Veloris is committed to be a good corporate organisation, taking account of the economic, social and environmental impact of our business and aiming to maximise the benefits and minimise any negative impact of our global operations (Code of Conduct)

Human rights

Veloris supports the principles of the European Union Declaration of Human Rights, and we are committed to upholding these principles in our policies, procedures and practices. Respect for human rights is and will remain integral to our operations.

We will endeavour to work with business partners who conduct their business in a way that is compatible with our policies of respect for human rights and ethical conduct. We will work with customers to ensure that contractual requirements do not infringe human rights.

We will take measures to ensure that the work of our employees does not compromise universally accepted human rights conventions, whilst recognising and respecting the diversity in local cultures in which we operate.

The Environment

We will conduct our business with respect and consideration for the environment. We will strive to minimise our environmental impact through the management of waste, vehicle emissions and energy consumption.

Local Communities

Veloris is fully committed to supporting and assisting the communities in which we operate through a variety of means including charitable fund-raising, sponsorship of community projects and voluntary work by employees. We conduct our business with respect and consideration for the good of local communities, taking steps to minimise any disturbance because of our operations. We will also serve local interests by providing good employment opportunities and effective services and products.

Our standards of business practice

We are committed to high ethical standards in our business dealings to ensure the integrity of our employees and our organisation is maintained.

Bribery and corruption

Veloris is resolutely opposed to bribery and corruption in whatever form it may take. Gifts or entertainment may only be offered to a third party if they are consistent with customary business practice in the relevant territory, are modest in value and cannot be interpreted as inducements to trade. Where there is doubt, guidance should be sought from the relevant Veloris Director. No financial or other inducements should be given to third party organisations or to individuals from such organisations in any circumstances, including government agencies and representatives.

Sales of the Company’s services and products and purchases of products and services from suppliers will be made solely on the basis of quality, performance, price, value and/or for the benefit of the Group, and never on the basis of giving or receiving inducements in the form of payments, gifts, entertainment or favours or in any other form.

Employees should not accept gifts, money or entertainment from third party organisations or individuals where these might reasonably be considered likely to influence business transactions. Gifts, other than trivial ones with a low value, should be returned. In a culture where such an action might cause offence, the gift should be declared to the company and, if practical, donated to an appropriate charity.

Political contributions

Veloris does not make contributions to political parties worldwide.

Treatment of customers

Mutual trust and confidence between Veloris and our customers are vital. All employees should strive to consistently deliver service excellence and value for money, meeting customers’ expectations and anticipating their changing requirements

External suppliers

All suppliers are entitled to fair treatment, and all potential suppliers should have a reasonable opportunity to win Veloris business. It is our policy to pay suppliers on time in accordance with agreed terms of trade. We set high standards for our suppliers in the context of our own ethical policy.

Competition

Veloris will always compete vigorously, but in a fair and ethical way. Competitive success is built on providing good value and service excellence. Competitors should not be disparaged. When in contact with competitors, employees will avoid discussing confidential information and no attempt will be made to improperly acquire competitors’ trade secrets or any other confidential information. Employees must not discuss pricing strategies or undertake any arrangements or practices which would conflict with the laws applicable to the business concerned.

Our approach to corporate governance

Veloris is committed to protecting the interests of our shareholders and our organisation through compliance with the relevant legal and regulatory environments and careful management of business risks.

Compliance with the law

Veloris will comply fully with all relevant national and international laws and will act in accordance with local guidelines and regulations, including those which are industry specific, governing our operations.

It is the responsibility of all managers to ensure, by taking legal or other expert advice where appropriate, that they are aware of all local laws and regulations which may affect the area of the business in which they are engaged, including tax and exchange controls.

Accounting standards and records

All accounting documentation must clearly identify the true nature of business transactions, assets, and liabilities in conformity with relevant regulatory, accounting and legal requirements. No record or entry may be false, distorted, incomplete or suppressed.

All reporting must be accurate and complete and in compliance in all material respects with accounting policies and procedures. Employees must not materially or knowingly misrepresent management information for personal gain or for any other reason.

External reporting

Veloris may be required to make statements or provide reports to regulatory bodies, government agencies or other government departments. Care should be taken to ensure that such statements or reports are correct, timely and not misleading. Senior management must be made aware of any sensitive disclosure before it is made. Care must also be taken when making statements to the media that information given is correct and not misleading. Enquiries from the media should be referred to company media relations experts and statements should only be made by designated spokespersons.

Veloris will provide, through our website and through the published annual report and accounts and other statements, appropriate information to enable shareholders to assess our business performance. We will comply with applicable laws and regulations as to the disclosure of information about Veloris.

Policies and procedures

Veloris recognises that there are risks associated with carrying out any business activity. Management is responsible both for ensuring that policies and procedures are in place to manage risks and for complying with those policies and procedures. Employees should ensure that they are aware of the risks associated with their activities and that they comply with policies and procedures in place to manage those risks.

Our commitments to our employees

Veloris is committed to optimising individual and business performance through employing the best people at all levels and creating an environment in which they want to and are able to contribute fully to the Group’s success. To achieve a working environment in which team spirit and commitment to the goals and values of Veloris are maintained, the Company will ensure that individual employees are treated fairly and with dignity and respect.

National regulation

In dealing with our employees, we will act in compliance with national regulatory requirements and employers’ obligations to employees under employment law must be respected.

Harassment

Harassment can be defined as unwanted behaviour, which a person finds intimidating, upsetting, embarrassing, humiliating or offensive. Conduct involving the harassment (racial, sexual or of any other kind) of any employee is unacceptable. Should an employee believe that he or she has been harassed the matter should be raised with the relevant Human Resources Manager who will arrange for it to be investigated without delay, impartially and confidentially.

Equal opportunity

We value all our employees for their contribution to our business and their opportunities for advancement will be equal and not influenced by considerations other than their performance, ability and aptitude. Employees will also be provided with the opportunity to develop their potential and, if appropriate, to develop their careers further with the company.

Health & Safety

Veloris places the highest priority on promoting the health and safety of employees whilst at work. We will constantly review the effectiveness of our methods of operation to best protect those who work in a high-risk environment.

Terms of employment

Veloris employees will work towards creating permanent long-term relationships. Employees will be paid for and work hours at least as favourable as the terms established by national legislation or agreements or industry standards.

Pre-employment screening and selection

In order to protect the interests of our employees and customers Veloris will apply rigorous pre-employment screening and selection techniques.

Our employees’ commitments to Veloris

Employees must avoid situations where appearance of business impropriety exists, even though the circumstances might not otherwise specifically violate this code of conduct or where specific laws, or regulations do not apply.

Confidential information

Employees must not make use of confidential information obtained through their employment for personal gain, nor disclose such information to any third party during or after their employment. ‘Confidential information’ is either information that has been specifically described as being confidential or is otherwise obviously confidential from the surrounding circumstances.

The term “confidential information” does not include information in the public domain or information which the individual concerned is required by law to disclose.

Conflicts of interest

Every employee has a duty to avoid business, financial or other direct or indirect interests or relationships which conflict with the interests of the Company, or which divides his or her loyalty to the Company. Any activity which even appears to present such a conflict must be avoided or terminated unless, after disclosure to the appropriate level of management, it is determined that the activity is not unethical or improper, does not compromise integrity and is not detrimental to the reputation and standing of the Company.

Implementation

This Business Ethics Policy must be adopted by Veloris as a minimum standard and issued to all senior Managers. It will be published on our extranet and incorporated into future employment contracts where applicable. It will be monitored as part of Veloris compliance processes. The policy will be reviewed annually.

Employee complaints, whistle blowing and suggestions

Employees can expect that the Company will give due consideration to their constructive suggestions and will provide a considered and objective review of genuine concerns and complaints. Such concerns include fraud, misrepresentation, theft, harassment, discrimination and non-compliance with regulations, legislation, policies, and procedures.

Concerns must be investigated impartially so that the employee’s rights are protected. Employees who have concerns about potential unethical behaviour should advise their line Manager, HR Department, or a Company Director in the first instance. Employees may do this anonymously if they so wish. To ensure that confidentiality is maintained, employees should not discuss such concerns with colleagues or other third parties, unless specifically authorised or unless it is a legal requirement.

Compliance monitoring

We monitor, on a regular basis, compliance with this ethics policy, using information reported via the whistle blowing facility, internal/external audit, and ongoing management reporting.

Adherence to policy

Since Veloris aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with the Company’s principles and policies are not tolerated. Strict adherence to these principles and supporting policies is a condition of employment within Veloris. Any action by an employee, which deliberately or recklessly breaches this ethics policy, may result in disciplinary action and where appropriate, criminal proceedings will be initiated.

November 2025