HEALTH, SAFETY AND ENVIRONMENTAL POLICY STATEMENT

It is the Policy of BECTECS Ltd. to comply with all applicable legislation and to conduct all of its activities in such a way as to:

avoid harm to all personnel involved in, or affected by, its operations;

minimise adverse effects of its operations on the environment;

prevent pollution;

respect the interests of neighbours and local communities.

BECTECS Ltd. believes that prevention of accidents and ill-health, protection of the environment and prevention of pollution are essential to the efficient operation of its business. The Company is committed to high standards of health, safety and environmental protection and performance; these aspects command equal prominence with other business considerations in the decision making process.

BECTECS Ltd. believes that health, safety and environmental protection are responsibilities shared by everyone working for the Company and the full support of all staff, partners and contractors is vital to the successful implementation of this Policy. BECTECS Ltd. will ensure, as far as is reasonably practicable, that all personnel are aware of their own, and the Company's, health, safety and environmental responsibilities and that they are adequately informed, instructed and trained to meet these responsibilities.

BECTECS Ltd. will build value through developing sustainable long-term relationships between partners and the community. Health, safety and environmental performance will be monitored and regularly reported to the Board of Directors of the Company. BECTECS Ltd. has established a Health Safety and Environmental Management System to ensure that:

there is an effective management organisation in place;

there is effective co-operation with contractors and responsibilities are defined;

legislation is understood and complied with;

HSE issues are included as part of planning requirements;

Adequate emergency and contingency plans are established.

BECTECS Ltd. will ensure that the necessary resources are provided to fully support this Policy and will ensure that it is subject to audit and review as part of the Management System goal of continuous improvement in performance.

ANTI-BRIBERY & CORRUPTION POLICY STATEMENT

Policy Statement

The Bribery Act 2010 came into force on 1 July 2011 and creates a framework of five criminal offences:

Giving, promising, and offering of a bribe;

Agreeing to receive or accept a bribe;

Bribing a foreign official;

Failure of commercial organisations to prevent bribery;

A senior officer of a commercial organisation consenting to or conniving in an act of bribery BECTECS Ltd. will conduct business in an honest and ethical manner.

BECTECS Ltd. takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

BECTECS Ltd. will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010, which applies to conduct both in the UK and abroad.

Scope

All BECTECS Ltd. employees and others acting on behalf of BECTECS Ltd. must comply with this Anti-Bribery and Corruption Policy and it extends to all business dealings and transactions in the UK and in all countries in which BECTECS Ltd. operates. It is essential that BECTECS Ltd. conducts an effective process of due diligence prior to entering into significant business relationships and that a record is kept of this process.

Any breach of the policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned. This could constitute gross misconduct for which an offending employee may be dismissed without notice. It may also cause serious damage to the reputation and standing of BECTECS Ltd.

Our underlying philosophy is that the Board and employees are expected and required to maintain high ethical standards, legal compliance, responsible corporate behaviour and accountability.

Gifts and hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, any gift or hospitality:

must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

must comply with local law in all relevant countries;

must be given in the name of the organisation, not in an individual's name;

must not include cash or a cash equivalent;

must be appropriate in the circumstances;

must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift; and

must be given openly, not secretly.

BECTECS Ltd. appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.

It is not acceptable for an employee (or someone on their behalf) to:

give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or BECTECS Ltd. will improperly be given a business advantage, or as a reward for a business advantage already improperly given;

give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;

accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;

accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by BECTECS Ltd. in return;

threaten or retaliate against another member of staff who has refused to commit a bribery offence or who has raised concerns under this policy; or

engage in any activity that might lead to a breach of this policy.

Facilitation payment and "kickbacks"

BECTECS Ltd. does not make, and will not accept, facilitation payments or "kickbacks" of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

Charitable donations and sponsorship

BECTECS Ltd. only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with BECTECS Ltd.'s internal policies and procedures.

Record keeping

BECTECS Ltd. maintains appropriate financial records and has appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

Responsibilities and raising concerns

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for BECTECS Ltd. or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees are required to notify BECTECS Ltd. as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any concerns relating to a breach of the Policy should be reported to the Managing Director.

Communication and review

This policy will be communicated to staff via the Employee Handbook, during induction, and at staff meetings. This policy will be reviewed on a biennial basis.

Further information and guidance

This policy sets out the key principles which BECTECS Ltd. must adhere to. The Bribery Act 2010 can be viewed at: http://www.legislation.gov.uk/ukpga/2010/23/contents?view=plain