment – Any employment outside BTB, with or without compensation, must not harm job performance at BTB. You may not engage in outside business interests that divert time and attention away from BTB responsibilities or require work during BTB time. Avoid any potential conflict of interest by not accepting employment from any organization or suppliers, contractors, agents, customers or competitors to BTB.
  • Board memberships and other outside affiliations – Service of BTB employees on a board of directors or similar body of a for-profit enterprise or government agency is not permitted if creating a conflict of interest. All such service must be approved in advance by your manager. Serving on boards of not-for-profit or community organizations does not require prior approval unless there is a potential conflict of interest with BTB.
  • Political activities – BTB will not make contributions or payment or otherwise give any endorsement, directly or indirectly, to political parties or committees or to individual politicians. You may not make any political contribution on behalf of BTB or through the use of corporate funds or resources.
  • Gifts, benefits, reimbursements and entertainment – An BTB employee may not offer or accept gifts, benefits, reimbursements or entertainment to or from a third party that would constitute a violation of laws or that could affect, or appear to affect, the professional judgment in the performance of the respective work or duties for BTB or a third party.
  • Bribes, kickbacks, etc. – No one may, directly or indirectly, demand or accept, offer or give any kind of bribe, kickback or any other unlawful or unethical benefit to employees or other representatives or associates of BTB or any third party. Any such offer or proposed arrangement must be reported immediately to Director.
  • Disclosure of conflicts of interest – BTB requires that employees disclose situations or transactions that reasonably would be expected to give rise to a conflict of interest. If you suspect that you are involved in a transaction or any other arrangement that presents a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it to Director. Director will work with you to determine whether there is a conflict of interest and, if so, how best to address it. Although transactions or arrangements presenting conflicts of interest are not automatically prohibited, certain of such transactions or arrangements may be undesirable, and for certain persons, such as members of senior management, such transactions or arrangements may require the approval by the Director.

 
To meet social responsibilities and to achieve success in the marketplace, BTB uphold the highest standards of ethics including:

 
1) Business Integrity – The highest standards of integrity is upheld in all business interactions. We have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business dealings should be transparently performed and accurately reflected on BTB business books and records. Monitoring and enforcement procedures are implemented to ensure compliance with anti-corruption laws.

 
2) No Improper Advantage – Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

 
3) Disclosure of Information – Information regarding business activities, structure, financial situation and performance are only disclosed in accordance with applicable regulations and prevailing practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.

 
4) Intellectual Property – Intellectual property rights are respected; transfer of technology and know-how is tobe done in a manner that protects intellectual property rights.

 
5) Fair Business, Advertising and Competition – Standards of fair business, advertising and competition are upheld. Appropriate means to safeguard customer information are available.

 
6) Protection of Identity – Programs that ensure the confidentiality and protection of supplier and employee whistleblower are maintained.

 
7) Privacy – BTB is committed to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers,consumers and employees. BTB comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

 
8 ) Non-Retaliation – all personnel is able ad stimulated to raise any concerns without fear of retaliation.

 

6. ENVIRONMENT MANAGEMENT SYSTEM

BTB implements environment management system:

 
1) Company Commitment – A social and environmental responsibility policy (this Code of Business Conduct) statements affirms BTB’s commitment to compliance and continual improvement and is endorsed and enforced by executive management.

 
2) Management Accountability and Responsibility – BTB clearly identifies company representative responsible for ensuring implementation of the management systems and associated programs. Management reviews the status of the management system on a regular basis.

 
3) Legal and Customer Requirements – BTB implements the process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

 
4) Risk Assessment and Risk Management – BTB implements the process to identify the environmental, health and safety and labor practice and ethics risks associated with it’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.

 
5) Improvement Objectives – BTB maintains written performance objectives, targets and implementation plans to improve the it’s social and environmental performance, including a periodic assessment of performance in achieving those objectives.

 
6) Training – BTB maintains programs for training managers and workers to implement policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.

 
7) Communication – BTB implements the process for communicating clear and accurate information about the policies, practices, expectations and performance to workers, suppliers and customers.

 
8 ) Worker Feedback and Participation – BTB implements the processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.

 
9) Audits and Assessments – BTB performs periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

 
10) Corrective Action Process – BTB implements the process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

 
11) Documentation and Records – BTB maintains documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

 
12) Supplier Responsibility – BTB implements the process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.