Business Ethics Policy Statement

It is Ventec's goal is to maintain the highest standards of ethics, professionalism and business conduct as well as ensure that we act in strict compliance with the law at all times.

We will not tolerate any behaviour or practice that compromises the Company's integrity or honesty.

All decisions will be fair and based on transparent processes.

Compliance

Since the Company aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with Ventec's principles and policies will not be tolerated. Strict adherence to these principles and supporting policies is a condition of employment.

The Managing Director has overall responsibility for ensuring compliance with the objectives of this policy

Independence and Objectivity

Ventec is committed to being fair, transparent and impartial in all of its dealings and our members of staff are expected to uphold specific standards of behaviour, namely:

All staff are required to act in a way that is unbiased, and they must not be subject to any influence which may lead them to act in a way which favours any particular person or organisation.

Other than the salary paid by Ventec, employees may not directly or indirectly accept any form of payment or material benefit from third parties for services they perform on behalf of Ventec.

All staff are required to declare in writing any financial or personal interest, direct or indirect, in another company which is either a supplier to or a competitor of Ventec.

Unethical Behaviour and 'Whistle-Blowing'

The Company promotes a working environment which encourages all members of our team to express their concerns about behaviour or decisions that they perceive to be unethical without fear of reprisal or victimisation. Any member of staff who needs guidance or advice on business ethics issues should speak to his or her manager or the Managing Director.

The Managing Director is responsible for initiating and supervising the investigation of all reports of breaches of these principles and policies and ensuring that appropriate disciplinary action is taken when required.

Employment Policies

Ventec is committed to attaining the highest standards of employment practice and wishes to be recognised as a good employer. It is committed to communicating its strategy and objectives to employees and to keeping employees informed on the Company's progress against the strategy and objectives.

We support and promote the ethos and principles of equal opportunities in employment, striving to create a culture where every member of our team is treated fairly and without fear of harassment or victimization for any reason.

Balancing Transparency with Confidentiality

Ventec will be transparent in all of its operations except where it is constrained by issues of confidentiality.

The Company will strive to communicate clearly and succinctly in order to minimise complexity in our business dealings.

We will comply with the provisions of the Data Protection Act and members of staff will be trained accordingly.

Protecting Business Assets

All members of staff are required to avoid waste and extravagance and are encouraged to identify improvements to systems and procedures to achieve optimal effectiveness, efficiency and responsiveness.

All employees are expected to follow agreed procurement procedures when commissioning third party services. They are also bound by the Company's Business Expenses Policy when incurring business expenses which will be paid or reimbursed by Ventec.The Company's assets and funds may only be used for the legitimate business purposes of Ventec.

Suppliers, Advisors and Agents

Ventec will aim to develop relationships with its suppliers, advisors and agents based on mutual trust and shared values. Therefore:

All members of staff will conduct business with suppliers, advisors and agents in a professional manner.

The Company will pay its suppliers, advisers and agents on time and according to agreed terms.

As far as is practicable, we will engage with our business partners on matters relating to Corporate Responsibility.

Competitors

Ventec will:

Compete in a lawful manner.

Not seek to damage the reputation of competitors, either directly or by implication or innuendo.

Avoid discussing proprietary or confidential information in any contacts with competitors.

Not attempt to acquire information regarding a competitor's business by unlawful means, including industrial espionage, hiring competitors' employees to obtain confidential information, urging competitors' employees, clients or occupiers to disclose confidential information, or any other approach that is not above board.

Governance and Financial Matters

Ventec will:

Comply with all laws, rules and government regulations that are applicable to the Company.

Maintain accurate business records, following best practice in all respects.

Maintain financial statements and accounts in a manner that are accurate and auditable.

Contractual Arrangements

Ventec is committed to meeting its contractual commitments and will build relationships with its suppliers, agents and contracted service providers based on mutual trust.

All members of staff are expected to understand and comply with the terms of the contracts for which they have a responsibility.

Date: August 2015
Signed: Jason Chung
COO Asia

Date: August 2015
Signed: Mark Goodwin
COO USA & Europe