Conflict Of Interest Policy

You should not, directly or indirectly, engage in, or have any interest, financial or otherwise, in any other business enterprise which interferes or is likely to interfere with your independent exercise of judgement in Wupwoo Ltd’s best interest.

Generally a conflict of interest exists when an employee is involved in an activity:

Gifts from vendors, contractors, and others conducting business (or seeking to conduct business) with Wupwoo may appear to be a gesture of goodwill and appreciation and may even be customary business practice, but all staff should be aware that gifts are generally given with the intent to influence a current or future business decision, and accepting such gifts can therefore create conflicts of interest. Acceptance of a gift or other thing of value from a vendor working (or seeking to work) is strictly prohibited. It is the obligation of the employee responsible for a business relationship to handle gifts properly.

Supplemental employment performed outside of the Company may be undertaken only if it does not:

Failure to disclose an interest or relationship or neglecting to comply with the companies requirements for reporting a conflict of interest may subject the employee to disciplinary action up to and including termination of employment.

All employees are required to promptly report to their manager any actual or perceived conflict of interest that they are aware of or suspect.

Should you be in doubt as to whether an activity involves a conflict, you should discuss the situation with your manager.

Review March 2020

Version 2

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