Partner Code of Conduct

1. Purpose and applicability

This Code of Conduct for Partners of Halberd Bastion (‘Code of Conduct’) is released to promote and ensure the absolute integrity of Halberd Bastion’s business dealings with its Partners.  It is intended to establish clear compliance standards and ethical principles which are expected of all Partners of Halberd Bastion.

This Code of Conduct applies to all Halberd Bastion Partners and their employees, temporary workers, agents, subcontractors, and similar individuals or entities.  Halberd Bastion Partners (Partners) refer to any party that provides products or services to Halberd Bastion.  Halberd Bastion expects all our Partners to be familiar with and comply with applicable laws and regulations and demonstrate high standards of business ethics.

2. Legal compliance

General legal compliance: Partners must comply with applicable laws and regulations in force in their place of incorporation and the places in which they operate as well as any applicable international laws and rules.  Partners are expected to ensure cooperation with Halberd Bastion will not be negatively affected due to legal compliance problems.

Labour protection: Partners must provide their employees with a healthy work environment where they are treated with dignity and fairness and ensure that their employees are free from discrimination or harassment for any reason whatsoever, including skin colour, ethnicity, age, gender, sexual orientation, religion, or political affiliation.

Environmental compliance: Partners must conduct their operations in an environmentally responsible business manner and in strict compliance with applicable environmental laws and standards.

Anti-bribery: Partners shall not offer, make or receive any form of business bribe in order to win or retain business or seek to influence a business decision inappropriately.  This shall include offering or providing any gift or hospitality which is excessive or inappropriate in nature for the purpose of obtaining any improper advantage or illicit benefit.

Unfair competition: Partners shall not monopolize the market or engage in any unfair competition practices individually or in collusion with others.  Typical examples of this conduct include but are not limited to practices that damage the rights and interests of end users: (a) dividing markets through agreement or collusion; (b) fixing prices; (c) coordinating in competing bids; (d) requiring purchase of tie-in products; and (e) abusing a dominant position in the market.

Cyber security: Partners shall strictly abide by all applicable laws and regulations regarding cyber security, data protection and money laundering of the countries/provinces/states in which they operate and shall not infringe the freedom of communication and privacy of end users.

Export control: Partners shall strictly abide by: (a) the applicable laws, regulations, and resolutions regarding export control of the countries in which they operate; (b) any export control laws of Australia; and (c) any further export control obligations Halberd Bastion communicates to a Partner from time to time whether set out in Partners contract or otherwise.

3. Business ethics

Complete and truthful materials: Partners must ensure that all materials they provide to Halberd Bastion are truthful, factual, legitimate, and valid and that full authorization has been obtained from third parties if the materials contain any confidential information related to a third-party.  Partners must also acknowledge that all information they provide to Halberd Bastion, including but not limited to purchase orders, sales reports, special price applications, rebates, payment applications, and changes to important company information, are truthful, accurate, and complete.

Falsified revenue: Partners are not allowed to assist Halberd Bastion employees in recognizing falsified revenue, recognizing revenue in advance, or intentionally delaying revenue recognition by such means as creating fraudulent projects, inflating customer requirements, signing multiple contracts for the same project, or providing fraudulent receipts or acceptance reports, neither are Partners allowed to forge/falsify stamps, official documents, or correspondences of Halberd Bastion in any form.

Lawful acquisition and use of competitor information: Partners are prohibited from using any illegal or unethical means to acquire and use trade secrets or other confidential information of others, including but not limited to improper solicitation or receipt of confidential information from customers, a competitor's employee, or any other party, whether or not such information is owned by the competitor or the third party.

Marketing communication and advertising media: In the course of marketing communication, Partners shall not make false/misleading statements or exaggerate product performance.  Without prior permission from Halberd Bastion, Partners shall not disclose information regarding their projects in cooperation with Halberd Bastion to the media.

During external business interactions, Partners shall not make any false or misleading statements to any party.

Subject to Halberd Bastion audits: Partners shall not cover up any information that may compromise Halberd Bastion's interests.  To ensure compliance with this Code of Conduct, Partners shall be subject to reasonable audits from Halberd Bastion or third parties on its behalf.

Compliance with Halberd Bastion’s Partner policies: To the extent permissible by local law, Partners must strictly abide by Halberd Bastion’s Partner policies, including but not limited to policies and regulations on Partner management, Partner incentives, and supply paths.  They must also recognize Halberd Bastion's exclusive right to develop and interpret the said policies and regulations.

Unauthorized commitments: Partners shall not make commitments to end users or any third party on matters in which they have not been authorized in writing by a Halberd Bastion employee with such express authority to do so.

Any losses incurred by Halberd Bastion from a Partner's unauthorized commitment or its failure to reject the unauthorized commitment of Halberd Bastion employees (i.e. those Halberd Bastion employees not expressly authorized to make such a commitment) shall be fully borne by the Partner on a full indemnity basis and Halberd Bastion shall not be obligated to any contractual commitments to Partner arising from such actions.

Defamation: Partners must operate with integrity and shall not defame or disparage Halberd Bastion.

Bribing Halberd Bastion employees: Partners are not allowed to bribe or transfer illicit benefits to any Halberd Bastion employee in any forms whatsoever, including but not limited to cash, negotiable securities, and payment vouchers, in an attempt to obtain illicit benefits or maintain cooperation with Halberd Bastion.  In addition, Partners are not allowed to give inappropriate gifts and/or etiquette to Halberd Bastion employees that far exceed the propriety of the situation, or any other conduct that could be construed as inappropriate conduct.  Whether the entertainment or gifts are appropriate business etiquette or not shall be determined by Halberd Bastion at its discretion taking into account various factors including considering whether those involved in the giving or receiving would be embarrassed should such events or actions be made known to the public.

This clause also applies to the family members and other close relatives of Halberd Bastion employee.

Conflict of interest relationship: Partners shall not allow those who currently work at Halberd Bastion or their family members to have a stake in their company.  In the event that a Halberd Bastion employee or his/her immediate family member(s) works for a Partner, or acts as an employee, consultant, board member, executive, or shareholder of the Partner, the Partner shall report such situations to Halberd Bastion immediately.

Intellectual property rights and confidential information: Partners shall respect Halberd Bastion’s intellectual property rights.  Without prior permission, Partners shall not disclose any confidential information they have access to during their dealings with Halberd Bastion nor use any Halberd Bastion intellectual property except in accordance with any applicable license granted by Halberd Bastion.

4. Compliance Management

Establishing a compliance system: Halberd Bastion encourages all Partners to establish their own compliance management system to ensure compliance with local laws, fair competition, and alignment with Halberd Bastion’s policies.

Communicating Halberd Bastion’s principles: Partners shall make this Code of Conduct available to their respective Partners or develop an equivalent document with standards not lower than those contained in this Code of Conduct.

Strict employee management: Partners must strictly manage the conduct of their employees, ensure employees abide by their own business conduct guidelines, and require their employees to abide by this Code of Conduct.

5. Miscellaneous

Consequences of any violation of this Code of Conduct: Any violation of this Code of Conduct may result in reduction of incentives Partners are entitled to or the immediate termination of the business relationship with Halberd Bastion.  In addition, Halberd Bastion reserves the right to request Partners to indemnify all losses caused to Halberd Bastion due to their violation of this Code of Conduct.

Version update: Halberd Bastion will post this Code of Conduct on Halberd Bastion's official website at Partner Code of Conduct.  Halberd Bastion reserves the right to supplement and change this Code of Conduct at any time.  Partners are expected to monitor the website regularly for changes to this Code of Conduct.

Submitting questions or reporting violations: If you have any question about this Code of Conduct or become aware of any violations of this Code of Conduct that is believed in good faith to be either an actual or potential violation of this Code of Conduct, please send an email to abuse@halberdbastion.com.  Please submit the questions or report any suspicious behaviour which may constitute a violation with your real name attached.

Please note that the information that you provide to Halberd Bastion must be truthful, accurate and complete to the greatest extent possible.  If necessary, Halberd Bastion expects you to reasonably assist with any investigations into the incident or situation that you report, including providing reasonable access to any associated documentation within Partner control.  Reporting misleading or defamatory information to Halberd Bastion may result in Halberd Bastion's immediate termination of your business relationship with us.