OFILM Code of Conduct & Statement of Principles

OFILM is committed to attain and uphold the highest standards of social responsibility, employee well-being and ethics, and to create an inclusive, diverse and cooperative work environment, both in places of work as well as company accommodation.

We value each person’s contributions and dedication to our business success over the long-term. We succeed as a company, as a trusted partner to other companies, because our employees at all levels feel respected, encouraged and safe every day of their working lives. This is our earnest goal. We need all of your input, insights, feedback to fulfill and strengthen our Code of Conduct.

We seek ongoing improvements in all aspects of our business. Employee feedback helps drive this, and is a vital part of creating a safe and respectful workplace for everyone.

We want to first state our fundamental commitments to you.

1. Equality and Mutual Trust: There shall be no unreasonable restrictions on worker’s freedom of movement or freedom of association in any of our premises. In addition, there will be no unreasonable restrictions on entering or leaving company premises for work or personal reasons.

2. Uphold the Law: We will always abide by the laws and regulations of the nations where we operate, including all labor laws. These laws help protect worker’s rights and freedoms. They are a foundation for all of our efforts to create an excellent environment for each worker to pursue his or her career goals.

3. Humane Treatment: We will not tolerate any harsh and inhumane treatment anywhere in our company. This includes prohibitions against any form of sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers. Not only these acts themselves, but any threats to engage in such unacceptable conduct, are prohibited. Employees who violate this policy will be subject to disciplinary action up to and including termination.

Our anti- harassment policy applies to and prohibits harassment by any person involved in the operations of the Company including supervisors, co-workers and independent contractors. Our anti-harassment policy also protects employees from harassment by and in engaging in harassment of clients, vendors, or others doing business with OFILM.

In addition to sexual harassment our Code of Conduct prohibits all types of harassment which are based on an employee’s gender, race, color, creed, sex, marital status, age, national or ethnic origin or ancestry, religious beliefs and practices, medical condition or any other basis.

4. Non-Discrimination: We take pride in being an equal opportunity employer. We make employment decisions on the basis of merit. We want to have the best available persons in every job. Company policy prohibits unlawful discrimination based on genetic characteristics or information, race, color, creed, gender, marital status, religious creed, gender identity, gender expression, age, national origin or ancestry, physical or mental disability, medical condition, veteran status, sexual orientation or any other consideration. All such discrimination is unlawful.

We shall not engage in discrimination based on gender, race, color, creed, sex, marital status, age, national or ethnic origin or ancestry, religious beliefs and practices, medical condition or any other basis.

5. Non-Retaliation: We prohibit retaliation against any employee because of the employee’s opposition to a practice the employee reasonably believes to constitute employment discrimination.

6. Non-Coercion: Employees are never coerced to work for us.

We hope all employees are satisfied by their working experience, pay and career prospects. That is our commitment. If not, we respect all employees’ rights to resign voluntarily. Any and all back pay or severance will be paid promptly by OFILM to departing employees.

7. Wages and Benefits: We are committed to a simple principle: Equal Pay for Equal Work. This is applicable for all employees, regardless of race, nationality or origin. Compensation paid to workers shall comply with all national wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

8. Ethical Practices: All employees at all levels are expected to observe high standards of ethics and good judgment in all activities relating to their employment at OFILM.

9. Your Health and Safety: We place high importance on the health and well-being of every employee. We endeavor to provide safe working conditions for all employees. Although the Company strives to maintain high safety and health standards, the success of such a program also rests with our employees.

Please do not take unnecessary safety risks under any circumstances. Please report to management any unsafe condition you observe that represents a potential hazard to the safety of any employee, customer or visitor to our locations.

10. Zero Tolerance Policy for Workplace Violence: We affirm that violence in the workplace – physical or emotional – is unacceptable. The costs of workplace violence are great, both in human and financial terms. Therefore, we adopted this Zero Tolerance Policy for workplace violence.

Acts or threats of physical violence, including intimidation, harassment and/or coercion, which involve or affect your work for OFILM will not be tolerated.

11. Focus on Employee Development: We seek to enable all employees to improve their skills and abilities. For this, we provide regular opportunities for training and skill enhancement.

12. A Free and Open Environment: We seek to create a free and open cultural atmosphere at all locations. Employees can freely control their time outside work. We embrace cultural diversity and expect all our employees to do as well.

13. Voicing Your Concerns: We don’t condone any violation of this Code of Conduct.

We believe work-related problems, questions, or complaints can best be resolved by frank and prompt discussion between our employees and management. Work-related problems or issues should be brought to the immediate attention of management for resolution.

If an employee has a work-related problem or issue, the following procedure should be followed:

A．The employee should discuss the issue privately with his/her immediate supervisor.

B. If the immediate supervisor is unable to or does not solve the issue, or if the matter is personal in nature or the employee does not feel comfortable discussing the matter with his/her immediate supervisor, the employee should discuss the matter with the next level of management or with Human Resources.

C. If the employee is not satisfied with the resolution of the issue at this level, he/she may take the issue to each level of management up to the CEO, whose recommendation the matter will be final and binding.

D. Employees shall be able to use this procedure without any fear of retribution.

A Final Word: We appreciate and value each employee’s choice to be part of our company, to help contribute to its long-term success. We affirm our commitment to each of you to maintain and enhance a high standard of conduct and fairness as an employer.