Code of Conduct

This policy applies to all units of Glow and to all employees regardless of function, grade or standing. References in this policy to “Glow” or “the Company” are meant to include references to all Units of the Glow Group.

  1. The Company’s activities and operations will be carried out in strict compliance with all applicable laws and prevailing rules and regulations of the countries Glow operates in and in line with International Power plc Values, International Power plc Ethics Charter, and International Power plc Anti Bribery Policy Board Statement, as announced by International Power plc. and communicated to all Glow employees.
  2. In each of its decisions regarding its activities and operations, Glow must respect the environment (both our natural and human environment) and take into account the direct and indirect impact of its activities and operations on the environment in order for Glow to conduct itself as a business leader responsible for our shared environment for the sustainable development of its business.

    Under this environmental and social responsibility, Glow is committed to its Glow Environment Policy as announced by the Operations Management and communicated to all staff to encourage concern and respect for the natural and human environment.
  3. Employees will ensure that the Company deals in all fairness with its customers, suppliers, competitors and any stakeholders in order to conduct its business operation. In its relations with governmental agencies, customers and suppliers, the Company will not, directly or indirectly, engage in bribery, kick-backs, payoffs, or other activities which may be construed as corrupt business practices.
  4. The use, directly or indirectly, of Company funds for political contributions to any organization or to any candidate for public office is strictly prohibited, where such contributions are forbidden by applicable laws. Where such contributions are lawful and organized within a legal framework, they must be kept at a minimum, they must be made in a fair and prudent way avoiding any partisan or one-sided attitudes and not being made to organizations or candidates holding extremist views, and they must be approved by the most senior Glow officer.
  5. Sales and marketing agents, representatives and consultants (“Agents”) will be retained and paid only if they operate independently from Glow and in conformity with applicable legislation. All contracts and agreements must be in writing. Compensation must be comparable to that paid to similar Agents for similar work and in accordance with the applicable detailed policy.
  6. Corporate funds and assets must be utilized solely for lawful and proper corporate purposes. Transfer or expenditure of such funds or assets will be undertaken only if the stated purpose is in fact the actual purpose. The transfer or expenditure of such funds and assets must be authorized in writing in accordance with procedures established by Glow. No false or artificial entries shall be made in the Company’s books and records for any reason, and all financial transactions must be accurately and properly accounted for in those books and records.
  7. Employees may not take advantage of, commercialize or exploit any of the Company’s information or property, or their position with the Company, for the purpose of inappropriate personal gains or opportunities.
  8. In principle, employees do not accept gifts in connection with or because of their business activity. Nevertheless, courtesy considerations may lead to their acceptance. However, such gifts must be limited in number and associated with occasions which justify them in accordance with local custom.

    Employees may receive gifts or may accept invitations only if such gifts or invitations have no influence on their decision making and are not illegal under any applicable law.

    No employee may receive cash from any customer, supplier or business associate of Glow, and only gifts or invitations of a reasonable amount are permitted.
  9. Employees, irrespective of their function, grade or standing, must avoid conflict of interest situations between their direct or indirect (including members of immediate family) personal interests and the interest of the Company. Typical conflict situations include providing services (whether as an employee or otherwise) to or owning stock (or stock options) in business entities which are competitors, customers or suppliers of Glow (minor shareholdings of less than 1% in listed companies are generally not considered to be conflict of interest situations).
  10. Employees must notify their direct supervisor of any actual or potential conflict of interest situation and obtain a written ruling as to their individual case (which in the case of directors or senior executive officers can only be given by the Board or one of its committees, and will be disclosed to shareholders).
  11. No employee of Glow can buy or sell shares or other securities of a business undertaking, or give advice on the same, if he or she has access by reason of his or her professional activities with Glow, to any non-public information about that business undertaking (whether a part of the Glow Group or not). Trading by employees of Glow stock, including the exercise of stock options, if any, is possible only in accordance with the more detailed guidelines published from time to time by corporate management (see note on insider trading).
  12. All employees of Glow shall be treated fairly and equally in terms of accountability, rights, remuneration and labor practices and in compliance with the labor law. All benefits provided to Glow employees in addition to their standard remuneration (salary and bonus) must be awarded in full compliance with corporate guidelines and national legislation (including tax regulations) and remain in line with local practice.
  13. Glow will respect the privacy of data relating to individual persons (whether employees or third parties) which it may hold or handle as part of its information processing activities or otherwise, and will support and respect, within its sphere of influence, the protection of international human rights set out in the United Nations’ Universal Declaration of Human Rights.
  14. Employees should maintain the confidentiality of the Company’s and its employees’ and customers’ confidential information which is disclosed to them. Glow recognizes Intellectual Property Rights and other proprietary information as a central shareholder value in any high technology company. Glow takes every appropriate action to preserve and enhance its Intellectual Property and respects the Intellectual Property rights of others.
  15. All officers, executives and managers of Glow and its subsidiaries are responsible for the continuing enforcement of and compliance with this policy, including necessary distribution to ensure employee knowledge and compliance. Non-compliance with this policy will result in disciplinary measures.
  16. Any employees meeting with difficulties in the application of this policy must consult with their management. Any reports of violations of this policy by an employee to his or her supervisor, or directly to Glow’s Ethics Officer, will be treated seriously and confidentially provided they are made in good faith and properly documented, and Glow will not take any retaliatory action against employees or anyone who do such reports.
  17. In line with SET Instructions, Glow employees shall not accept stock options of any company other than Glow.