Code of Ethics

OS Trio is dedicated to uphold uncompromised integrity in all its operations and adhere to the highest ethical standards. This Code of Business Conduct and Ethics (the “Code”) embodies the commitment of OS Trio and its subsidiaries (the “Company”) to conduct its business in accordance with all applicable laws, rules and regulations and the highest ethical standards. All employees, including officers, and members of the Board of Directors of the Company are expected to adhere to those principles and procedures set forth in this Code that apply to them.

1.1 Business Integrity

Our core values are based on high standards of business integrity. We do not pay bribes, engage in acts of corruption or receive kickbacks either directly or indirectly. OS Trio promotes fair practice and upholds its commitment to high standards of integrity.

1.2 Conflicts of Interest

The OS Trio staff should avoid transactions in which their personal interests could conflict or might be seen to be in conflict of those of the company. This may include: making use of any client information acquired during the course of their employment with OS Trio for personal benefit; transferring such information to a third party; or engaging into an act that could be considered as insider trading.

1.3 Confidentiality

In carrying out the Company’s business, employees and directors often learn confidential or proprietary information about the Company, its customers, prospective customers or other third parties. Employees and directors must maintain the confidentiality of all information so entrusted to them, except when disclosure is authorized or legally mandated. Confidential or proprietary information includes, among other things, any non-public information concerning the Company, including its business, marketing, product and service plans, business and pricing strategies, financial information, forecasts, designs, databases, personnel information, customer and supplier lists and data and similar types of information provided by clients, suppliers and business partners.

1.4 Political Activities

OS Trio follows a policy of strict political neutrality. Donations to any political parties, organisations, or individuals engaged in politics are not acceptable. OS Trio employees are entitled to their own political views and activities, but they may not use company premises or equipment to promote those views nor associate their views with those of the company.

1.5 Business Relationships

OS Trio expects its suppliers, sub-contractors, representatives and joint venture partners to adhere to integrity principles that constitute our core values.

1.6 Guidance

The OS Trio staff must abide by this code in all circumstances. For any doubt about the application of this code, employees should seek guidance from their line manager. The management will provide backing to company staff who find themselves in difficult situations, or who fail to win business, as a result of abiding by the code. OS Trio considers the breach of code very seriously. Employees who fail to abide by the code may face disciplinary action including dismissal.

1.7 Gifts, Gratuities and Kickbacks

Any individual working for or on behalf of OS Trio is strictly prohibited from accepting or offering kickbacks, cash gifts or gratuities from any supplier, customer, competitor or business partner, directly or indirectly. A kickback can be in the form of cash, fee, commission, gift, or anything of value.

2.0 Recruitment Process

At OS Trio, we discourage discrimination and offer equal employment opportunities. We promote workplace diversity and make employment decisions irrespective of race, colour, gender, marital status, ethnicity, religion, age, national origin, sex, sexual orientation, gender identity, veteran status, ancestry, genetic information, disability, or any status protected by federal, state, local or host country law. This applies to all HR aspects including recruiting, hiring, promotions, transfers, terminations, compensation, administering benefits, disciplinary actions, training, performance assessments, and all other employment terms and conditions. A background checks will be conducted by the company during the recruitment process.

3.0 Intellectual Property

OS Trio’s intellectual property rights (our trademarks, logos, trade secrets and “know-how”) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. We strongly encourage you to report any suspected misuse of trademarks, logos, or other OS Trio intellectual property to the Legal Department. Likewise, we must respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose OS Trio and you to criminal and civil fines and penalties. Please seek advice from the Legal Department before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to OS Trio’s proprietary information. You should also check with the Legal Department if you are developing a product that uses content or code to which OS Trio does not yet have a license.OS Trio is not against the proper use of open source as part of the development process. But we must strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against OS Trio. Please seek guidance from the Legal Department prior to utilizing any open source software distributed pursuant to an unapproved license.  Note that this applies whether the development is “customer facing” or “internally-facing.

3.1 Definition of Third Party

Third parties: Separate contract conditions, policies and processes shall apply for the third party.

3.2 Policy

3.2.1 OS Trio will handle complaints from third parties in an effective and appropriate way, and will register such complaints with the appropriate external authorities as and when necessary.
3.2.2 Third parties may file complaints with OS Trio management and staff at any level. Complainants can email to
3.2.3 Complainants should present their complaint in a written form, providing complete information about circumstances and OS Trio’ alleged involvement.
3.2.4 If complainants believe that complaints have not been handled appropriately, and prefer to seek redress through an independent body, they are advised to seek support from a relevant external body.

3.3 Initiation, conduct and reporting of investigations into third party complaints

3.3.1 An Office or Department head, or a Regional Director, can initiate an investigation into third party complaints. The concerned body will inform its line manager and submit a report describing the findings.
3.3.2 Where an investigation reveals that a crime or serious disciplinary offence may have been committed, the Regional Director will refer the matter immediately to the operations department.
3.3.3 The investigation’s findings would be communicated to the complainant in written form, upon conclusion of the investigation.

3.4 All OS Trio Employees must

3.4.1 Guide complainants about the process and assist them in complaint submission
3.4.2 Ensure that complaints are escalated through the company’s line management system to an appropriate level
3.4.3 Refer to their line manager when they are in doubt and ensure that investigations are fully supported

3.5 Responsibilities of Heads of Office and Departments

3.5.1 Create awareness about the policy internally as well as externally.
3.5.2 Conduct training and implement processes to ensure policy compliance
3.5.3 Ensure that complaints are investigated completely in line with the policy, and that appropriate disciplinary action is implemented when required.
3.5.4 Guide complainants about the outcome of investigations and disciplinary action in written form, and ensure that appropriate reimbursement is made.
3.5.5 Ensure that action is taken to report complaints to the appropriate external authorities.
3.5.6 Ensure that OS Trio provides full support to external investigating authorities.

3.6 Legal Counsel

Where a criminal act may have taken place, the Legal Counsel will take the matter to the appropriate authorities and facilitate the investigation.

4.0 Monitoring and updating of the code

This Code shall be subject to periodical verification and, if needed, updates. ln the event that any changes are made, the revised Code shall be effective immediately at anytime without prior notice.