VENDOR CODE OF CONDUCT

Through its Standard of Business Conduct (https://srm.in.startv.com/), STAR has established company standards that include ethical business practices and regulatory compliance. These standards apply to all STAR employees, directors, and officers. We also expect everyone working on our behalf, including consultants, agents, suppliers and business partners, to adhere to its ethical standards. As such, STAR expects its vendors to embrace this commitment to integrity by complying with and training its employees on the STAR Vendor Code of Conduct.

COMPLIANCE WITH THE VENDOR CODE OF CONDUCT

Vendors and their employees, agents and subcontractors (collectively referred to as "Vendors") must conduct their business interactions and activities with integrity and in compliance with the applicable laws and regulations of their respective countries. The Vendors must adhere to this Vendor Code of Conduct while conducting business with or on behalf of STAR.

Vendors must promptly inform their STAR contact (or a member of STAR management) when any situation develops that causes the Vendor to operate in violation of this Code of Conduct.

While STAR Vendors are expected to self-monitor and demonstrate their compliance with this Code of Conduct, STAR may require the immediate removal of any Vendor representative(s) or personnel who behave in a manner that is unlawful or inconsistent with this Code of Conduct or any STAR policy. Compliance with this Code of Conduct, and attending training on this Code of Conduct, as may be offered by STAR, is required in addition to any other obligations in any agreement a Vendor may have with STAR.

A. LEGAL AND REGULATORY COMPLIANCE PRACTICES

All STAR Vendors must conduct their business activities in full compliance with the applicable laws and regulations while conducting business with and/or on behalf of STAR.

B. BUSINESS PRACTICES AND ETHICS

STAR Vendors must conduct their business interactions and activities with integrity and must, without limitation: .

Business Records: Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy. Create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements. Be honest, direct, and truthful in discussions with regulatory agency representatives and government officials.

Press: Speak to the press on behalf of STAR only if the Vendor is expressly authorized in writing to do so by STAR

Gifts and hospitality: Avoid gifts to STAR employees because even a well-intentioned gift might constitute a bribe under certain circumstances, or create conflicts of interest. Do not offer anything of value to obtain or retain a benefit or advantage for the giver, and do not offer anything that might appear to influence, compromise judgment, or obligate the STAR employee. If offering a gift, meal, or entertainment to STAR employees, always use good judgment, discretion, and moderation. Any gift from a Vendor must be permissible under the STAR Corporate Governance Policies. Any gifts, meals, or entertainment must comply with applicable law, must not violate the giver's and/or recipient's policies on the matter, and must be consistent with local custom and practice.

Conflicts of Interest - personal dealing and related parties: Avoid the appearance of or actual improprieties or conflicts of interests. Vendors or representatives should not deal directly during negotiation or otherwise with any STAR employee whose spouse or other family member or some other close relation is an employee or has a personal or financial interest in the vendor or the vendor's business.

Work environment - Share STAR's commitment to human rights and equal opportunity in the workplace. All STAR Vendors must conduct their employment practices in full compliance with all applicable laws and regulations, and must, without limitation co-operate with STAR's commitment to a workforce and workplace free of harassment and unlawful discrimination.

REPORTING QUESTIONABLE BEHAVIOR

If you wish to report questionable behavior or a possible violation of the Vendor Code of Conduct, you are encouraged to work with your primary STAR contact in resolving your concern. If that is not possible or appropriate, please contact STAR through any of the following methods:

Email: lcgc@startv.com