# Code of Conduct CEK-POL-001 · Version 1.0 · Issued October 2026 · Cekera Ltd ## 1. Purpose This Code of Conduct sets out the standards of behaviour that Cekera Ltd ("Cekera" or "the Company") expects in every business dealing. It is the foundation of the Company's policy framework, and every other policy should be read together with it. Cekera trades industrial equipment across borders. Our customers, suppliers and banks rely on us to act lawfully, honestly and predictably. A single improper act can end a commercial relationship, so integrity is treated as a condition of doing business and not as an aspiration. ## 2. Scope This Code applies to the Director, officers, employees, contractors, consultants and any agent or intermediary acting on behalf of Cekera (together, "Personnel"), in every country where the Company does business. Suppliers and business partners are expected to meet equivalent standards, as set out in the Supplier Code of Conduct. ## 3. Our principles - We obey the law in every country where we operate. Where this Code sets a higher standard than local law, we follow this Code. - We are honest and accurate in what we say, write and record. - We win business on the merits of our products, prices and service. - We treat people with dignity and respect. - We protect the health and safety of people and the environment. - We raise concerns promptly and never retaliate against anyone who does so in good faith. ## 4. Integrity in business ### Bribery and corruption Cekera does not offer, give, request or accept bribes, kickbacks or facilitation payments, in any form, directly or through third parties. Detailed rules are in the Anti-Bribery and Corruption Policy. ### Gifts and hospitality Modest gifts and hospitality may be given or received only where they are lawful, infrequent, openly recorded and could not be seen as influencing a business decision. See the Gifts, Hospitality and Entertainment Policy. ### Conflicts of interest Personnel must avoid situations where a personal, family or financial interest could conflict with the interests of Cekera, and must disclose any actual or potential conflict. See the Conflicts of Interest Policy. ### Fair competition We compete vigorously and fairly. Personnel must not agree with competitors on prices, bids, territories or customers, must not exchange commercially sensitive information with competitors, and must not obtain competitor information by improper means. ### Sanctions, export controls and money laundering We comply with applicable sanctions, export control and anti-money laundering laws. We know who we are dealing with before we trade. See the Sanctions and Export Controls Policy and the Anti-Money Laundering and Know Your Counterparty Policy. ## 5. Accurate records and financial integrity - All transactions must be recorded accurately, completely and in the correct period. - No undisclosed or unrecorded account, fund or asset may be created or maintained. - Invoices, shipping documents and customs declarations must describe goods, values, origins and parties truthfully. - Records must be retained for at least seven years, or longer where the law requires. ## 6. People and workplace - We provide a workplace free from discrimination, harassment and bullying. - We respect internationally recognised human rights and do not tolerate forced labour, child labour or human trafficking in our business or supply chain. - We provide safe working conditions and expect Personnel to work safely and to stop work that is unsafe. ## 7. Company assets and information - Company assets, funds and systems are to be used for legitimate business purposes and protected from loss, theft and misuse. - Confidential information belonging to Cekera, its customers and its suppliers must be protected and used only for the purpose for which it was shared. - Personal data must be handled lawfully and securely, in line with the Data Protection and Privacy Policy. ## 8. Environment and communities We aim to minimise the environmental impact of our activities, comply with environmental law and act as a responsible member of the communities where we and our customers operate. ## 9. External communications Only authorised persons may speak on behalf of Cekera to the media, regulators or the public. Personnel must not make statements that are misleading or that disclose confidential information. ## 10. Making good decisions When the right course of action is not clear, ask: - Is it legal? - Is it consistent with this Code and our policies? - Would I be comfortable if it were reported to a customer, a bank or a regulator? - Would I be comfortable explaining it to my family? If the answer to any of these is no, or you are unsure, stop and seek advice from the Compliance Officer. ## 11. Responsibilities The Director of Cekera has overall responsibility for this policy and for ensuring that it is applied. The Compliance Officer is responsible for day-to-day implementation, for giving guidance, for maintaining the records this policy requires and for reporting to the Director. Until a separate appointment is made, the Director acts as Compliance Officer. All Personnel are responsible for reading, understanding and complying with this policy. ## 12. Breaches of this policy A breach of this policy is a serious matter. It may result in disciplinary action up to and including dismissal, or in the termination of a contract with a third party. Where a breach may also be a criminal offence, Cekera may report it to the competent authorities. ## 13. Questions and reporting concerns Questions about this policy should be addressed to the Compliance Officer at compliance@cekera.com. Any suspected breach must be reported promptly, in accordance with the Whistleblowing (Speak Up) Policy. No person will suffer retaliation for reporting a concern in good faith. ## 14. Review This policy is reviewed at least once a year, and whenever there is a material change in the law or in the business of Cekera. Changes are approved by the Director.