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Code of Conduct

Policy objectives

The goal of Accesa (the Company) is to sustainably strengthen the success of our shareholders and clients through competitive IT solutions and services. Our Code of Conduct outlines the ethical principles and behaviours that govern our conduct as an organisation, that we all need to demonstrate. They are mandatory and are published externally on the Company’s website for transparency reasons.

Policy statement

The trust our shareholders and customers place in our company and in the quality of our service depends largely on how we behave and how we use our skills for the benefit of our customers.

We believe in a world in which businesses use technology to have a meaningful impact on the way we live, work, and do business.

We partner with our clients on this journey to envision and engineer the solutions that seamlessly integrate into their business and improve people’s lives. In doing this, we are guided by the following core ethical principles:

Honesty: We uphold honesty by consistently communicating truthfully, refraining from deception or misleading information, and being forthright in all our business interactions. We strive to build trust through transparent and accurate communication.
Integrity: We conduct ourselves with unwavering integrity, adhering to high moral and ethical standards in every facet of our operations. We keep our commitments, act ethically, and take responsibility for our actions, ensuring our business practices reflect our core values.
Transparency: We promote transparency by openly sharing information that is relevant and appropriate with our employees, suppliers, clients, and stakeholders. We believe in being open and accessible, fostering an environment of trust and accountability.
Respect: We treat everyone with respect, recognising every individual's inherent dignity and worth. We embrace diversity and inclusion, valuing different perspectives and cultures. We create a workplace and business environment that is free from discrimination, harassment, or bias.

Purpose, scope, and users

The purpose of this policy is to set the relevant ethical principles and fundamental values of the Company and to set the expected behaviour from employees, behaviour that the company considers fundamental to their successful operation.

All internal company guidelines and policies must be consistent with this code. This policy applies to all Accesa’s entities - Accesa IT Systems S.R.L., Accesa Consulting S.R.L., and Accesa Managed Services companies (collectively referred to as “the company”). As far as the term “employees” is used in this policy, it means all persons working for Accesa including the board of directors (Management Board). The suppliers and other third parties engaged in business activity with us, must adhere to our Supplier Code of Conduct available on Company’s website.

1. Main principles

Anti-Corruption and Bribery

Integrity, lawful conduct, and impartiality in business decisions are prerequisites for a trusting business relationship. We have a zero-tolerance policy for corruption, bribery, or any form of improper benefit, whilst we support all activities aimed at detecting, preventing, and reporting it. We document and make transparent all business transactions related to donations and sponsorships.

We comply with anti-corruption laws and regulations and actively promote a culture of transparency and ethical behaviour.

All employees are prohibited from accepting or offering improper benefits, as defined in the Anti-Corruption Policy and Conflicts of Interest Policy. Corresponding internal regulations apply, which must be observed by all employees in business dealings.

Compliance with laws and regulations

We comply with all applicable Romanian and international laws, regulations, and international standards governing our industry and business operations. This means we are committed to preventing and detecting illegal or unethical business practices.

We align our software/company’s products and services to legal requirements, including data protection, intellectual property rights, and cybersecurity.

Responsible Use of Technology

We use technology responsibly, aiming to prevent that our software and services do not cause harm, violate privacy, or facilitate illegal activities.

We are mindful of the potential societal impact of our products and services and take measures to address any ethical concerns.

Intellectual Property

We respect and protect intellectual property rights, both our own and those of others, by having a zero-tolerance for software piracy, plagiarism, or unauthorized use of copyrighted materials.

We implement proper mechanisms to prevent any infringement of intellectual property rights and we carefully monitor our products and services to fully comply with applicable legal requirements in this area.

Fair Competition

We compete fairly and ethically in the marketplace, adhering to anti-trust and competition laws.

We avoid using unlawful/ unfair competitive practices or providing any incentives, such as price fixing, collusion, improper gifts, or misleading advertising and maintain a strong commitment to fair and ethical competition.

All employees are instructed regarding their legal or contractual obligations not to disclose business secrets or other internal information to competitors or other third parties in an unauthorized and unjustified manner.

Data Protection

We follow the highest standards to safeguard personal data, as well as other confidential or restricted information such as commercial or trade secrets and business data, in line with applicable regulatory requirements and standards.

We build trust and confidence among clients, employees, and business partners, by adhering to the GDPR and Data Protection principles.

We collect and process data only for legitimate purposes, prioritise transparency towards data subjects and enforce proper technical and organisational measures to ensure personal data security.

We respect data subjects’ rights, promptly respond to data breaches, and we safeguard personal information, including when transferring data internationally. Our accountability extends to conducting privacy risk assessments, monitoring and auditing personal data handling, and regularly reviewing and updating our privacy practices.

Environmental Responsibility

We promote environmental responsibility and sustainability in our operations.

We strive to minimise our environmental footprint, reduce waste, promote sustainable practices, and comply with applicable environmental laws and regulations.

We encourage energy conservation, waste reduction, recycling, and responsible resource management.

Respect and Dignity at work and OHS

We promote a respectful and inclusive work environment free from discrimination, harassment, or unfair treatment. We foster a work environment that values diversity and provides equal opportunities for all employees.

We treat all individuals with respect and dignity, regardless of their gender, civil status, age, religion, disability, or any other protected characteristic.

We prioritize our employees’ health, safety, and well-being, maintaining a safe working environment, comply with occupational health and safety regulations (OHS), and encourage reporting of potential hazards.

Conflicts of interest

We conduct ourselves with integrity and honesty in all our interactions within the organization and with external stakeholders.

We avoid conflicts of interest and act in the company's best interests, maintaining transparency and avoiding deceptive practices. When a conflict arises, it must be disclosed promptly to the compliance function so that steps are taken to resolve or mitigate such conflicts.

We strongly discourage our employees from using any confidential information about our clients, suppliers, or other business partners, for their personal gain/interest or for other purposes than those for which it was entrusted to us.

Whistleblowing Reporting

We ensure the transparency and honesty of our business operations; thus, our business processes are fully and truthfully documented We have an internal control system and active risk management to avoid risks that could jeopardize the continued existence of the company.

We provide a dedicated channel for employees to report ethical concerns, misconduct, or violations of the Company’s internal regulations and policies.

Whistleblowers will be protected from any kind of retaliation, and reports are treated confidentially, and promptly investigated, whilst appropriate actions are being taken.

2. Closing word

Trust in a company is measured in particular by how shareholders, clients, and business partners perceive the company. This code of conduct does not work simply because it is available it must be applied in daily business activities, therefore:

We provide regular training and communication to ensure awareness and understanding of this Code of Conduct.
Employees and subcontractors are expected to read, acknowledge, and comply with the principles outlined in this Code.
By following this Code of Conduct, we uphold our commitment to integrity, responsibility, and ethical business practices, fostering trust and professionalism within Accesa and its subcontractors.

When you doubt any topic related to this Code, please seek advice from the Compliance Office (compliance@accesa.eu).

SUPPLIER CODE OF CONDUCT

Based on the Group core values addressing business ethics and social and environmental commitments, Accesa IT Systems S.R.L., Accesa Consulting S.R.L., and Accesa Managed Services companies, from now on, are called “Partner” requires the Supplier to adhere to the hereafter listed Principles (as defined below) which will be attached to the contract entered between them (the “Contract”).

The Supplier shall do its utmost to implement these Principles throughout its whole supply chain. This Supplier Code of Conduct is not intended to replace the laws and regulations in force. It seeks to encourage and respect these laws and regulations and ensure that they are faithfully and effectively enforced.

Principles

1. Compliance with National and European Law

In addition to complying with the following provisions as detailed in sections 1 to 6 below, the Supplier shall always comply with applicable laws, regulatory requirements and the contractual obligations as agreed between the Parties. This shall include the US Foreign Corrupt Practices Act and the UK Bribery Act, where applicable.

Furthermore, the Supplier shall adhere to any international trade sanctions (including embargoes), which shall include any sanctions that may be in force because of a resolution passed according to Chapter VII of the UN Charter by the UN Security Council and any sanction that the European Union may have imposed. The Supplier shall bind its contractors and/or subcontractors (from now on referred to as “Subcontractors”) to the Principles of this Supplier Code of Conduct as they are involved in provisioning deliverables under the Contract. The Parties agree that adhering to this Supplier Code of Conduct is a primary contractual obligation under the Contract.

2. Social Responsibility Practices

2.1. Freedom of Association and Right to Collective Bargaining

The Supplier shall seek to implement internationally recognized standards, e.g. International Labor Organization (ILO) Conventions, without violating national legislation. It shall ensure that its employees and representatives, including temporary (agency) workers, may openly express themselves in their company concerning matters related to their working conditions.

2.2 Child Labour Child labour is strictly prohibited

"Child labour" means the definition of Article 32 of the United Nations Convention on the Rights of the Child (UNCRC). If any child is found working at the Supplier's premises, the Supplier shall immediately take steps to redress the situation in the child's best interests.

2.3 Diversity and Non-Discrimination

The Supplier shall prohibit and fight harmful discrimination based on race, colour, sex, sexual orientation, language, religion, political or another opinion, national or social origin, property, birth or another status, and shall promote diversity, equality of opportunity or treatment in employment and occupation.

The Supplier shall treat all employees with respect and shall not use physical punishment, mental or physical coercion, any form of abuse or harassment or threat of such treatment.

2.4 Remuneration

The Supplier shall provide remuneration according to national legal standards on minimum wage. Where no national legal standards exist, the remuneration shall be sufficient to meet basic needs (ILO C131 – Minimum Wage Fixing Convention). The basis on which workers are paid shall be conveyed to them on time.

2.5 Working Hours

The Supplier shall respect the individual worker’s need for recovery and secure that all workers have the right to adequate leave from work with pay. Where no national legal standards exist, ILO standards shall apply. Working hours, including overtime, shall comply with applicable local laws.

2.6 Health and Safety

The Supplier shall provide its workers with a safe and healthy workplace and should implement effective programs to – where necessary - improve the working environment.

The Supplier shall do its utmost to control hazards and take necessary precautionary measures against accidents and occupational diseases.

The Supplier shall provide adequate and regular training to ensure that workers are educated on health and safety issues. This shall include provisions and instructions to use appropriate personal protective equipment.

The Supplier shall secure that, where it provides accommodation, it shall be clean, safe, meet the workers' basic needs and, where appropriate, for their families.

The Supplier is encouraged to implement a Health & Safety Management System based on international standards such as OHSAS 18001 or similar.

3. Environmental Responsibility Practices

3.1 Environmental Protection

The Supplier shall take a precautionary approach towards environmental challenges (e.g. climate change, biodiversity, etc.), undertake initiatives to promote greater environmental responsibility and encourage the development and usage of environmentally friendly technologies.

The Supplier shall act following relevant local and internationally recognised environmental standards and applicable local laws, whereby the highest standard shall be applied.

The Supplier shall minimise its environmental impact and should implement measures contributing to pollution prevention and protecting the environment. The Supplier shall minimise or strive to avoid hazardous air emissions, energy consumption and CO2 emissions. In particular, the Supplier shall develop products and services that feature low energy consumption and CO2 emission reduction during the life cycle.

The Supplier shall obtain and adhere to all necessary permits and strive to implement an Environmental Management System based on international standards such as ISO 14001.

3.2 Natural Resources and Waste Management

The Supplier shall limit the use of materials and resources, including water when sourcing or producing goods to minimise environmental impact.

The Supplier is encouraged to track the source of conflict minerals, promote transparency along its supply chain and put measures in place for this purpose. The use of rare resources shall be limited or avoided where possible.

The waste produced by all its activities shall be identified, monitored and managed. The Supplier shall strive to reduce waste. Waste treatment shall follow applicable environmental laws.

4. Prohibited Business Practices

4.1 Anti-Corruption

The Supplier shall refrain from any form of corruption or actions that could potentially be construed as such. The Supplier may not offer, promise or grant illegal benefits to national or international public officials or decision-makers operating in the private sector to achieve preferential treatment or a favourable decision; the same applies when dealing with donations, gifts or invitations to business meals and events.

The Supplier may not allow itself to be promised or offered advantages and shall not accept the same if this may or shall create the appearance to the party bestowing the benefits that it can thus be influenced in business decisions.

Likewise, the Supplier may not request advantages. The Supplier shall avoid conflicts of interest that may lead to corruption risks. If the Supplier is also a customer, it shall not draw any unfair advantages from this and shall keep procurement and sales separate.

The Supplier undertakes and requires its directors, officers, employees, suppliers, affiliates, Subcontractors and each respective representative (from now on, the “Third Parties”) to respect the rules of this Section together with the regulations by appropriate means for the effective implementation and to maintain of a compliance framework, that:

(i) the Third Parties involved in the performance of the Contract comply with these Rules and that

(ii) every necessary means used by Third Parties to perform the Contract comply with the Rules. To ensure compliance with the Rules for the duration of the Contract, the Supplier shall provide on demand. At all times, all elements requested to establish such compliance and shall inform the Partner without any delay, when it knows or has reason to know, of any failure to comply with the Rules by itself or any Third Party, as well as the corrective

measures adopted to ensure compliance with the Rules. A material non-compliance with the Rules may trigger a termination right of the Contract following its provisions.

4.2 Competition

The Supplier shall respect the rules of free and fair competition in all business relations and not act against any competition and/or antitrust law.

4.3 Sponsorship

All sponsoring measures by the Supplier must follow current legislation.

4.4 Political Contributions

The Supplier shall not donate money or grant any monetary benefits to any political party unless permitted by law.

4.5 Money Laundering

The Supplier shall take all measures to prevent money laundering within its sphere of influence.

4.6 Data Security and Data Protection

The Supplier shall adhere to all applicable data protection laws and all specific data protection and security requirements agreed to in the Contract.

5. Monitoring and Audits

To ensure compliance with the Principles as outlined in this Supplier Code of Conduct for the duration of the Contract, the Supplier shall provide on demand all elements requested to establish such compliance and shall inform the Partner without any delay when it knows or has reason to know, of any failure to comply with the Principles by itself or by any Subcontractor, as well as the corrective measures adopted to ensure compliance with the Principles.

Accesa, therefore, expects all employees and its partners to behave in accordance with these requirements.

The employees, customers or suppliers of the Company are encouraged to make disclosures of offences, cases of suspected illegal behaviour, or serious irregularities-omissions in connection with the Code of Conduct through a dedicated reporting platform.