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Code of Business Conduct

Effective date: 26 February 2025

Introduction
The ENNOVI Group Code of Business Conduct (“Code”) plays an important role in how we put our values into practice. It is founded upon our belief that, as an organization, we are most successful when we show values of integrity, transparency, and ethical conduct in our workplace, with our business partners, and in our community. 

As a global leader in our industry, we hold all our employees to high standards of ethics and integrity. Our continued success requires our commitment and discipline in ensuring that those high standards are embraced in all that we do, both in the workplace and in our community. 

This Code outlines our values and expectations for all our employees, including our directors and officers (“Company Personnel”). This Code is here to guide you on the standards of business conduct required for your work at ENNOVI. This Code also informs you about the resources available if you need support, have a question, or wish to make a report regarding unethical conduct within our organization. We expect all Company Personnel to carefully read and understand this Code.
This Code applies to all Company Personnel.
We are committed to acting with integrity—it is the right thing to do, protects our organization, and allows us to fulfill our obligations to our stakeholders. We believe that how we achieve our success is equally as important as the success itself.
Managers must promptly address any concerns brought to their attention and report them in accordance with our Whistleblowing Policy. If a manager neglects or fails to address an issue escalated by an employee, they may be subject to disciplinary action. If necessary, you can contact the Legal Department for assistance.
Company Personnel who violate or fail to comply with this Code or any matters addressed in this Code may face disciplinary action, including and up to termination of employment. 
We do not tolerate retaliation, harassment, or victimization against anyone who raises a concern in good faith about a violation of this Code or assists with an investigation. Any Company Personnel found to have committed any such act of retaliation, harassment, or victimization, shall be subject to disciplinary action, including and up to termination of employment. 

Our Code is Organized into Four Sections:

I. Our Business 

II. Our People 

III. Our Assets 

IV. Our Community 

I. OUR BUSINESS 
We are committed to complying with all laws and regulations, whether local, national, regional, or international, that apply to our organization. Violation of these laws can result in significant harm to our organization, including financial penalties, criminal proceedings, and damage to our business relationships and reputation. Therefore, we must be familiar with and follow the applicable laws and our organization’s policies.
Anti-Bribery and Anti-Corruption Laws
Corruption, which encompasses giving, receiving, promising, or asking for anything of value with intent to influence an act or decision, obtain or retain business, or gain an improper business advantage, is strictly prohibited. This prohibition applies to our interactions with counterparties, including private individuals, public officials, private and public companies, and other organizations.

We require compliance with all anti-bribery and anti-corruption laws that apply in all countries where we operate. Violating these laws can have severe consequences for you and our organization. If the only way to obtain the business is through corrupt means, we must choose to walk away from the deal.

Red Flags for Bribery and Corruption

Watch out for bribery and corruption red flags, for example:
  • Unusual financial transactions, such as overinflated invoices, expense claims that are poorly defined or unsupported by proper receipts or documentation, requests for payments through third-party/shell companies unrelated to the transaction, or failure to adhere to accepted international accounting standards, etc.
  • Payments to unqualified vendors or requests by a counterparty for any special commission, incentive, rebate, or bonus for work or services that are not performed by such counterparty.
  • Counterparty’s lack of transparency, such as avoidance of due diligence audits, or refusal to provide references, etc.
  • Payments to parties in countries known to be at high risk of corruption (e.g., the country ranks poorly on the global corruption index).
  • Dealings with parties with poor business reputation or adverse media, such as investigations or past convictions for tax fraud or financial crimes, etc.
  • Dealings with politically exposed persons, such as requests for gifts/hospitality by public officials, requests for improper payment or facilitation payments to public officials, or influence of public officials in selection of business partner, etc.

Any suspicious conduct which might amount to a breach of anti-bribery and anti-corruption laws must be reported to the Legal Department immediately.

We have established an Anti-Bribery and Anti-Corruption Policy to underscore our commitment to combating bribery and corruption. You can access this policy via the ENNOVI Intranet.

Money laundering is the process by which the origin of money gained through illegal activities, such as terrorism, fraud, or bribery, is disguised, making it appear to come from legitimate sources. This typically involves a series of transactions designed to obscure the true source of the funds.

You must remain vigilant and be aware of potential red flags and avoid any involvement in activities that raise suspicions of money laundering.

Red Flags for Money Laundering

Watch out for money laundering red flags, for example:
  • Receipt of unusually large cash payments without legitimate business purpose.
  • Payments received from bank accounts that do not match the customer’s name or location.
  • Payments to offshore accounts or unverified beneficiaries.
  • Requests for cash payments instead of bank transfers, or transactions involving virtual assets (e.g., cryptocurrency), especially where ownership of the virtual assets cannot be easily traced to the customer.
  • Over-invoicing, under-invoicing, sending multiple invoice requests, or requesting to structure invoicing in an unusual manner.
  • Counterparty avoids standard due diligence checks on ultimate beneficial ownership and source of funds.
If you detect any red flags, please report them to the Legal Department immediately.

Our organization is committed to maintaining business relationships with reputable customers, suppliers, and other parties whose business activities and financial resources are legitimate.
Antitrust and competition laws play an important role in fostering and promoting free and fair competition among businesses, preventing abusive behavior in the market, and protecting consumer interests. These laws generally prohibit:
  • arrangements with competitors that restrict trade in some way, for example, price fixing, bid rigging, and predatory pricing;
  • abuse of intellectual property rights; and
  • use of market power to unfairly disadvantage competitors.
We must follow all antitrust and competition laws, because the violation of these laws can expose our organization and employees to criminal penalties, large fines, and civil lawsuits. We must exercise caution when interacting with competitors, conducting benchmarking activities, or having information exchanges or collaborations with competitors in conferences or trade shows. When you are attending any meeting or event, if you suspect that any anti-competitive conduct is taking place, promptly disengage and make your exit, and report the incident to the Legal Department immediately.

Red Flags for Antitrust and Anti-competitive Conduct

Watch out for red flags relating to antitrust and anti-competitive conduct, for example:
  • Sharing and exchanging sensitive business information with competitors (e.g., pricing and cost-related information, or new product developments that have not been made public etc) at trade association events or other formal/informal settings.
  • Engaging in exclusive dealing practices (e.g., signing exclusive supply agreements or exclusive purchasing agreements, etc).
  • Counterparty is negotiating for excessive non-compete or restraint of trade obligations.
  • Attempting to limit market access for competitors (e.g., through collusive/predatory pricing).
  • Sharing bid submission information with competitors or other forms of collusion for bid rigging.
If you detect any red flags, please report them to the Legal Department immediately.

We have established an Antitrust and Competition Law Compliance Policy which provides more detailed guidance. You can access this policy via the ENNOVI Intranet.
The protection of natural persons in relation to the processing of personal data is regarded as a fundamental right. The protection of personal data is vital for safeguarding individuals’ privacy, ensuring compliance with relevant laws, and maintaining trust with our stakeholders. Many countries have laws governing the collection, storage, and use of personal data. In those instances where we are entrusted with the personal data of our employees and business partners, we have an obligation to use, process, and retain personal data only to the extent permitted by the applicable laws and regulations and in accordance with our organization’s policies.

We must be alert to any conduct which could compromise data protection and privacy. We should also be cautious of any unauthorized attempts to access or use personal data by parties within or outside our organization.

Red Flags for Data Protection and Privacy

Watch out for red flags in data protection and privacy, for example:
  • Storing personal data on data servers or removable storage devices (e.g., external hard disk drives) which are not encrypted/secured and unauthorized by IT Security.
  • Transferring sensitive personal data without proper consent and failing to implement adequate encryption or security measures.
  • Employee wrongfully accessing, copying or disclosing personal data of other employees or business partners (e.g., unauthorized attempts to bypass security protocols).
  • Counterparty lacks a comprehensive data protection and privacy policy and has not appointed any data protection officer when required by law.
  • Vendor refuses to accept standard data protection and privacy obligations when processing personal data or disclaims all liability for any data breach under its service contract.
If you detect any data breach or improper handling of personal data, report such incidents to the Legal Department immediately.

We have established a Global Data Protection Policy which provides more detailed guidance on the proper handling of personal data and the reporting procedure in case of any data breach. You can access this policy via the ENNOVI Intranet.
We have a duty to ensure that all our business records (including financial statements, expense reports, invoices, corporate filings, transaction documents, and any other documentation relevant to our business) are accurate, fair and complete. Our business records must represent the true nature of our organization’s business and financial position and enable fair and accurate financial reporting.

All acts of altering or falsifying any information in our business records and providing misleading or fraudulent statements in our business records are strictly prohibited.

If you want to know more about our organization’s Financial Policy and its related procedures and guidelines, please consult the Finance Department.
Trade compliance is the process of ensuring that our international trade activities, including the export and import of goods, services, and technology, adhere to the applicable trade compliance laws and regulations, including those which apply extraterritorially. The following are some of the key trade compliance laws that apply to our business activities:
  • Sanctions are restrictive measures designed to influence the behavior of certain countries, regions, organizations, or individuals by restricting their economic activities and imposing other prohibitions (e.g., embargoes, trade restrictions, travel bans, or asset freezes, etc).
  • Export controls are laws, regulations, and policies restricting the movement of goods, technology, or software to certain parties, end uses, and destinations. These laws and regulations safeguard national security by preventing the development and proliferation of weapons of mass destruction, protecting sensitive technologies, and advancing national security policies.
  • Import regulations are regulations that govern the entry of goods into a country and ensure compliance with local laws and regulations.
We must be proactive in ensuring that any transactions with our business partners do not violate applicable trade compliance laws, including but not limited to the unauthorized export or import of goods, services, or technology to or from embargoed countries or sanctioned/restricted parties.

Red Flags for Trade Compliance

Watch out for red flags in trade compliance, for example:
  • Vendor avoids due diligence audits or is unable to provide any Certificate of Origin or Conflict Minerals Reporting Template (CMRT) declaration.
  • Requests to provide misleading or incomplete information in customs declarations.
  • Counterparty’s parent company, subsidiaries, or affiliates are sanctioned/restricted parties with risk of transaction being used to circumvent trade sanctions and/or export control restrictions.
  • Customer refuses to give any contractual undertaking or end-use declaration to disclaim use of the supplied goods for any restricted purpose (e.g., military end use, or development of biological or chemical weapons, etc).
  • Customer sells to an end customer which is a sanctioned/restricted party to circumvent trade sanctions and/or export control restrictions.
If you spot any red flags or suspect any violation of trade compliance laws, please report them to the Legal Department immediately.

We have established a Global Trade Compliance Policy to provide more comprehensive guidance on the trade compliance rules that apply to our organization and the actions required to stay compliant. You can access this policy via the ENNOVI Intranet.
ENNOVI is committed to respecting and advancing human rights. We strive to uphold the fundamental human rights of all people, not only through our own business activities but throughout our supply chain.

As a global enterprise with employees from all over the world, we value and celebrate the rich and diverse culture they bring to our organization. We believe in a company culture that promotes fairness, equal opportunity, and mutual respect.

You can access ENNOVI’s human rights policies via the ENNOVI Human Resources platform, including the Global Human Rights Policy which establishes our overarching commitment to respect and uphold fundamental human rights.
Non-Discrimination and Preventing Harassment
We strive to provide equal opportunities for our employees and job applicants. Our employment decisions are based on business needs, skills and qualifications, and the person’s ability to perform the job effectively. We uphold a dignified work environment and respect for all our employees. Harassment or discrimination of any kind is strictly prohibited and will not be tolerated.

To ensure our employees feel safe, we have established a mechanism to report incidents of harassment or discrimination. If you experience or witness any harassment or other behavior that violates our non-discrimination practices, we urge you to escalate the matter using our whistleblowing reporting channels.
Your safety and well-being and that of our visitors are of utmost importance to us. We are committed to providing a safe and healthy work environment across all our offices and manufacturing facilities. We require all Company Personnel and visitors to adhere to our organization’s workplace policies and procedures and to always put health and safety first.

A safe and healthy work environment adds to our competitive advantage. It supports employee well-being by enhancing physical and mental health, and increasing engagement, productivity, and job satisfaction. Additionally, implementing thorough health and safety measures reduces the incidence of accidents and injuries, and safeguards employees while minimizing costs linked to absenteeism and medical expenses, thereby benefiting you and our organization.

If you observe any unsafe conditions or unsafe behaviors or suspect any violation of our workplace policies and procedures, you must promptly report them to your local management team or through our whistleblowing reporting channels.
We expect you to act in the best interest of our organization and avoid situations where your personal interest may conflict with the organization’s interests. Conflict of interest occurs when your personal, social, financial, or other activities or relationships interfere with your objectivity or loyalty to our organization.

You are required to tell your manager about any situation that presents the possibility of a conflict of interest.

Red Flags for Conflict of Interest

Watch out for red flags in conflict of interest, for example:
  • Employee has a financial interest (e.g., shareholder) in a vendor or customer.
  • Employee is a board member of a public listed corporation that is unaffiliated with ENNOVI.
  • Employee’s relative works for ENNOVI’s competitor or at the procurement/purchasing department of a customer.
  • If ENNOVI employs a relative of an employee and the new employee may be in a supervisory or subordinate job relationship with such employee.
  • Employee is offered a lavish gift or hospitality from a business partner (e.g., gift value exceeds the monetary limits under our Gifts and Hospitality Policy).
  • Employee engages in a personal relationship with a business partner’s representative which may influence his/her ability to make business decisions.
Undisclosed conflicts are prohibited and may result in disciplinary action. After the conflict of interest is disclosed through the reporting channel, we will assess the nature and extent of the conflict and may implement measures to mitigate or resolve the conflict, such as recusal from specific decisions, reassignment of responsibilities, or other appropriate measures.

We have established a Conflict of Interest Policy to provide more guidance on this topic. You can access this policy via the ENNOVI Intranet.
Use of Company Assets
We provide you with assets and resources to perform your job. These may include but are not limited to mobile phones, laptops, information systems, and software. You are responsible for taking care of these resources and using them for business purposes only and according to the scope of authority granted to you.

It is essential to use company assets in a manner consistent with the information security and confidentiality policies set by our organization. Protecting information that is of a confidential, proprietary or commercially sensitive nature is of utmost importance. Please be aware that our organization reserves the right to monitor the use of its assets, especially information systems, to ensure compliance with our information security policies.

We have established an IT Acceptable Use Policy and other Information Security Policies to provide more guidance on access controls, information processing, and how to protect information assets. You can access these policies via the ENNOVI Intranet.
Our organization’s intellectual property and confidential information, as well as third-party confidential information provided to us in the course of our business relationships, are vital assets and must always be protected.

Intellectual property includes our copyrights, patents, trademarks, brand names and logos, research and development, ideas, inventions, and trade secrets.

Confidential information includes any information, regardless of form, relating to our organization’s business, including but not limited to commercial, operational, technical, financial, and proprietary information, trade secrets, and know-how; confidential information received from third parties; and other company information not generally known to the public, where its improper disclosure may put our organization at a competitive disadvantage or benefit our competitors. Examples include internal organization charts, product plans, customer lists, pricing proposals, marketing strategies, research and development data, unpatented inventions, business processes, and technology, etc.

You must not use our organization’s intellectual property and confidential information for your personal gain or any unauthorized or non-business purposes. You must also maintain the confidentiality of the information you are privy to, whether it belongs to our organization, business partners, or third parties, except when disclosure is expressly authorized by our Legal Department or by law.

We have established a Policy on Regulation of Confidential Information to provide more information on how to protect and handle confidential information. You can access this policy via the ENNOVI Intranet.
We abide by the laws and regulations that apply to our business in everything we do. We are mindful of how we conduct ourselves and its impact on our work environment and surrounding community.
Environmental Protection
Prioritizing environmental protection yields various benefits for our organization and our Company Personnel.

We respect the environment and diligently follow all environmental laws and regulations that apply wherever we conduct business. Beyond that, we strive to continuously improve our environmental impact through our organization’s business practices to support long-term viability and sustainability.

Fostering a positive sense of environmental commitment builds a strong corporate image founded on social responsibility and helps to attract eco-conscious individuals to join us as employees, customers, and business partners. Moreover, promoting resource conservation demonstrates fiscal and environmental responsibility and helps to mitigate the impact of climate change on our communities, enhancing our organization’s success and engaging like-minded stakeholders.

We have established an Environmental Policy which provides details about our environmental protection initiatives. You can access this policy via the ENNOVI Intranet.
Contributing in a positive way to community growth and development is important to us. We consider it our social responsibility and part of our overall business strategy.

Our employees engage in local programs to help empower their communities through volunteer work and donations. We consider it a core value to participate in community initiatives and help those in need.
Our organization’s success relies heavily on our relationships with our trusted suppliers. We believe in conducting fair and transparent procurement by carefully selecting suppliers based on the products and services that meet our needs. When making our decisions, we consider various factors such as reliability, ethical business practices, price, delivery, and quality.

We hold our suppliers to a high standard of ethical conduct and expect them to comply with all applicable laws and regulations, including anti-bribery and anti-corruption, labor and employment, and human rights laws. We will not tolerate any unethical practices, and any supplier found to engage in such behavior will be reviewed and may face termination of their business relationship with us.

As an organization committed to long-term sustainability and environmental stewardship, we prioritize suppliers who share our vision and dedication. We encourage our suppliers to adopt eco-friendly practices, reduce their environmental footprint, and comply with environmental regulations. Together, we can create a brighter, greener future for all.

For more information, refer to our Supplier Code of Conduct and Sustainable Procurement Policy. You can access these policies via the ENNOVI Intranet.
We are politically neutral and do not make political contributions to anyone or any organization anywhere we operate. You are free to support people and causes of your choice with your own time and resources.

However, you may not make political contributions on behalf of our organization or give the impression that our organization is politically affiliated. Reach out to the Legal Department if there is any doubt or suspicion that such acts have been committed.

Any Questions?

If you have questions regarding anything in this Code or want to report a concern, please speak with your line manager or local Human Resources representative. If that is not an option, you may contact any of the following representatives:
  • Members of the Board of Directors
  • Senior Leadership and Managers
  • Human Resources Department for concerns regarding employment, benefits, and workplace issues
  • Legal Department for interpretation of this Code, advice on how to conduct business in a compliant manner, and reporting concerns: corp.compliance@ennovi.com
  • Finance Department for advice on financial and accounting matters, and company controls
  • IT Security Department for concerns regarding cybersecurity incidents or other issues relating to information security: it.security@ennovi.com
  • Quality Department for concerns regarding quality, safety, and regulatory compliance of our products
  • Procurement Department for concerns regarding supplier management and sustainable procurement
  • Corporate Sustainability and ESG Department for concerns relating to environment, workplace security, safety and health: sustainability@ennovi.com

You may also report a concern through our EthicsPoint whistleblowing hotline or web intake site at https://ennovi.ethicspoint.com.

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