CODE OF CONDUCT

We have a zero-tolerance policy towards all forms of corruption and bribery:
- Employees must not offer, give, or receive bribes or improper payments in any form.
- We prohibit facilitation payments, even where they may be legally permitted.
- All gifts and hospitality must be reasonable, proportionate, and properly recorded.

COPEMER LTD is committed to preventing money laundering:
- We conduct appropriate due diligence on our business partners and transactions.
- Employees must report any suspicious financial activities or transactions.
- We maintain accurate records of all financial transactions.

We believe in fair competition and strictly adhere to all applicable competition laws:

- Employees must not engage in price-fixing, bid-rigging, or market allocation with competitors.

- We do not share sensitive business information with competitors.

- All agreements with competitors, suppliers, or customers must be reviewed for compliance with competition laws.

COPEMER LTD is committed to respecting human rights and eliminating modern slavery:

- We prohibit the use of forced labor, child labor, and human trafficking in our operations and supply chain.

- We ensure fair working conditions, including appropriate wages and working hours.

- We respect the right of employees to freedom of association.

The health and safety of our employees and partners is paramount:

- We provide a safe and healthy working environment for all employees.

- All employees must follow safety procedures and report any hazards or incidents.

- We regularly assess and mitigate health and safety risks in our operations.##

COPEMER LTD complies with all applicable trade sanctions and export control laws:

- We conduct thorough screening of business partners against sanctions lists.

- Employees must not engage in transactions with sanctioned countries, entities, or individuals.- We maintain proper documentation for all international transactions.

We encourage all employees to report any suspected violations of this Code of Conduct:

- Reports can be made confidentially to the designated compliance officer.

- We prohibit retaliation against anyone who reports concerns in good faith.

Adherence to this Code of Conduct is mandatory for all employees, directors, and representatives of COPEMER LTD.

We are committed to regularly reviewing and updating our policies to ensure ongoing compliance with applicable laws and regulations.