GCL International Bulgaria Ltd
(“the Company”) is committed to the practice of responsible corporate
behaviour.

Through its business
practices the Company seeks to protect and promote the human rights and basic
freedoms of all its employees and agents.

Further the Company
is committed to protecting the rights of all of those whose work contributes to
the success of the Company, including those employees and agents of suppliers
to the Company.

The Company is also
committed to eliminating bribery and corruption. It is essential that all
employees and persons associated with the Company adhere to this policy and
abstain from giving or receiving bribes of any form.

This policy is
non-exhaustive, and all aspects of the Company’s business should be considered
in the spirit of this policy.

Fair Competition

The Company engages
in practice an open, and equitable competition in the marketing based on audit
professionalism, value of services, competitive price and customer service etc.

Transfer of
certification from another Certification Bodies should be fair and comply with
applicable procedures and guidelines of accreditation bodies or scheme owners.

Anti-Bribery and
Corruption

The Company is
fundamentally opposed to any acts of bribery and to the making of facilitation
payments as defined by the Bribery Act 2010.

Employees and any
other persons associated with the Company such as agents, subsidiaries and
business partners are not permitted to either offer or receive any type of
bribe and/or facilitation payment.

All employees are
encouraged to report any suspicion of corruption or bribery within the Company
in accordance with the Whistleblowing Policy available on GCL website.

The Company uses its
reasonable endeavours to implement the guidance principles on bribery
management that are published, from time to time, by Secretary of State in
accordance with Section 9 of the Bribery Act 2010.

If an employee or
associated person is found guilty of giving or receiving a bribe, he/she will
be personally criminally liable and may be subject to disciplinary action.

Anyone found guilty
of bribery, will be responsible for bearing any related remedial costs such as
losses, court fees or expenses.

Conflicts of Interest

The Company holds as
fundamental to its success the trust and confidence of those with whom it
deals, including clients, suppliers and employees. Conflicts of interest
potentially undermine the relationship of the Company with its partners.

In order to help
preserve and strengthen these relationships the Company has developed a
Corporate Hospitality and Gifts Policy, which provide rules and guidelines
concerning the conduct of its officers and employees aimed at minimising the
possibility of conflicts of interest and at avoiding risks associated with
bribery and corruption. Copies of the Corporate Hospitality and Gifts Policy
are available on our website: www.gcl-intl.bg

All officers,
employees and representatives of the Company are expected to act honestly and
within the law.

Shareholders and
Investors

Shareholder &
Investor should not involve in the Company day-to-day operations. They shall
not on any occasion, influence the certification decision of any audits to
ensure impartiality of the certification.

On the other hand,
the Company, its officers, employees and representatives are committed to
ensuring that no act or omission which is within their power, and which would
have the effect of deliberately, negligently or recklessly misleading the
shareholders, creditors or other investors in the Company occurs.

Suppliers and
Partners

The Company expects
all subcontract and freelance auditors, suppliers and partners to work towards
and uphold similar ethical and moral standards.

The Company will
conduct a background check pertaining ethical record of potential auditors,
suppliers, and partners before entering into any agreement. Further, the
Company reserves the right to request information from above parties regarding
the production and sources of goods supplied.

The Company also
reserves the right to withdraw from any agreement or other arrangement with any
auditors, supplier or partner who is found to have acted in contravention of
the spirit or principles of this Ethical Policy.

Other Policies

This Business Ethical
Policy should be read in conjunction with Social Accountability Policy
concerning Human Rights & Workers’ Rights, Environmental Policy which
addressing Environmental Issues, Privacy & Data Protection Policy for
information and confidentiality.