Employees will:

• Act with respect towards fellow employees, customers and all parties at all times.
• Comply with the letter and spirit of applicable U.S. laws, and the laws of other countries (as permitted by U.S. law).
• Comply with company policies and procedures, contracts with customers, and other binding company commitments.
• Compete ethically and fairly, in accordance with formal procurement rules and ethical business practices.
• Not offer, give or accept a gift or gratuity that might be considered a bribe, kickback, inducement, or reward in dealing with a customer or government official.
• Avoid conflicts of interest or even the appearance of a conflict of interest.
• Not act to gain personally from company business opportunities, without prior approval.
• Keep accurate, timely, and complete company records and reports.
• Protect company and customer assets. Use them wisely for company or customer benefit.
• Protect intellectual property and not disclose confidential information.
• Make no public statements on behalf of the company, without prior approval.
• Report illegal or unethical conduct to management or the employee hotline.

Violations and Consequences

As an Akal employee you have the responsibility to comply with every part of this code. You may ask questions, seek guidance, and must report suspected violations of this Code of Conduct. Retaliation against an employee who comes forward to raise concerns will not be tolerated.

Anyone who violates this Code, including through neglect or intentional disregard, will be subject to disciplinary action, including possible termination. The company also may seek reimbursement from an employee for any losses or damages the company