Ethics

Policy Statement
The policy of Zerfass Engineering Ltd. is to comply with all governmental laws, Industry rules and regulations applicable to our business.

The company’s ethics policy does not stop there. Even where the law is permissive, the company chooses a course of high integrity. Local customs, traditions and values differ from place to place, and this must be recognized. But honesty is not subject to criticism in any culture. Shades of dishonesty simply invite demoralizing and reprehensible judgments. A well-founded reputation for scrupulous dealing is itself a priceless corporate asset.

The company cares how results are obtained, not just that they are obtained. Directors, officers and employees should deal fairly with each other and with the company’s suppliers, customers, competitors and other third parties. The company expects compliance with its standard of integrity throughout the organization and will not tolerate employees who achieve results at the cost of violation of law or who deal unscrupulously.

The company’s directors and officers support, and expect the company’s employees to support, any employee who passes up an opportunity or advantage that would sacrifice ethical standards.

It is the company’s policy that all transactions will be accurately reflected in its books and records. This, of course, means that falsification of books and records and the creation or maintenance of any off-the-record bank accounts are strictly prohibited.

Employees are expected to record all transactions accurately in the company’s books and records, and to be honest and forthcoming with the company’s internal and independent auditors.

The company expects candor from employees at all levels and adherence to its policies and internal controls. A detriment that results when employees conceal information from higher management or the auditors is that other employees think they are being given a signal that the company’s policies and internal controls can be ignored when they are inconvenient. That can result in corruption and demoralization of an organization.

The company’s system of management will not work without honesty, including honest bookkeeping, honest budget proposals and honest economic evaluation of projects. It is the company’s policy to make full, fair, accurate, timely and understandable disclosure in reports and documents that the company files with the Zerfass Engineering Ltd’s owners, regulators, and in other public communications. All employees are responsible for reporting material information known to them to higher management so that the information will be available to senior management responsible for making disclosure decisions.

Daniel Zerfass, M.Eng, P.Eng