Code of Ethics & Business Conduct

1. Purpose & Scope

This Code of Ethics and Business Conduct establishes the ethical standards, legal compliance requirements, and cultural expectations for all personnel operating within the Aevum Zenth Conglomerate. As a multidivisional enterprise spanning over 400 subsidiaries and 62 countries, we recognize that our reputation, license to operate, and long-term value creation depend on unwavering adherence to the highest standards of integrity.

This document applies to every director, officer, employee, contractor, consultant, and third-party agent acting on behalf of Aevum Zenth. Ignorance of this Code does not constitute a defense against its requirements.

2. Leadership Commitment

The Board of Directors and Executive Leadership of Aevum Zenth affirm that ethical conduct is non-negotiable. We are committed to:

• Leading by example in all business decisions and interpersonal conduct
• Allocating sufficient resources for compliance training, monitoring, and audits
• Fostering an environment where ethical concerns can be raised without fear
• Integrating sustainability and social responsibility into core strategy

3. Integrity & Compliance

Anti-Corruption & Bribery

We strictly prohibit offering, promising, giving, soliciting, or accepting anything of value to influence business outcomes, government actions, or internal decisions. This includes compliance with the U.S. FCPA, UK Bribery Act, and all applicable local anti-corruption statutes.

Fair Dealing & Competition

Our operations shall adhere to antitrust and competition laws globally. We will not engage in price-fixing, market allocation, bid-rigging, or the improper exchange of competitively sensitive information with rivals.

Financial Reporting & Transparency

All financial records must be accurate, complete, and timely. Management is responsible for establishing and maintaining adequate internal controls. Material misstatements or intentional omissions are grounds for immediate disciplinary action.

4. Workplace Standards

Aevum Zenth operates a zero-tolerance policy regarding:

• Harassment, discrimination, or retaliation of any kind
• Workplace violence, intimidation, or threats
• Substance abuse that impairs safety or professional performance
• Exploitation of labor or violation of human rights in our supply chain

We are an equal opportunity employer committed to diversity, equity, and inclusion. Business decisions shall be made on merit, capability, and business necessity, free from bias.

5. Conflicts of Interest

A conflict of interest arises when personal interests improperly influence, or appear to influence, professional judgment or corporate duties. Employees must:

• Disclose any outside employment, board memberships, or significant financial holdings
• Avoid doing business with relatives, close associates, or entities in which they hold an interest
• Recur themselves from decisions where impartiality could be reasonably questioned
• Submit annual Conflict of Interest declarations through the Governance Portal

6. Protection of Assets & Data

Corporate assets, intellectual property, and confidential information are entrusted to us for business use only. Unauthorized copying, sharing, or external transfer of proprietary data is strictly prohibited. Cybersecurity hygiene, including strong authentication and prompt incident reporting, is mandatory across all divisions.

We are also committed to environmental stewardship. All operations must comply with applicable environmental regulations and align with our Net-Zero 2040 commitments.

7. Reporting & Non-Retaliation

Employees and contractors are encouraged to report suspected violations through multiple confidential channels:

• Direct manager or divisional compliance officer
• Global Ethics Hotline (24/7, multilingual): +41-800-ZENTH-CODE
• Secure web portal: ethics.aevumzenth.com/report

Non-Retaliation Guarantee: Aevum Zenth strictly prohibits retaliation against anyone who reports concerns in good faith, participates in investigations, or declines to participate in unethical conduct. Violations of this policy will result in severe disciplinary action, up to and including termination.

8. Enforcement & Document Control

Violations of this Code will be investigated promptly and impartially. Disciplinary measures are proportional to the severity of the breach and may include counseling, suspension, termination, civil action, or referral to law enforcement.

This Code is reviewed annually by the Board’s Governance & Compliance Committee. Material updates will be communicated globally and require digital acknowledgment.