"Committed to defining boundaries in a professional communication system, we adopt strict measures to ensure that it remains intact at all times"

Every year, we subject our clients and experts to read and sign our expert network compliance policy document. This is done to avoid them from soliciting and divulging Material Non-Public Information (MNPI) during their interactions. It also avoids violating legal, contractual, and fiduciary obligations that are binding on them.

Compliance Considerations For Experts

Golden Apple is not an investment adviser, we do not conduct business as an investment adviser or permit our experts to provide investment advice. Our experts agree not to provide Golden Apple or any client any investment advice concerning the value of any security. Whether that is buying, selling, or otherwise investing in any security. Experts are strictly prohibited from disclosing confidential information: Material, non-public information (MNPI).

CURRENT EMPLOYEES

Our experts cannot participate in a consultation if the topic is a company for which they are a current employee. The only exception to this rule is if they are the proprietor of the company. They also agree not to consult for a client that may be a direct competitor.

FINANCE, ACCOUNTING & STRATEGY EMPLOYEES

Experts previously employed in Finance, Accounting & Strategy roles are not permitted to discuss finance, stategy and accounting issues within one year of their departure of the company. In no case, will this information entail anything proprietory to the companies in which they have previously worked in.

GOVERNMENT EMPLOYEES

Current government employees cannot participate in Golden Apple DWC LLC projects if their employers prohibit outside consulting. In any case, they will not discuss legislations, regulations or policies that they may be in a position to influence.

HEALTHCARE PROFESSIONALS & CLINICAL TRIAL PARTICIPANTS

Current Healthcare professionals are prohibited to disclosing patient and any other information that they are not allowed to disclose under their relevant jurisdictions. They confirm that they are licensed in all jurisdictions in which they practice in and have the relevant authority and certificates to provide advice. Clinical trial participants agree to the same, and in no case will disclose any confidential information that they learn during their participation in trials and until results are made public.

AUDITORS & LAWYERS

Auditors are not permitted to consult about organisations they have audited in the last three years and Lawyers are not allowed to provide any legal advice during interactions or establish an attorney-client relationship during any Golden Apple DWC LLC project interactions.

Privacy, Anti-bribery & Corruption Policy

Striving to work ethically across all business fields, we have zero tolerance towards bribery and corruption. Our company follows a motto of fair trade and professional integrity in every transaction/conversation held herein.

What is bribery? ⇒ A bribe is a dishonest gift of money. An inducement offered, promised, or given in order to receive any commercial, contractual, regulatory or personal advantage.

What does it include?

– Payment offered to a companies employee or to a third party to secure a business advantage.
– Dishonest gifts, hospitality or expenses payment made to secure a business advantage.
– Political contributions or donations made to secure an unfair business advantage.
– Any facilitation payment made to unfairly secure or accelerate a regulatory routine or necessary business actions.

Enforcement

Our expert network compliance policy is regularly audited to remain suitable and effective concerning all Golden Apple operations.

Any concerns raised by any person or employee related to non-compliance with the terms is promptly investigated. Failure to comply with these terms may legislate a disciplinary offense and may result in civil or criminal proceedings.

Policies & Adoption

Golden Apple does not engage in bribery or corruption. It’s policy strictly discourages any employee or third party to receive any form of incentive which is unlawful, immoral or represents a breach of trust.

We respect the laws relevant to countering bribery and corruption in all the areas in which we operate. Particularly, laws that are directly relevant to specific or local business practices.

Scope

This policy applies to all the Golden Apple employees and associated third parties acting on behalf of the company. It extends to all our business activities in all domains within which the organisation operates.

Responsibilities

All Golden Apple employees and experts receive training consistently in respect of this policy. It is their responsibility to comply with these terms.