Code of Ethics & Business Conduct

Jopetnah International Limited's Code of Ethics & Business Conduct establishes the standards of integrity, professionalism, and responsible business practices expected of all employees, contractors, partners, and representatives of the organisation. This Code reflects our commitment to ethical conduct and compliance with all applicable laws and regulations across all jurisdictions in which we operate.

Every person associated with Jopetnah is responsible for understanding and upholding these standards. We believe that ethical conduct is not merely a legal obligation, but a cornerstone of our reputation, stakeholder trust, and long-term sustainability.

1. Compliance with Law

All employees and representatives must comply with applicable laws, regulations, licences, and permits in all jurisdictions where we operate. This includes compliance with anti-corruption laws, competition law, data protection regulations, and industry-specific standards. No employee is expected to violate any law, and concerns about legal compliance should be reported immediately.

2. Conflicts of Interest

Employees must avoid situations where personal interests conflict or appear to conflict with the interests of Jopetnah. This includes financial interests, personal relationships, and outside business activities. Any potential conflict of interest must be disclosed in writing to your manager or the Company Secretary, in line with our Conflict of Interest Policy.

3. Confidentiality and Data Protection

Protect confidential and proprietary information belonging to Jopetnah, clients, partners, and individuals. All personal data must be handled in accordance with applicable data protection laws. Unauthorised disclosure or misuse of confidential information is grounds for disciplinary action.

4. Gifts and Entertainment

Employees may not offer, promise, or give gifts, entertainment, or anything of value to government officials or business partners with the intent to secure business advantage or favourable treatment. Modest gifts of nominal value consistent with business practice may be acceptable if disclosed and approved by management. See our Anti-Corruption & Anti-Bribery Policy.

5. Anti-Fraud and Financial Integrity

All financial records and business transactions must be accurate, complete, and honest. Fraud, embezzlement, theft, or misrepresentation of company assets is strictly prohibited. Employees are responsible for reporting suspected financial misconduct to senior management or the Managing Director.

6. Health and Safety

Jopetnah is committed to maintaining safe and healthy workplaces. All employees must comply with health and safety regulations and report hazards or unsafe practices immediately. We do not tolerate retaliation against employees who report safety concerns in good faith. See our HSE Policy.

Jopetnah seeks a professional environment in which all people are treated with dignity and fairness. Employment and engagement decisions are made on the basis of merit, qualifications, and capability, without regard to age, gender, gender identity, race, ethnicity, national origin, disability, sexual orientation, religion, or any other protected characteristic.

We are committed to:

• Providing equal opportunity in hiring, promotion, and compensation
• Maintaining a workplace free from harassment, bullying, and discrimination
• Respecting freedom of association and the right to collective bargaining
• Ensuring fair wages and benefits in accordance with applicable labour laws
• Providing reasonable accommodations for employees with disabilities
• Creating an inclusive culture where diverse perspectives are valued and heard

Any employee who experiences or witnesses discrimination, harassment, or unfair treatment is encouraged to report it to their manager, the Director of Human Resources & Public Relations, or through the channels in our Whistleblowing / Speak-Up Policy, without fear of retaliation.

Our commercial activities should be conducted responsibly and with awareness of their wider effects. We seek to build durable relationships based on honesty, fair dealing, and mutual benefit.

In our dealings with clients and customers, we:

• Provide accurate information about our services and capabilities
• Deliver services in accordance with contractual commitments
• Handle customer data securely and in accordance with privacy laws
• Respond promptly and professionally to complaints and concerns
• Avoid deceptive or misleading marketing and sales practices

In our relationships with suppliers and business partners, we:

• Conduct fair and transparent procurement processes
• Ensure partners comply with applicable laws and ethical standards
• Pay suppliers fairly and in accordance with agreed terms
• Work collaboratively to resolve disputes and concerns
• Respect intellectual property and contractual obligations

In our engagement with communities, we are committed to understanding and minimising negative impacts on the environments and societies in which we operate, and where possible, creating positive social value.

Anyone who becomes aware of suspected misconduct, a serious breach of this Code, or unlawful conduct is encouraged to report it through the appropriate channels. We are committed to investigating all concerns thoroughly, fairly, and promptly.

You can report concerns by:

• Speaking directly with your manager or senior leadership
• Contacting the Managing Director or the Company Secretary
• Submitting a written report marked “Confidential”, as described in our Whistleblowing / Speak-Up Policy

Protection from Retaliation: Jopetnah strictly prohibits retaliation against any employee who reports concerns in good faith, participates in an investigation, or raises ethical questions. Retaliation of any kind is grounds for disciplinary action, up to and including termination.

For detailed information about our reporting procedures and whistleblower protections, please refer to our Whistleblowing / Speak-Up Policy.

The Managing Director and senior leadership are responsible for promoting ethical conduct throughout the organisation, fostering a culture of integrity, and ensuring appropriate systems and controls are in place to support compliance with this Code.

Every person covered by this Code is responsible for:

• Understanding and complying with all provisions of this Code
• Attending ethics and compliance training or briefings provided by the Company
• Reporting suspected violations promptly and in good faith
• Cooperating fully with investigations
• Demonstrating ethical conduct in all professional interactions

This Code is reviewed periodically and updated as needed to reflect changes in law, business practices, and stakeholder expectations. All updates will be communicated to employees, and acknowledgement of this Code may be required periodically.

Effective date: September 2026  |  Version: 1.0  |  Approved by: Managing Director