CODE OF CONDUCT DELTIA

[October 11th, 2024]

At Deltia, our business relationships are guided by a commitment to ethical conduct, mutual respect, and

responsible practices. This Code of Conduct applies to Deltia as well as to our customers, suppliers, and

partners. We seek to create and maintain a respectful, safe, and compliant business environment. By

adhering to this Code, all parties help foster integrity, transparency, and accountability, supporting the

sustainability of our business and relationships.

This Code outlines the expectations for each party involved in our business network. Compliance with these

standards is essential to our shared success and reflects our commitment to ethical business practices.

1. LEGAL AND ETHICAL COMPLIANCE

At Deltia, we believe that adherence to laws and ethical standards is foundational to a successful

and trustworthy partnership. To meet this commitment, we expect all parties involved to:

1.1 Follow All Applicable Laws and Regulations: Compliance with relevant laws, rules, and standards

in all regions where we operate is mandatory. This includes regulations related to labor, safety,

environmental protection, trade, and consumer protection. Each party is responsible for staying

informed about these legal requirements and ensuring their business activities align with them. By

observing local and international laws, we protect the integrity of our operations and the well-being of

those impacted by our work.

1.2 Engage in Ethical Business Practices: We hold ourselves and our partners to the highest

standards of integrity. This means strictly avoiding any form of corruption, including bribery, extortion,

or embezzlement. Offering or accepting bribes, as well as participating in any other forms of illegal or

unethical inducements, is strictly prohibited. These standards ensure that we conduct business

openly, fairly, and responsibly.

1.3 Prevent Illegal Activities and Promote Accountability: Any activities or practices that could result

in legal or ethical violations must be prevented. All parties should ensure reasonable safeguards are

in place to monitor and verify compliance.

2. FAIR COMPETITION AND BUSINESS INTEGRITY

Fair competition is essential to a healthy business environment, supporting innovation and ethical

practices. We expect:

2.1 Engagement in Fair Business Practices: All business activities should be conducted with fairness

and respect toward competitors. We expect all parties to follow anti-trust and competition laws,

refraining from actions that unfairly hinder competition or exploit monopolistic practices.

2.2 Transparency and Avoidance of Conflicts of Interest: We ask our partners to disclose any

situations where personal interests or outside affiliations might conflict with business responsibilities.

By openly addressing conflicts, we maintain transparency and ensure that all decisions are made in

the best interest of the partnership. Partners should avoid any relationships, transactions, or

affiliations that could compromise, or appear to compromise, their impartiality or integrity in working

with Deltia.

Transparency and a commitment to fair business practices strengthen trust among all parties,

fostering a collaborative and supportive environment.

3. CONFIDENTIALITY AND DATA PRIVACY

The protection of information and respect for privacy are paramount in our partnerships. We expect

all parties to prioritize:

3.1 Safeguarding Confidential and Proprietary Information: During the course of business, sensitive

information—such as trade secrets, proprietary data, or business strategies—may be shared. It is

the responsibility of each party to ensure that this information is handled with the utmost care, not

disclosed without authorization, and only used for the intended purposes. By respecting

confidentiality, we protect our competitive advantage and maintain trust.

3.2 Compliance with Data Privacy Laws: In today’s digital age, personal data protection is critical. All

parties must comply with relevant data protection regulations, including GDPR, ensuring that any

personal data collected, processed, or stored as part of our business relationship is managed

responsibly. Partners are required to implement appropriate security measures to protect data from

unauthorized access, alteration, or misuse. Should a data breach or security incident occur,

immediate notification to Deltia is essential.

Through these confidentiality and privacy commitments, we safeguard both corporate and individual

rights, reinforcing trust within our partnership.

4. LABOR STANDARDS

We are committed to upholding fair labor practices that respect the rights and dignity of all workers

involved in our business activities. This includes:

4.1 Prohibition of Child Labor and Forced Labor: Under no circumstances should any party employ

under-aged workers or engage in any form of forced, bonded, or involuntary labor. Labor practices

must comply with international standards and local laws governing the rights of workers. Workers

should be free to choose employment voluntarily, and any form of coercion or trafficking is strictly

prohibited. These standards are non-negotiable and form the foundation of our commitment to

ethical labor practices.

4.2 Equal Opportunity and Non-Discrimination: We believe in an inclusive and diverse workplace. All

employment decisions, including hiring, compensation, promotion, and termination, should be based

on qualifications and performance without discrimination on the grounds of race, gender, age,

religion, disability, or other protected characteristics. By fostering equal opportunity, we create a

workplace where everyone can contribute and thrive.

4.3 Respectful and Fair Treatment: Each partner is expected to provide a work environment free from

harassment, abuse, or harsh treatment. Every worker should be treated with respect and dignity,

fostering a culture of professionalism and empathy. Workplace policies should reflect a commitment

to fair treatment and encourage respectful communication and behavior at all levels.

These labor standards promote a positive and supportive work environment, which benefits both

individuals and organizations alike.

5. HEALTH, SAFETY, AND ENVIRONMENT

We are committed to a safe, healthy, and environmentally responsible workplace. This commitment

extends to our partners, and we expect:

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5.1 Adherence to Health and Safety Standards: All parties are responsible for creating safe work

conditions by following relevant health and safety regulations, minimizing workplace hazards, and

providing appropriate safety equipment and training. Emergency preparedness plans should be in

place, and all employees should be educated about procedures for responding to incidents. By

prioritizing health and safety, we protect our employees and maintain a productive environment.

5.2 Environmental Responsibility and Sustainability: We strive to minimize our impact on the

environment and encourage our partners to adopt sustainable practices. This includes responsible

use of resources, waste reduction, and measures to reduce emissions. Partners should aim to

conserve natural resources, avoid hazardous materials where possible, and engage in activities that

support recycling and reuse. Together, we contribute to a healthier planet and demonstrate our

commitment to environmental stewardship.

Through these health, safety, and environmental commitments, we help create a workplace that is

sustainable for future generations.

6. CONFLICT-FREE SOURCING

Ethical sourcing is a key component of responsible business practices. Therefore:

6.1 Commitment to Conflict-Free Materials: We encourage all parties to source materials in a way

that does not fund conflict or human rights abuses. By sourcing responsibly and transparently, we

ensure that our supply chain reflects our values and supports global human rights. We expect all

partners to adopt practices that verify the origins of materials and, where possible, choose suppliers

with certified conflict-free practices.

This commitment supports a sustainable supply chain and upholds the values of peace and fairness

globally.

7. REPORTING AND ACCOUNTABILITY

An open and accountable culture allows us to address and resolve issues proactively. To support

this:

7.1 Encouragement of Reporting Concerns: We encourage all parties to report any violations of this

Code or any concerns about unethical practices. Reports can be made to designated contacts within

Deltia, and we commit to protecting individuals from retaliation. Every report will be reviewed,

ensuring that concerns are taken seriously and addressed appropriately.

7.2 Commitment to Investigation and Corrective Action: When a violation of this Code is reported,

Deltia will conduct an investigation. Based on the findings, corrective actions will be implemented as

necessary to prevent recurrence. Partners found in violation of this Code may face consequences,

including the potential termination of the business relationship, depending on the severity of the

infraction.

By fostering a culture of accountability and transparency, we ensure that our partnerships remain

aligned with our ethical standards.