Ethics Policy

As members of the Omega 365 team, employees are required to exhibit the highest standards of honesty and integrity. Every team members’ actions can have a direct impact on the Omega brand, its people, and environment.

Accordingly, all employees must familiarize themselves with our policy of ethics and dedicate themselves to offering their colleagues, clients, and business partners a service based on honesty, impartiality, fairness, and equity, dedicated to the protection of health, safety, and the environment.

Omega’s code of ethics is built around the company's core ethical values: respect for the individual, uncompromising integrity, and honesty and reliability.

Respect for the individual

Omega is made up of a wide variety of exceptional people. The Omega environment demands that all employees are treated with understanding and respect, and that team members aim to assist and maximize each other’s potential whenever possible.

• We respect the capacity and desire for personal growth
• We deal with each other in an open and honest way
• We encourage constructive criticism
• We believe a collaborative environment enables continuous learning
• We lead by example
• We encourage pluralism, guard the principles of non-discrimination, and take particular care not to discriminate based on sex, race, age, religion, ethnicity or nationality
• We accept the responsibility as a company, and as individuals, to prevent situations that jeopardize the health of employees and/or their families

Uncompromising integrity

In order to maintain a profile of uncompromising integrity and strict ethical conduct, we expect that employees maintain their own personal integrity in work situations. Omega’s profile is built on the actions of every employee. In order to assess your ethical integrity, ask yourself the following questions:

• Have I lied or caused anyone to have a false impression of my motives or objectives?
• How would I feel if the full details of what I did appeared on the front page of a newspaper?
• Can I justify my actions to each of the parties involved?
• Have I discussed the situation with my manager and/or other colleagues?

If you are ever in doubt about ethical actions or decisions, please be open and ask an Omega Manager, or email your concerns to whistleblowing@omega365.com

Honesty and reliability

Omega’s reputation is built on honesty and reliability. As a representative of Omega, it is integral that every employee takes on these values as their own and performs their everyday work in an honest and open manner. Be sure to promise only what you can deliver and always deliver what you promise.

In order to maintain Omega's reputation:

• We distinguish between right and wrong and do the right thing
• We observe absolute confidentiality when required
• We present our capabilities honestly
• We do not misrepresent our purposes
• We only make promises that we can keep
• We measure our success by our clients’ success
• We take time to consider the consequences of our actions

Employee responsibilities

All employees and personnel engaged by an Omega company are required to abide by our ethics policy. Responsibilities under this policy include:

• Abiding by applicable laws, regulations and policies
• Actively promoting honesty and integrity
• Ensuring confidentiality
• Maintaining impartiality in all business dealings
• Applying facts and written contracts/agreements as a basis for dispute resolution
• Avoiding business situations that may conflict with Omega’s best interests
• Declining gifts, contributions, services or other benefits unless insignificant in value (where non-acceptance may cause offence the employee must report the acceptance to, and seek advice from his/her manager immediately)
• Refraining from business matters that may inhibit the employee’s impartiality
• Reporting actual or potential conflicts of interest to management as soon as possible
• Avoiding other paid employment or work of significance without permission from Omega
• Not engaging in corrupt activity or permitting bribery
• Immediately reporting corruption or bribery, or attempted bribery to management
• Not having direct or indirect economic interests, employment or board positions at Omega's commercial counterparties
• Refraining from the facilitation of payments
• Not engaging in any form of slavery or human trafficking
• Not engaging in any form of child labour (any work that deprives children of their childhood, interferes with their ability to attend school regularly, or is mentally, physically, socially or morally dangerous and harmful)
• Immediately reporting child labour, slavery or human trafficking, or attempts of such
• Not engaging a party in the position of a partner agent of Omega

Whistleblowing

This policy is to be used for reporting serious concerns and irregularities in the client’s or Omega’s business activities in situations when reporting through the regular organizational lines is not an option, ref our Whistleblowing Policy. The channel for whistleblowing in Omega is the email address: whistleblowing@omega365.com

Consequences of infringement

Breaches of Omega’s policies or applicable law may result in disciplinary action or reports to the appropriate authorities. Employees who offer, pay, solicit or accept bribes will be dismissed and, if possible and appropriate, prosecuted.