Code of Conduct Eventure

1. Introduction
2. Purpose
3. Scope of Application
4. Our Principles, Values and Responsibilities
5. Compliance with Legislation
6. Conflict of Interest
7. Corruption, Bribery, Fraud
8. Relationships with Partners, Suppliers, Subcontractors, Clients
9. Relationships with Colleagues and Employees
10. Employee Competencies, Evaluation and Equal Opportunities
11. Confidentiality and Data Protection
12. Protection of Company Assets
13. Environmental Protection – Environmental Policy
14. Health and Safety in the Workplace
15. Fair Competition
16. Adherence and Compliance with the Code
17. Breach of the Code
18. Ethics and Regulatory Compliance Program
19. Validity of the Code

The Company’s Code of Conduct defines the framework within which it operates. Its aim is to promote a corporate culture that encourages behavior based on the highest standards of business ethics and conduct, in accordance with applicable legislation and the ten universally accepted principles of the United Nations Global Compact, in the areas of human rights, labor standards, environmental protection, and anti-corruption

(www.unglobalcompact.org/what-is-gc/mission/principles).

This Code includes the fundamental principles, rules, and values that shape the framework of our activities and guide our daily conduct and practices. It outlines the behavior we expect from our employees, as well as how we conduct business with our clients, suppliers, and partners.

EVENTURE operates in compliance with the applicable legal and regulatory frameworks, as well as internal policies. Nevertheless, since we recognize that legislation cannot anticipate every business scenario, it is important for all clients, suppliers, and team members to fully understand what we stand for and how we operate. The combination of this Code of Conduct with the Company’s Principles and Values forms the foundation for building trust, which plays a key role in our sustainable business success.

The purpose of establishing the Code of Conduct is to further promote ethical integrity, honesty, transparency, and proper professional behavior across all levels of the Company’s hierarchy.
We respect and adhere to the Code of Conduct in all our collaborations with stakeholders, as well as the laws and regulatory frameworks of the countries in which we operate, along with international standards and initiatives.

This Code serves as a guide to help us make decisions in situations where ethical dilemmas may arise regarding appropriate behavior and handling of matters related to business ethics. Additionally, it aims to ensure compliance with the business ethics and conduct principles adopted by the Company in its relationships with and by all partners (e.g., clients, suppliers, external associates).

We are all obliged to read and understand the Code of Conduct and must be aware that:

- The Code does not cover every possible scenario or provide full analysis of every issue. In situations where the appropriate course of action is unclear, we must seek guidance from our supervisor.
- Some of the issues addressed in this Code are explored in more detail in separate Company policies or internal procedures.
- This Code may not necessarily include all legal and regulatory provisions that may apply to a particular jurisdiction. In cases of conflicting or overlapping provisions, the applicable legal and regulatory framework of the specific jurisdiction shall prevail.
- The Code is communicated to all employees upon hiring. Additionally, it is posted on the notice boards at both the Company’s headquarters and its branches, as well as on the Company’s website, so that it is readily available to all employees and external partners.

Compliance with the Code of Conduct is a personal commitment we make as employees, and a promise we extend to everyone outside the Company.

The Code of Conduct, along with the procedures and measures related to it, applies to all employees, staff, executives, and senior management of EVENTURE. We also encourage our suppliers, partners, consultants, and other professional collaborators to respect the principles of the United Nations Global Compact and to adopt the principles set out in our Company’s Code of Conduct.

Adhering to the values, principles, and rules of this Code is a collective responsibility shared by all EVENTURE personnel to ensure that employees, subcontractors, suppliers, and partners embrace the Company’s core values. This includes part-time employees, representatives, and associates.

The Code of Conduct sets out guiding principles. It is essential that each of us has a clear understanding of what constitutes proper ethical business conduct, as well as the consequences of non-compliance.

We respect the laws and regulatory framework of each country, along with international commitments and corporate responsibility initiatives, and we act with a high sense of accountability and ethics. We acknowledge our duty to operate safely and to protect the environment. We invest in and actively contribute to improving the quality of life for all, both inside and outside the Company.

Honesty, integrity, meritocracy, responsibility, confidentiality, equality, objectivity, creativity, fair professional practices, team spirit, and respect for society and the environment are the fundamental values and principles by which the Company operates and responds to daily challenges. Specifically:

- We are committed to the appropriate use and protection of information related to our Company, clients, partners, investors, and employees.
- We promote transparency and open communication about the services we provide, based on our expertise and many years of experience.
- We treat our people objectively, avoiding bias, conflicts of interest, or any influence on professional judgment by third parties.
- We act with honesty and integrity in all professional and business relationships, protecting the interests of the Company over personal gain.
- We do not engage in unfair competition and we respect our competitors.- We recognize our environmental responsibility and act in ways that reduce the impact of our operations on the environment.

In addition to upholding our values and principles, we are responsible for:

- Respecting the rights of our employees, compensating them fairly and competitively, and encouraging them to participate in the design and control of their work.
- Pursuing mutually beneficial relationships with our partners and suppliers.
- Offering high-quality services to our clients.
- Conducting our business activities in compliance with the law and our role as members of society, promoting sustainable development and respecting Health, Safety & Environmental Protection regulations.

Management bears enhanced responsibilities for ensuring adherence to this Code and specifically must:

- Foster an environment of honesty and transparency where employees feel comfortable raising concerns.
- Demonstrate ethical behavior and act in accordance with the principles of business ethics.
- Ensure ongoing training and development of employees on ethical matters.
- Respond promptly to concerns or violations raised by employees and provide guidance when requested.
- Receive and respond to questions from employees regarding the principles of the Code of Conduct.
- Continuously improve and strengthen the Company’s anti-corruption efforts.

Compliance with laws and regulations is a fundamental principle for the Company.

We are all required to respect and adhere to the law in the performance of our duties. Management, employees, and individuals acting on behalf of the Company are expected to comply with the applicable legal framework and regulations, and to observe any imposed restrictions. Each person is personally responsible for complying with the law and the Company’s internal operating rules. Ignorance of the law is not acceptable, especially in areas directly related to our work.

If we need any clarification regarding the legal or regulatory framework, we must seek guidance from the appropriate authorities or the Company’s Legal Advisor.

A conflict of interest arises when an employee serves their own interests or the interests of someone directly or indirectly connected to them in a manner that competes with the interests of the Company. Favoring personal benefit or gain in the performance of duties by management or any employee, to the detriment of their loyalty to the Company, constitutes a conflict of interest.

All employees, at every level, are required to avoid any activities intended for personal financial gain or other private benefit while carrying out their duties, as this would violate their duty of loyalty to the Company.

We are obligated to act in the best interests of the Company and to both avoid and identify behaviors that could lead to any form of conflict of interest.

The guiding principle is that if a conflict of interest exists or may arise, it must be reported promptly to our immediate supervisor. We must also disclose any situation where a close relative works for or provides services to—or has a significant financial interest in—a competitor, supplier, or customer.
Conflicts of interest may arise in various situations and cannot all be anticipated in the Code. In case of doubt, we must inform our supervisor immediately so an appropriate solution can be found.

The key to addressing potential conflicts is full transparency and disclosure of all facts. This allows for a thorough analysis of the situation. Something that may initially appear problematic may in fact pose no harm to the Company. However, only through complete disclosure can all involved parties have confidence in assessing and addressing the matter.

Management and all employees of EVENTURE who are subject to this Code of Conduct are committed to acting with integrity, honesty, and fairness in all relationships, both inside and outside the Company, in compliance with national and international anti-corruption laws.

The Company does not tolerate any form of corruption (whether accepting or offering money to gain an improper business advantage), including to public officials, persons associated with public officials, or any individual or legal entity.

No individual, regardless of rank, may accept, request, offer, promise, or provide any illegal financial amounts or other benefits to serve improper purposes. The golden rule is total transparency and full disclosure of relevant facts to Management. Any situation that is or could potentially be a conflict of interest must be reported immediately to Management.

As part of our commitment to society, the Company may support local charitable organizations or sponsor events or activities (e.g., sports, cultural, or educational initiatives). Donations or sponsorships must only be made to reputable organizations after proper research and evaluation, and never with the expectation of gaining a business advantage. All donations and sponsorships must be transparent and properly documented.

It is forbidden to give or receive gifts intended to, or that may appear to, influence the creation or continuation of a business advantage. In particular, we must not accept or offer:

- Cash gifts
- Any gift during tender submission or contract negotiation periods
- Travel expenses
- Entertainment that may be considered luxurious or costly

Fraud is defined as an act or omission by a person who, with the intent of unlawfully gaining a benefit for themselves or another, causes harm to someone else’s property by misleading them through false representation or by intentionally hiding or omitting facts.

Someone committing fraud may seek either direct benefits or indirect ones, such as influence, power, or promotion, at the expense of the Company, employees, suppliers, or clients.
No form of fraud is tolerated, and all actions or omissions that expose us to fraud risk must be explicitly reported by everyone.

At EVENTURE, it is fundamental to treat clients, suppliers, and partners with fairness and honesty, establishing ethical, transparent, and professionally sound relationships with them.
Employees must respect the internal procedures applied by these companies and aim to develop long-term, profitable relationships with clients, offering security, support, quality, and value through continuous innovation.

The Company must explicitly avoid unfair discrimination in dealings with clients, suppliers, subcontractors, and partners. We must:

- Apply appropriate selection processes and controls when choosing a partner, supplier, or subcontractor to evaluate their integrity, quality, suitability, and reliability, and ensure they are properly licensed, capable, and qualified.
- Share sufficient information about the Code of Conduct prior to entering into any agreement, ensuring the partner understands the expectations. Partners must be aware that the Code is available on our website and commit to complying with our business ethics and conduct standards.
- Ensure all agreements with suppliers, partners, and third parties are in writing and clearly define the scope of goods and services provided, along with fees. These agreements must comply with applicable law and market principles and be made under conditions of transparency and fairness.
- Build mutual respect with our clients by applying best practices and ethical and professional conduct standards.
- Prioritize client satisfaction.
- Continuously improve the quality of our projects and services.
- Foster meaningful and open communication with our clients, offering support when needed.
- Aim for excellent collaboration and high-quality service, grounded in our expertise and long-standing experience.

The Company promotes workplace relationships based on mutual trust, constructive cooperation, two-way communication, and recognition. Respect is a fundamental value in our relationships with colleagues and all employees.

We must:

- Foster respect, honesty, and transparency among colleagues.
- Encourage and appreciate diversity, differing viewpoints, and experiences, while supporting sincere and open communication and showing adaptability, flexibility, and willingness to compromise.
- Develop relationships built on understanding and trust, demonstrating mutual respect and respecting the organizational hierarchy.
- Encourage well-intentioned feedback aimed at personal and professional development.

Additionally, key aspects include:

- Strict prohibition of drugs and alcohol in the workplace.
- Health and safety rules in the workplace are essential to protecting human life.
- Caring for health and safety is a core business policy and philosophy. We assess and monitor related risks and take all necessary preventive measures against accidents and occupational illness at work sites.
- We ensure the adequacy of building facilities and technology infrastructure.
- We provide continuous training and education on safety measures (e.g., emergency response, first aid, proper storage and handling of flammable or hazardous substances, equipment safety, and workplace signage) to prevent dangerous conditions and protect everyone.

Employees of the Company, depending on their assigned duties and regardless of the type or nature of their work, must demonstrate their competencies and skills in order to achieve the following goals:

- Results Orientation: Focus on achieving planned results through persistence and dedication to team and business goals.
- Planning and Organization: Execution of tasks in a methodical way and within set timelines, while flexibly incorporating new objectives and responsibilities when needed.
- Problem Solving and Decision Making: Assessment of alternative solutions and weighing of benefits and risks using critical thinking, and making timely and sound decisions based on appropriate analysis.
- Teamwork: Promoting a spirit of cooperation and teamwork through communication, participation, support, and sharing of information with colleagues and partners.
- Communication and Interpersonal Skills: Clear, persuasive written and oral communication, active listening and responsiveness, and development of constructive work relationships both within and outside the Company.
- Professional Conduct: Demonstration of ethical and professional behavior aligned with the Company’s values, setting performance standards and leading by example.
- Innovation and Creativity: Identifying opportunities and taking initiative to develop and implement new ideas and solutions.
- Leadership/Management Skills: Inspiring, motivating, and guiding employees toward improved performance and optimal results.
- Subject Matter Knowledge: Meeting job requirements through appropriate technical knowledge and capabilities.

The Company is committed to providing development opportunities based on each employee’s performance, competencies, and skills. Employee performance is evaluated to offer appropriate guidance and foster professional growth.

The selection, hiring, and training of employees is based on criteria such as:

- Qualifications and effectiveness
- Experience and knowledge
- Interest and creativity
- Other relevant criteria for the specific job role

 

We protect the confidentiality of all information related to the Company’s business activities. Confidential information includes all non-public financial, technical, or business-related data—such as administrative procedures, organizational matters, acquisition/merger plans, major management changes, Company development and strategy, know-how, business and financial plans, costs, tender documents, employees, clients, and suppliers.

We also ensure the confidentiality of employees’ personal data and of information entrusted to us by third parties.

Use or disclosure of such information is prohibited unless there is prior approval or legal obligation. Disclosure is only permitted when required by law, authorized for business reasons, or based on explicit consent. In all such cases, we must notify the relevant authority or supervisor for approval.

Any external party receiving such information must sign a confidentiality agreement (where legally applicable).

When using information systems, we must take special care to maintain data confidentiality, protection, and security, and avoid unauthorized access.

Employees must not disclose or share Company confidential information with third parties, including family and friends, during or after their employment. Protecting confidential information is the responsibility of all employees, regardless of how they obtained such information.

We handle the Company’s assets and resources responsibly, using them properly and exclusively for business purposes. Assets include both tangible (facilities, equipment, IT hardware/software, etc.) and intangible assets (trade secrets, patents, trademarks, intellectual property, information), as well as third-party assets in our possession.

Customer, subcontractor, and supplier lists, contract information, technical or commercial practices, bid proposals, studies, and any data accessed during the course of work are considered Company property. Our obligation to protect intangible assets continues even after leaving the Company.

We do not use Company assets for personal benefit or share them with individuals outside the Company.

Telecommunication systems and internal networks are Company property and must only be used for work purposes. We are responsible for keeping access credentials safe and must not illegally copy or use Company software.

We take particular care to avoid losses, damages, unnecessary expenses, or misuse of assets.

A core part of the Company’s environmental culture is proactive engagement with environmental challenges. We prioritize the development of Environmental Management Systems and are committed to minimizing the environmental impact of our operations by conserving natural resources and biodiversity, managing energy consumption, and handling waste responsibly.

Through responsible environmental management of our projects, we both protect the environment and determine our environmental footprint—two critical issues linked to climate change and sustainable development, which are major global challenges.

Strict compliance with environmental laws, including acquiring and maintaining all necessary permits and approvals for our business activities, is a fundamental operating principle of the Company.

We are committed to acting responsibly and with respect for the environment and society. Proper environmental management of our projects is one of our top priorities and is vital to the sustainability of our operations.

The Company recognizes health and safety at work as a fundamental right of employees and a key component of its sustainability. All decisions made within the Company must respect and prioritize workplace health and safety.

The Company has adopted—and continuously improves—an effective Health and Safety Policy based on the development of an Occupational Health and Safety Management System, combined with individual and collective preventive measures to minimize the risk of injury and stress in the workplace.

We believe in cultivating a culture of accident prevention and risk awareness among employees, and we actively promote this through training programs. Employees must consider themselves personally responsible for adopting all necessary preventive and behavioral measures that protect their health and safety, as outlined in the relevant training materials and safety instructions.

Employees must never expose themselves or others to risks that could lead to injury or harm.

All employees and management of the Company must conduct fair transactions with customers, suppliers, competitors, contracting authorities, and entities, acting fairly and always in compliance with the principles of lawful competition—both during tendering procedures and throughout the execution of contracts undertaken by the Company.

We are committed to ensuring that all our business activities are conducted within the framework of fair and healthy competition and in strict compliance with all applicable laws in the countries where we operate.

Unfair competition practices are not part of our Company culture. Training programs and compliance checks must be conducted regularly.

Practices that constitute unfair competition may expose the Company to significant financial penalties and reputational damage.

We must avoid any behavior that could be interpreted as an attempt—or an actual act—of violating competition protection regulations.

We are committed to operating responsibly and with respect for both the environment and society. Proper environmental management of our projects is one of our key goals and is essential for the sustainability of our business activities.

16. Adherence and Compliance with the Code

- All employees are responsible for reading and understanding the Code, seeking guidance when needed, and complying with both its letter and spirit.
- Employees must refrain from behavior that could damage the Company’s reputation.
- They are required to safeguard confidential information, protect Company assets, and avoid conflict-of-interest situations.
- Transactions with public authorities, customers, and suppliers must be conducted with integrity and based on honesty and transparency.
- Employees who interact with suppliers and customers as part of their job duties must inform them of the Code and, when necessary, ensure their compliance with its principles.
- All employees are obligated to report any actual or suspected violations of the Code to Company management.
- Management has an enhanced responsibility to ensure compliance with the Code.

Responsibility for managing violations of the Code lies with Company management. Depending on the severity of the violation, appropriate actions will be taken in accordance with applicable law.

If we become aware of any breach of this Code, we must report any incident that may pose a threat to human life, safety, the environment, or Company assets. We encourage the submission of signed reports, as these are easier to investigate. In any case, employees may seek clarification or advice on issues related to the Code of Conduct and matters of ethics and regulatory compliance from the Company’s legal counsel.

We are obliged to report serious misconduct, omissions, or criminal acts that come to our attention involving employees or external partners of the Company. Such reports may include incidents of:

- Theft, embezzlement, fraud, threats, extortion
- Forgery, use of forged documents
- Corruption, bribery, misuse of assets, abuse of power
- Breach of confidentiality, violation of legal frameworks
- Unethical behavior, insults, or defamation
- Violations of competition protection regulations

Based on the findings of any investigation, the Head of Regulatory Compliance proposes corrective and/or disciplinary actions. These may include (but are not limited to):

- Additional training
- Termination of employment
- Revisions to existing policies and/or procedures

The Company maintains a zero-tolerance policy toward any behavior that does not comply with the Code of Conduct. In this context, violation of the provisions of the Code constitutes a disciplinary offense.

Disciplinary offenses are subject to a two-year limitation period from the time they are committed.

Disciplinary authority is exercised by the competent body of the Company. If not otherwise specified, the legal representative of the Company is responsible for imposing disciplinary measures. Penalties are determined case-by-case, based on the nature and severity of the misconduct, and are imposed in accordance with applicable legislation. Disciplinary actions may include: written warning, written reprimand, fines, demotion, temporary suspension, or termination of contract.

The Code of Conduct is approved by the Company's Management. Management is responsible for ensuring that the principles outlined in this Code are communicated, understood, and observed by all employees. Compliance with the Code is regularly monitored. Any findings that ensure its proper implementation, along with any required updates, fall under the responsibility of the Board of Directors.

This Code applies to all employees, regardless of their date of hire. When interacting with suppliers and clients in the course of our duties, we must inform them of the Code and, if necessary, ensure their compliance with its provisions.

The Code of Conduct has been approved and ratified by EVENTURE’s Management and may only be modified or revoked by them. It will be updated or revised appropriately in response to changes in the scale or nature of the Company’s operations or following the emergence of extraordinary events. Any amendments or revocations will be communicated accordingly.

The Code takes effect upon its approval by Management. Proven violations of applicable law may lead to civil and criminal liability under current legislation, as well as termination of employment or other professional ties with the Company. In any case, if an act or omission is found to breach competition protection laws, the Company commits to taking all necessary and appropriate corrective measures immediately.

In case of any doubt regarding the legality of any communication, agreement, commercial practice, or activity, we must consult the Company's legal advisor.