CODE OF CONDUCT

In addition to this Code, all employees are required to read, be familiar, and comply with the Group-wide ENVEA Code of Ethics, which defines our core principles for doing business and to operate in an ethical way.

At a minimum, all ENVEA personnel are expected to:

• Act in a manner that is safe, ethical and consistent with our values and applicable laws and regulations.
• Ask questions if you are unsure of your responsibilities or the correct course of action to take.
• Are encouraged to report any concerns or possible breaches of the Code.
• Cooperate fully in any internal or external investigation, if requested to do so.
• Attend training as required by your job function

Employees who are responsible for the management of others are required to act as positive role models and support team members and application of the Code by:

• Ensuring they receive new employee induction training.
• Creating an environment that is respectful and inclusive.
• Encouraging team members to speak up and listen and respond to concerns when they are raised.
• Ensure that no one experiences retaliation for speaking up or co-operating in an investigation in good faith.
• Supervising staff and monitoring business activities.
• Appropriately reporting and investigating any potential breaches of the Code.

Questions on the Code should be referred to your manager, Human Resources (or equivalent in your Business Unit), or Member of the CSR Team or a member of the Executive Board.

Failure to comply with the Code may lead to disciplinary action up to and including dismissal or termination of contracts in the case of contract staff or business partners. ENVEA will cooperate fully with law enforcement or regulators if required.

1. People and Safety

   ENVEA has a policy of do no harm, to our people, the environment and the communities where we operate. Our activities are managed to protect the health, safety and security of everyone involved in our activities.

   We strive to treat everyone with fairness, respect and dignity and we have zero tolerance for any form of discrimination, abuse, violence, bullying or harassment. Decisions related to recruitment, development and promotion are based upon aptitude and ability only. Decisions must not be influenced by factors such as age, gender, sexual orientation, marital status, race, color, ethnic origin, religion, or belief, disability or political views.

   ENVEA respects the privacy of its staff and will only take an interest in what employees do outside of work if it affects the Group’s reputation or legitimate business interests. We only use personal information to the extent needed for Human Resources (or equivalent in your Business Unit) purposes and in any event in compliance with applicable laws.

2. Business Integrity & Legal Compliance

   ENVEA is committed to complying with all applicable local, regional, national and international legal requirements including the Sapin II law, the UK Bribery Act (2010), the US Foreign Corrupt Practices Act (FCPA), and any other applicable laws.
   Where differences exist between the standard of the law or regulations and requirements of the Code, the most restricted standard shall be applied. Where laws conflict or you are unsure of the correct action to take, you must consult with Member of the CSR Team or other member of the executive team. All staff should be familiar with the contents of the Anti-Corruption Policy and aware that you may be liable to appropriate and proportionate disciplinary action, dismissal, legal proceedings and possible imprisonment if you are involved in bribery and corruption.

   1. Anti-Corruption, Government Officials, and Gifts & Hospitality

   We do not tolerate bribery, corruption and influence peddling in any form within our business. Bribery occurs when you, directly or indirectly, offer, pay, seek or accept a gift or favour to influence a business outcome improperly. To mitigate risk, Group Personnel must comply with the Anti-Corruption Policy

3. Avoiding Conflicts of Interest

   ENVEA expects its staff to avoid situations that could lead to conflicts between an individual’s interests and those of ENVEA.

   Any employee who considers that he or she may be in a situation with a potential conflict of interest should inform his or her line manager (unless that manager is also involved in the conflict of interest, in which case it should be reported to a more senior manager). Conflicts of interest should be appropriately recorded.

   1. Competition and Anti-Trust
      ENVEA operates fairly and honestly and only acquires information about our competitors by legal and ethical means. Our staff and representatives must not engage in any form of agreement or understanding with competitors to fix prices, rig bids, allocate customers and/or restrict supply. If your role involves dealings with competitors, you must ensure that you are fully briefed on the implications of the competition law.
   2. Donations and Contributions
      In general, ENVEA does not make political donations, but from time to time, may make charitable or social contributions. Any such contribution by ENVEA or on the Group’s behalf must be pre-approved in writing by Member of the CSR Team or another member of the executive team and made in a manner consistent with the Anti-Corruption Policy.
   3. Business Partners
      Our suppliers and business partners are essential to our ability to do business. We expect them all to share our commitments to safety, ethics and compliance. Staff members responsible for hiring or engaging third party business partners must be familiar with and comply with the ENVEA Third Party Due Diligence Policy. Staff members who are directly responsible for the management of contracts with third parties or regularly engage with business partners must ensure the Code and other relevant standards are communicated, appropriate due diligence is completed, third parties are actively monitored, and any indications of noncompliance are reported.

4. Environmental Commitment

   ENVEA promotes environmental stewardship and human well-being in all aspects of its operations. All staff have a general duty to preserve and protect the environment, and to proactively demonstrate a commitment to environmental stewardship and sustainable development. We strive to improve our environmental performance, develop environmental objectives to minimize environmental impacts, and comply with all environmental, health, and safety laws, regulations, and other requirements. ENVEA aims to equip all personnel with the knowledge and tools needed to meet the goals of this policy and to actively participate in efforts to prevent negative environmental impacts.

5. Safeguarding Information and Assets

   Intellectual, physical and financial corporate assets are valuable and must be managed properly and protected appropriately. All books, records and accounts must reflect all transactions in connection with our business accurately. Information relating to ENVEA’s operations must be kept secure, using systems established for that purpose. Information should only be disclosed or exchanged with authorized persons or entities, subject to the requirements of legislation.

   Personal data and intellectual property must be safeguarded and communications facilities must be used responsibly. Personal data is subject to legal safeguards specified in applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Staff should take care of equipment provided to them and should also keep safe passwords and any other electronic security measures. ENVEA reserves the right to monitor the use of electronic communications and to take action in the event of misuse.

   You may not divulge or discuss confidential information or other information relating to the ENVEA’s operations which could lead to a violation of confidentiality agreements or contractual obligations. Only authorized Group spokespersons are permitted to make any public communication regarding ENVEA or its business to the media or analysts. If you are approached or contacted with a request for information, then you should refer it to Member of the CSR Team or other member of the executive team.

6. Compliance Procedures and Training

   All Group Personnel shall receive and review a copy of the Code of Conduct. ENVEA will provide periodic training programs or modules to educate Group Personnel about the requirements and obligations of the Code of Conduct and other Group policies. Group Personnel must participate in this training when required and the Designated Officer will retain attendance and/or completion records establishing compliance with this requirement.

7. Manager’s Responsibilities

   Every manager has a responsibility to ensure compliance with the Code of Conduct and other Group standards and procedures and to report potential violations of the Code and results of subsequent investigations to the Designated Officer and the Executive Board. External, independent reviews will be carried out to periodically provide additional assurance.

   Additionally, Group Personnel must report misconduct or suspicion of misconduct. Guidance on reporting misconduct is provided in the ENVEA Speak Up Policy.

8. Dealing with Violations of the Code

   In the event that violations of this Code are suspected and/or proven, action will be taken. If there is reason to suspect non-compliance, then an investigation will be undertaken to determine if a violation has occurred. In the event that a violation has occurred, action will be taken to address any resultant harm, fulfil any obligations to report to regulatory agencies and to identify the root cause and implement measures to prevent further violations.

   Please bear in mind that some violations may be criminal in nature and punishable by fine or imprisonment. Violations can jeopardize our relationships with our customers and suppliers, and could result in loss of the privilege to do business in the countries where we operate. If you authorize, direct, cover-up or in any way participate in any such violations, you will be subject to appropriate and proportionate disciplinary action, which may include dismissal or termination, reimbursement to ENVEA for any losses or damages resulting from the violation, and civil and/or criminal liability. Furthermore, ENVEA may, as appropriate, implement system-wide changes and/or notify the relevant governmental office or agency.