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, embargoes, export controls, and trade compliance laws and regulations, and applies a reasonable, risk-based approach to screening customers, suppliers, and transactions.
Access Spectrum Company Limited does not engage in business with any country, territory, individual, or entity subject to comprehensive trade sanctions or embargoes imposed by applicable authorities.
As of the effective date of this Statement, comprehensively sanctioned or embargoed countries and territories include, but are not limited to:
- Cuba
- Iran
- North Korea
- Syria
- Crimea, Donetsk, and Luhansk regions of Ukraine
This list is subject to change in accordance with updates issued by relevant authorities, including the United States, the European Union, the United Kingdom, and the United Nations. Access Spectrum Company Limited monitors such updates and applies the most current restrictions.
Access Spectrum Company Limited reserves the right to decline, suspend, or terminate transactions where sanctions or trade 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