Code of Conduct & Business Ethics

Effective Date: January 01, 2026 | Version: 1.0

1. Introduction

At Sustalium B.V., our mission is to deliver transparent, reliable compliance technology. To achieve this, our own business practices must meet the highest ethical standards. This Code of Conduct outlines the baseline expectations for our team, contractors, and partners.

2. Diversity, Equity, and Inclusion (DEI)

We are committed to a work environment free of discrimination and harassment. We do not discriminate based on race, colour, religion, gender, gender identity, sexual orientation, national origin, genetics, disability, or age. Employment and partnership decisions are based strictly on merit, qualifications, and business needs.

3. Human Rights & Fair Labor

• No Forced/Child Labor: We have a zero-tolerance policy for modern slavery, forced labor, and child labor in our operations and our supply chain.
• Fair Wages: We are committed to paying all employees and contractors a living wage that meets or exceeds local legal minimums.

4. Data Privacy & Information Security

• All employees must strictly adhere to the General Data Protection Regulation (GDPR) and our internal Information Security Management protocols.
• Client data, trade secrets, and proprietary information must be handled with strict confidentiality and must never be accessed or shared without explicit, authorized business purpose.

5. Conflicts of Interest

Employees must avoid any situation where personal interests conflict, or appear to conflict, with the interests of Sustalium B.V. Any potential conflict of interest must be disclosed immediately to management.

6. Compliance with Laws

Sustalium B.V. operates in compliance with all applicable local, national, and international laws, including sanctions and trade regulations. Ignorance of the law is not an excuse. When in doubt regarding a business decision, team members are required to seek guidance from management.