Code of Conduct

At Hill Top Country Club Limited (“Hilltop”), in performing the job duties, our employees are expected to use their judgment to act, at all times and in all ways, in the best interests of Hilltop. A "conflict of interest" exists when an employee's personal interest interferes with the best interests of Hilltop. For example, a conflict of interest may occur when an employee receives a personal benefit as a result of the employee's position with Hilltop. A conflict of interest may also arise from an employee's business or personal relationship with a customer, supplier, competitor, business partner, or other employee, if that relationship impairs the employee's objective business judgment.

Because an employee's receipt of gifts or services could create a conflict of interest, the Internal Control Department developed a Code of Conduct for employees relating to the disclosure of gifts or services received from customers, suppliers, competitors, business partners or shareholders.

Hilltop does not encourage our customers, suppliers, competitors, business partners, shareholders or another employee to offer gifts and advantages to our employees. Based on the Code of Conduct of Hilltop, our employee may decline to our customer, supplier, competitor, business partner, or other employee the receipt of gifts and advantages should a conflict of interest exists. Hilltop hope the decline or a return of gifts and advantages will not offend our customers, suppliers, competitors, business partners or shareholders.

Employees should attempt to avoid conflicts of interest and employees who believe a conflict of interest may exist should promptly notify the Internal Control Department. The Internal Control Department will consider the facts and circumstances of the situation to decide whether corrective or mitigating action is appropriate.

Last updated: June 2021