Code of practice

A. We Avoid Conflicts of Interest

Directors, officers and employees should avoid situations in which their personal interests might conflict, or appear to conflict, with the interests of Orbex. Conflicts of interest may arise in many types of situations, such as when an individual`s financial or other outside interests produce conflicting loyalties, interfere with job performance, or are adverse to the interests of Orbex.

It is Orbex`s policy that officers and employees do not:

• enter into unauthorized business relationships with competitors. Accordingly, officers and employees may not own a competing business or assist any unauthorized person outside Orbex, including family or friends, in the planning, design, manufacture, sale, purchase, installation or maintenance of products that compete or could compete with Orbex`s products or any work performed by Orbex;
• accept any “friends and family” stock or stock option grants or receive compensation in connection with serving on an “advisory board” from a supplier, customer or channel partner with whom you conduct business on behalf of Orbex;
• receive securities from any underwriter or other financial institution (e.g., receive an allocation of shares of stock in a public offering conducted by another company) in connection with or in exchange for Orbex Solutions use of that underwriter or financial institution for investment banking or other services;
• have a financial interest in privately-held suppliers, customers or channel partners (or own more than a small percentage of a public entity) with whom you conduct (or can reasonably expect to conduct) business on behalf of Orbex;
• use Orbex Solutions name, information, property, time or other resources to perform outside activities such as a second job or volunteer, political or community activities not specifically sponsored or approved by the company. These activities must always be kept separate from your duties for Orbex;
• accept a position on a Board of Directors without referring to and complying with Orbex Solutions or
• use any elective or appointed social, political or governmental position, paid or voluntary, within the community to interfere with Orbex business.

Orbex Solutions employees must avoid not only financial relationships or other situations between themselves and other businesses that could result in conflicts of interest, but also circumstances in which their immediate family members are involved in these kinds of financial relationships or situations. This does not mean that an employee`s family members are prohibited from being employed by one of Orbex customers, competitors or suppliers.

B. We do not Allow Gifts or Entertainment to Influence Decision-Making

It is Orbex Solutions policy that directors, officers and employees should not seek, accept or provide, directly or indirectly, gifts, entertainment or other favors of the type or amount that go beyond common courtesies consistent with ethical and accepted business practices. You should avoid even the appearance of a conflict of interest. Accordingly, cash payments are strictly prohibited.

As a general rule, you can accept a gift from non-governmental customers, suppliers or business partners if it’s unsolicited, inexpensive and not given to influence your judgment. Otherwise, you should decline the gift and explain Orbex Solutions policy to the gift-giver. Employees should consult their supervisor if there is any question about a gift.

Employees may provide reasonable (not lavish) entertainment and meals to non-governmental customers, suppliers or other business partners, provided that the entertainment is related to a proper business purpose, that it is not being offered to influence the recipient`s business decision, and that it is permitted under applicable laws, regulations, and rules. Similarly, you should consult your supervisor before accepting an invitation for entertainment that seems lavish or excessive.

Gifts and entertainment for officials and employees of governments, whether in the U.S. or elsewhere, are highly regulated and often prohibited. It is Orbex Orbex Solutions policy that employees and agents should never provide government officials with gifts, entertainment or meals, or cover travel-related expenses of those officials, without satisfying all applicable company policies and procedures for those types of payments. Consistent with applicable laws and company policy, improper payments or gifts provided to government officials in order to obtain or retain business for Orbex are strictly prohibited. Employees who require further guidance can send an email with their questions to support@orbex.co.uk

C. We Report Information in Accordance with Laws and Regulations

It is Orbex Solutions policy that there be full, fair, accurate, complete, objective, timely and understandable disclosure in all reports and documents that Orbex Solutions files with or submits to government and self-regulatory agencies and in other public communications made by Orbex.

There should be no undocumented or improperly approved side agreements with vendors, customers, business partners or other third parties. All representations and warranties regarding the performance or capability of Orbex Solutions products or services should be contained in the final written contract. All side agreements to a written contract should be referenced in the contract. Documentation should clearly indicate if Orbex Solutions products are being moved to a location other than the customer`s place of business or another site specified by the customer. The documentation must be provided to the appropriate recipient in a timely fashion. Questions about requirements for financial reporting, including revenue recognition rules, may be directed to the Accounting and you should send mail or call Orbex Solutions for more information.

D. We Obtain Authorizations and Signatures Before Finalizing Commitments

Orbex Solutions Ltd has adopted detailed guidelines that specify (based on organization and level) which employees have the authority to approve Orbex Solutions entry into specific types of transactions. In addition, Orbex has adopted detailed guidelines that specify (based on organization) who can sign contracts and other documents on behalf of Orbex Solutions Ltd once they have been approved.

With that in mind, before signing an agreement on behalf of Orbex Solutions, you should review those documents. Remember, the obligation to check is yours; our suppliers and customers are not required to know if a document has been properly approved and signed.

E. We Safeguard Orbex Solutions Funds and Property

We are all responsible for safeguarding company funds and property by following procedures to prevent their loss, theft, embezzlement or unauthorized destruction.