CODE OF ETHICS

I. Introduction

The ENVEA (“ENVEA” or the “Group”) Code of Ethics (“Code”) defines our core principles for doing business and managing our operations in an ethical way that supports our values, commitment to business integrity and compliance with legal requirements.

The Code applies and binds to the Board of Directors and all ENVEA employees, including contract, agency, and temporary workers. We will take all reasonable steps to ensure all business partners, including joint venture partners, suppliers, agents and advisors act in a manner that is consistent with the spirit of this Code in their dealings with and on behalf of ENVEA.

II. Core Principles

All employees are required to read, be familiar, and comply with the following principles:

Act with Honesty and Integrity

All employees and ENVEA representatives are expected to be honest and transparent in all professional and business relationships. ENVEA employees are under no circumstances to knowingly be associated with providing misleading information.
Always Be Objective

ENVEA does not compromise professional and business judgement because of bias, conflicts of interest and/or undue influence of others. When undertaking a mutual engagement, employees shall be and appear to be independent.
Practice Professionalism

ENVEA employees must attain and maintain professional knowledge and skills at the level required to ensure that a client or employing organisation receives competent professional service, based on current technical and professional standards and relevant legislation. All employees are to act diligently and with due care and respect.
Exhibit Care in all Interactions

ENVEA’s value of “do no harm” is to be followed by all employees, who also have an obligation to promote environmental stewardship across the business, including but not limited to the promotion of sustainable development. ENVEA does not tolerate any form of discrimination or harassment whatsoever in any of its entities. Any suspicion of such behaviour will be subject to investigation and disciplinary action in accordance with local regulations.
Maintain Confidentiality

ENVEA employees are to respect the confidentiality of information acquired as a result of professional and business relationships. Confidential information must not be disclosed outside the organisation without approval, unless there is a duty or right to disclose, or disclosure is in the public interest and permitted by law.
Comply with all Laws

ENVEA employees are to comply with relevant laws and regulations and avoid any conduct that the employees know or should know might discredit the profession and/or ENVEA. Any unprofessional behaviour will be subject to disciplinary action.

III. Compliance with ENVEA Policies

To ensure compliance with the above responsibilities, ENVEA has adopted policies, procedures, and training to provide further guidance to all employees, and all employees should be familiar, and comply with the following:

Code of Conduct – This Code of Ethics is supported by a Code of Conduct for each business unit, and which contains further guidance on Company policies and procedures.
Anti-Corruption Policy – ENVEA will not tolerate bribery, kickbacks, or corruption of any kind, directly or through third parties, whether explicitly prohibited by this Policy or by law. In addition, ENVEA will offer anti-corruption training to employees about the obligations of anti-corruption laws and the Anti-Corruption Policy. Employees will be identified based on risk to participate in such training.
Third Party Due Diligence Policy – ENVEA employees must be aware of and comply with the ENVEA Third Party Diligence Policy.
Recordkeeping Controls – All expenditures made by ENVEA must be accurately reflected in ENVEA’s financial records and all payments made with ENVEA funds, and/or on behalf of ENVEA, must be properly authorized.

IV. Compliance Procedures and Training

All Group Personnel shall receive and review a copy of the Code of Ethics. ENVEA will provide periodic training programs or modules to educate Group Personnel about the requirements and obligations of the Code of Ethics and other Group policies. Group Personnel must participate in training when required and the Designated Officer^[1] will retain attendance and/or completion records establishing compliance with this requirement.

^[1] A complete list of Designated Officers and corresponding responsibilities is included in Appendix A of the Envea Code of Conduct.