Introduction

Locktel Academy Ltd. aims to fulfill its legal responsibilities to shareholders, customers, employees, business partners and the wider community by conducting all aspects of business at the highest level of excellence and professionalism, and by operating in an ethical manner. We are committed to customer satisfaction, first-class service and a responsible approach to the environment.

In order to meet these standards, we rely on the honesty and integrity of all our staff, irrespective of level or status within the organization, to point out ways in which we can improve the conduct of our business and make our decisions within a clear and ethical framework.

We wish to encourage a culture of openness, allowing all employees (including temporary employees and subcontractors) to raise and resolve any problems as quickly as possible. We recognise that subcontractors may have their own procedures and we would like to encourage them to add to these procedures so as to enable their employees to report directly to us on our operations.

Every employee must consider it their responsibility to bring Bribery, malpractice or problems promptly to the Managing Directors attention. They must do so if they are genuinely concerned that a business activity of Locktel academy Ltd. or its staff might involve:

• A risk to health and safety
• Damage to the environment
• Any criminal offence including a breach of the Anti-Bribery 2010 Act, including acts of fraud against Locktel Academy Ltd.
• Failure to comply with a legal obligation (under any statute, regulation, contract or at common law)
• Interference with proper judicial process e.g. destruction of evidence in proceedings involving Locktel Academy Ltd.
• Financial misreporting or
• A deliberate ‘cover-up’ of any of the above

Concerns must be reported promptly to Peter Vaskanin – Managing Director.

We will take prompt steps to investigate thoroughly and remedy any deficiencies brought to our attention.