iTree Group Code of Ethics and Business Conduct

Antitrust and Competition

All companies in the iTree Group family of companies comply fully with all applicable national and European Union laws regarding anti-trust and competition.

We do not: 
1. Agree with any competitors to fix or control prices either directly with competitors or through third parties or by any other method;
2. Structure or orchestrate bids to direct a contract to a certain competitor or reseller (bid rigging), including abstaining from bids or submitting noncompetitive or “courtesy” bids.
3. Boycott suppliers or customers, unless directed to do so by applicable national or international legal acts.
4. Limit the sale or production of any of our products or services.

Improper Payments, Money Laundering and Economic Boycotts

We do not offer, promise, authorize, direct, pay, make or receive any bribes, kickbacks or payments of money or transfer of anything of value (either directly or indirectly) to improperly obtain business to any natural or legal person in the private or public sectors.

We do not participate in any economic boycott not sanctioned by governments in the countries in which we operate. For products and services of our Partners, originating in the United States, we do not participate in any economic boycott not sanctioned by the United States government. We do not provide information that could be construed to support any such unsanctioned boycotts.

Dealing with Government

We strictly observe all laws, rules and regulations that govern purchasing of goods or services by public sector organisations and performance of contracts with public sector organisations. We ensure that all invoices submitted to public sector entities are accurate and comply with all laws regarding invoicing and payments. We maintain proper internal controls to ensure compliance with all applicable laws concerning prohibition on offering anything of value to government and public sector employees or officials.

We do not:
1. Attempt to obtain, directly or indirectly, from any source, procurement-sensitive information that is not publicly available or otherwise authorized for disclosure; confidential internal government information, such as pre-award, source selection information; or any proprietary information of a competitor, including, for example, bid or proposal information, during the course of a procurement or in any other circumstances where there is reason to believe that the release of such information is unauthorized. 
2. Give or offer, either directly or indirectly, any gratuity, gift, favor, entertainment, loan, or anything of monetary value to any government or public sector employee or official except as may be permitted by applicable law. 
3. Provide, attempt to provide, offer, or solicit a kickback, directly or indirectly, to obtain or reward favorable treatment in connection with any transaction.
4. Pay or enter any agreement to pay, directly or indirectly, a contingent fee to any party for the purposes of obtaining a government contract or influencing government action. 
5. Receive any contingent fees or participate in any influence/referral fee program on any transaction involving a government or public sector end user (this includes, but is not limited to, public higher education, public healthcare, and utility entities).

Lobbying of Government Officials

We do not lobby any public sector officials on behalf of our Partners. If we do use consultants or lobbyists, we disclose those individuals and entities to our Partners. We do not use the same consultants or lobbyists as our Partners, and, they do not use the same ones as we do.

Trade Compliance Laws and Regulations

We observe all local and European Union global trade laws and regulations, which govern imports, exports, re-exports and use of commodities, services and technical data. For products and services originating in the United States of America, we also fully comply with all applicable US and global trade laws and regulations.

iTree Group services are delivered through our subsidiaries:

• iTree Lietuva

• iTree Lietuva is a leading provider of IT solutions for the insurance sector, with projects in Scandinavia, Poland, Lithuania, Latvia, the Czech Republic, Slovenia, Hungary & Ukraine. Headquartered in Vilnius, iTree Lietuva has a large team of experienced engineers and consultants specializing in insurance technology. Our team has 15+ years experience in supporting global insurance companies. iTree Lietuva delivers a broad range of database, middleware and application development & support services, and, together with iTree Finance, boasts a team of 140+ professionals in Vilnius.

• iTree Poland

  iTree Poland focuses primarily on solutions for the insurance market and supports iTree initiatives in the large Polish market.