Responsibility and the continuous development of operations form an important part of our everyday work. The Patria way is guided, among other things, by the laws and regulations in force in each market, practices governing export permits and agreements that we have drawn up alongside our customers.

Abiding by the Patria values, ethical rules and guidelines will enable us to provide our stakeholders with added value and increase our attractiveness as an employer. By operating in the right way, we will also enhance our own working environment and ensure its continuity.

The ethical code forms the basis of the activities of every Patria employee. Each and every one of us at Patria bears responsibility for following these instructions. More about Patria and its Ethical industry player.

Introduction

Patria Group’s (“Patria”) objective is to pursue long-term profitable business in an ethical and responsible manner taking into account, inter alia, economical, human and social, as well as environmental matters since this creates loyalty and trust among employees, customers, shareholders, other stakeholders and in the communities in which Patria operates. Proper business conduct means compliance with the highly recognised standards of ethical conduct as well as with all and any applicable laws. To make Patria’s aim clear in this respect this Code of Conduct (“Code”) has been set up.

Applicability of the Code

The Code is applicable to all Patria’s domestic or foreign group companies. Furthermore, it is a non-negotiable requirement that all Patria’s employees including directors and officers follow this Code without exception. Accordingly, it is the responsibility of each employee within Patria to ensure full compliance with this Code.

Ethics and Legal Compliance

It is the policy of Patria to comply in all of its operations with all applicable laws and regulations wherever Patria conducts its business. These include, inter alia, laws and regulations related to antitrust and fair competition, including prohibition to obtain confidential information of other parties by improper means and to use or disclose confidential information of other parties without authorisation, corporate governance, product safety and product liability, occupational health and safety, labour, environment, human rights, protection of individual privacy as well as equality at work. It is the obligation of each employee to obtain understanding of laws and regulations relevant to their work and take appropriate measures to ensure compliance with the laws and regulations. Irrespective of position, no one at Patria has the right to conduct, expect or allow illegal activities.

Conflicts of Interest, Gifts and Bribes

Patria employees are expected to promote the interest of Patria and, while doing so, to act responsibly. Patria’s employees must avoid any activity which may lead to conflict of interest. Any kind of corruption and bribery in Patria’s operations is prohibited. Patria and its employees must not offer or pay bribes or any other illegal payments to any government officials or other parties in order to obtain or retain business or for any other reason. Patria s employees shall not take personal benefits or business courtesies from Patria’s stakeholders or suppliers which are not in accordance with any applicable law or code of local business practice. Benefits or business courtesies may only be accepted if given in the ordinary course of business and provided that they shall in all circumstances be of moderate value.

Respecting and Promoting Human Rights

Patria shall respect and promote universal human rights as defined by the United Nations’ Universal Declaration of Human Rights in its operations. Among those rights Patria considers to be fundamental and universal are: freedom of thought, opinion, expression, religion and peaceful assembly as well as freedom from any discrimination based on race, age, nationality, gender or sexual orientation. Furthermore, Patria shall not tolerate any use of forced or child labour.

Human Resource Practices

All employees with managerial duties are required to actively and purposefully promote a leadership culture, which is in accordance with Patria’s values and the spirit of this Code. Patria aims to provide a safe and inspiring working environment to all employees. Accordingly, employees are required to conduct their duties without endangering health and safety in the workplace. Employees shall be treated and evaluated in accordance with their job related skills. Patria is committed to being an equal opportunities employer and shall treat all employees fairly, impartially and equally. Harassment in any form is unacceptable.

Environment

The environment is an important element in all Patria’s business operations. Patria strictly adheres to environmental legislation and regulations. Patria is committed to operating in accordance with the principles of sustainable development using responsibly natural resources, continuously improving its environmental performance as well as preventing pollution.

Safeguarding Corporate Assets

Safeguarding Patria’s assets, both tangible and intangible (such as intellectual property rights) is vital to Patria’s success in business. Therefore employees have a duty to use Patria’s assets only for legitimate business purposes and to protect them for loss or any unauthorised use. In no event Patria’s assets may be used for unlawful or improper purposes.

Suppliers and Subcontractors

Patria shall make every effort to deal with suppliers, subcontractors, consultants and agents only, who are prepared to work in accordance with the principles presented in this Code. Patria requires that suppliers, subcontractors, consultants and agents shall comply with local legislation in all countries where they operate.

Implementation of the Code

All Patria employees must comply with this Code. Employees are encouraged to contact supervisors, managers or other appropriate personnel, when questions arise how to act in a particular situation and how to interpret this Code.

It is Patria’s policy to ensure the compliance with this Code by organising and developing appropriate auditing, monitoring and reporting processes.

Employees who violate this Code are subject to disciplinary action up to and including termination of employment. Furthermore, all employees are encouraged to report any violations against this Code to their own superior or to the General Counsel. Any person reporting such violations in good faith will not be retaliated in any way for making such a report. In all instances the rights and privacy of both the reporting person(s) and the one(s) accused of violations are to be adequately protected and assured