Code of Conduct

At SanGroup Europe, we are committed to upholding
the ‘highest standards’ of ethical and responsible
behavior in all of our business operations.

We strive to maintain ‘trust-based’ relationships
with our clients, business partners, suppliers,
employees, and the communities in which we
operate.

Therefore, all representatives, employees, contractors,
and agents of SanGroup Europe ‘are bound’ by the
following general standards of behavior.

Conflicts of Interest: We ensure that our personal interests and relationships do not create conflicts of interest that risk undermining that trust. It is therefore required to disclose any personal conflicts of interest, obtain required approvals, and follow any restrictions.

1

Money Laundering and Terrorist Financing: We do not engage in any money laundering or terrorist financing activities. We comply with all applicable laws and regulations to prevent and detect such activities.

2

Price Fixing: We do not collaborate with competitors on how to price our services or products to pursue opportunities in a particular market. We compete fairly and ethically, respecting the free market principles.

3

Confidentiality: We do not misuse the confidential information or know-how of our business partners, clients, suppliers, agents or former employers. We protect the confidentiality of our business information and the information entrusted to us by our partners and clients.

4

International Trade Controls: We comply with all applicable international trade controls including economic sanctions and export controls. We do our utmost to ensure compliance with all applicable laws and regulations.

5

Governance and Accountability: Our board of directors holds management accountable to operate and manage the company according to strong ethical and governance principles. We maintain transparent and effective governance processes, ensuring that we act in the best interests of our stakeholders.

6

Accurate Record Keeping: It is important to us that all transactions are recorded accurately, completely, and in a timely manner, in accordance with the accounting principles applicable at the company. We maintain proper and accurate financial records, ensuring transparency and accountability.

7

Delivering on Commitments: We only commit to what we can deliver and engage with our clients as one team.

8

Confidentiality of Non-Public Information: We take all reasonable measures to protect the confidentiality of non-public information relating to our company and clients.

9

Human Rights and Social Responsibility: We conduct our business in an ethical and responsible way. We support and respect human rights and take our share of social responsibility. We are committed to upholding international child labor standards in our own operations. We expect all of our suppliers to comply with international mandated labor standards and respect working hour requirements.

10

Environmental Sustainability: We are committed to minimizing our environmental footprint. We strive to operate our business sustainably, and we expect our suppliers, their subcontractors and business partners to do the same. This includes complying with all applicable environmental rules, regulations, and standards, and taking measures to reduce waste, conserve natural resources and prevent pollution.

11

Built to Last

We believe that our business can only be successful if we operate in a way that is consistent with our values, including our commitment to human rights, social responsibility and environmental sustainability.

We are committed to regularly reviewing and updating this Code of Conduct to ensure that we are meeting these standards, and to holding ourselves and our partners accountable for their adherence to these principles.

We expect that all our suppliers, business partners, and contractors are able to assume their responsibility and act in compliance with this Code of Conduct.