This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of HDT (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal or regulatory authorities. HDT intends to review doing business with others who do not commit to the same standard of zero-tolerance of corruption, including joint ventures partners and distributors.