This policy aims to establish principles of integrity and trust by which Confluence Digital Research ("Confluence") interacts with employees, clients, research respondents and business partners. Known collectively as our "Ethics Promise", all Confluence directors, executives, staff, and other company representatives are expected to be familiar with its contents, and apply not only the letter, but particularly the spirit of these guidelines in all their business on behalf of Confluence. Confluence is committed to protecting employees, partners, clients, and the company from illegal, damaging or other unethical actions by individuals, either knowingly or unknowingly. We believe that by setting standards and using sound judgement, Confluence will stand apart from its competitors and become a favoured solution provider to its clients. Clients, customers and business partners have an expectation to be treated fairly and honestly. This Ethics Promise will serve to guide the behaviour of Confluence executives and staff to ensure that this expectation is met at all times. Confluence will under no circumstances tolerate wrong, illegal, dishonest or improper action at any time. Nor will it tolerate actions that contravene its own code of conduct or any other code(s) of conduct to which it publicly subscribes. Should such action be discovered, Confluence will act quickly and responsibly to avoid or minimise any misunderstanding or damage that may result, and will institute appropriate action to ensure that the incident does not recur.

The directors and management of Confluence must lead by example, and in all their business practices act with honesty and integrity, and within the laws, regulations and codes of conduct that apply. All directors and managers welcome suggestions and concerns from employees, and must treat these seriously, in confidence, and with respect. This will instil a culture in which employees will feel able to alert executives to any issues that may require their attention. Directors and managers must fully disclose any conflict of interests concerning their position with or activities on behalf of Confluence.

Employees of and consultants to Confluence will treat everyone fairly, with due respect, and avoid the intent and appearance of unethical, illegal or otherwise suspect practices to avoid bringing themselves or the company in disrepute. Common sense, effort and commitment to ethical behaviour are required of every employee in order to live up to this Ethics Promise. Employees must fully disclose any conflict of interests regard concerning their position with or activities on behalf of Confluence. Employees will always strive to improve Confluence products and increase client satisfaction through effort, prompt response to inquiries, contributing ideas, and professional behaviour at all times. Adherence to this Ethics Promise will be an important consideration in any discretionary rewards or bonuses offered to employees.

Integrity and ethics will be applied through the company, in its approach to research respondents, its interpretation of statistics, its marketing messages and interaction both with clients and among Confluence staff. Ethical behaviour is the minimum standard. In all its dealings with customers, suppliers and partners, Confluence will promote a trustworthy and honest atmosphere to reinforce the vision of ethics within the company. The Confluence ethics message starts with its shareholders and directors, and will be reinforced throughout the organisation. Managers and employees are encouraged to freely discuss any questions or doubts about the integrity or ethics of a particular action, product or engagement. Better to make an informed, considered but ethical decision than a rushed, well-intentioned but unethical choice. Likewise, the board of directors will always be open to questions or suggestions regarding this Ethics Promise, its implications and its applications. The board of directors of Confluence will ensure that every employee, partner, consultant or other representative of the company is made aware of the Ethics Promise and subscribes to its contents.

Confluence will avoid the intent and appearance of unethical, illegal or improper practice in relationships, actions and communications. Confluence will not tolerate harassment or discrimination, and will strive to address historical disadvantages as far as is reasonably possible, above and beyond any legislation or regulation that may exist, without compromising on its values of integrity and quality. Unauthorised use of confidential information pertaining to or held by Confluence, including but not limited to marketing, proprietary technology, personnel, financial and operational information, will be considered a gross violation of this Ethics Promise. Unauthorised use of Confluence resources, assets, business relationships or proprietary information for personal or non-company gain will be considered a gross violation of this Ethics Promise.

Infractions of this Ethics Promise will not be tolerated and Confluence will act promptly to correct any problems resulting from such breach. Any director, manager, employee or other representative found to have violated this policy may be subject to penalties at the discretion of the board of directors. Such penalties may include disciplinary action, revocation of rights, contract repudiation, or termination of employment.