Access Spectrum Company Limited
Standard Compliance & Sustainability Statement
(Code of Conduct | ESG | Anti-Corruption | Sanctions & Trade Compliance)
Effective Date: January 6th, 2026
Applies to: Access Spectrum Company Limited (“ASC”) Ref: ASC-SOP-CEAST-001-2026
1. Purpose
Access Spectrum Company Limited is committed to conducting its business responsibly, ethically, and in compliance with applicable laws and regulations.
This document outlines Access Spectrum’s principles and practices relating to ethical business conduct, ESG responsibility, anti-corruption, and sanctions & trade compliance.
This statement reflects a practical, proportionate, and risk-based approach consistent with Access Spectrum’s role as an ICT solutions provider.
2. Legal & Regulatory Compliance
Access Spectrum Company Limited conducts its business in compliance with all applicable laws and regulations, including corporate, labor, anti-corruption, and trade compliance requirements.
3. Ethical Business Conduct (Code of Conduct)
Access Spectrum Company Limited is committed to fair competition, conflict-of-interest avoidance, confidentiality, and professional conduct.
Business gifts are limited to nominal and transparent courtesies.
4. Environmental, Social & Governance (ESG)
Access Spectrum Company Limited commits to environmental responsibility, social responsibility, and good governance proportionate to its scale.
5. Anti-Corruption Policy
Access Spectrum Company Limited maintains zero tolerance toward bribery, corruption, kickbacks, facilitation payments, fraud, or unethical conduct.
6. Sanctions, Embargo & Trade Compliance
Access Spectrum Company Limited complies with applicable sanctions and trade laws and applies reasonable, risk-based screening.
Access Spectrum Company Limited may decline or suspend transactions where compliance concerns arise.
7. Supply Chain Responsibility
Access Spectrum Company Limited expects suppliers and partners to comply with laws and ethical principles on a reasonable and proportionate basis.
8. Reporting & Record Keeping
Access Spectrum Company Limited maintains transparent records and encourages reporting of concerns.
9. Continuous Improvement
Access Spectrum Company Limited periodically reviews and improves its compliance practices.
10. Approval
Approved by Management of Access Spectrum Company Limited