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Code of Conduct

NTS Holding GmbH and its subsidiaries are a leading IT service provider with locations in several countries. As a reliable business partner, we also feel responsible in our dealings with our customers, suppliers, employees, and other business partners. For this reason, we have developed a code of conduct to support our employees in the independent performance of their business activities. It forms the basis for legally compliant and transparent behavior by all employees within the group.

Our employees are an essential part of our company’s success and are a significant reason for the trust placed in us and our reputation. That is precisely why it is important to us to establish clear guidelines and principles for ethics and morality in business life. This Code of Conduct is an essential basis for this. By setting an example for each and every individual, it should make a significant contribution to our corporate culture.

“For us, RELAX, WE CARE means above all being a reliable business partner, competitor, and employer. It goes without saying that we comply with the law and adhere to the ethical principles that we
have imposed on ourselves and by which we are measured.”

Alexander Albler CEO, NTS

Objective

We take responsibility, design and support IT solutions with care, quality and certified experience. Our corporate values form the basis and guidelines for our actions and shape our dealings with employees and business partners.

This Code of Conduct is intended to serve as a basis for all business activities and decisions within the NTS Group and to provide reliable guidance in our daily professional work.

Scope

The Code of Conduct applies to the management, all executives, and all employees of the NTS Group (hereinafter collectively referred to as “employees”). Newly hired employees must commit to complying
with the Code of Conduct in their employment contract.

Each employee is responsible for complying with and implementing the code of conduct. Managers have a special responsibility to set an example in implementing the contents of the code of conduct.

When interpreting the rules of the Code of Conduct, employees should also be guided by common sense and question whether, based on reasonable
ethical and moral standards, a specific course of action could be perceived negatively. In doing so,country-specific standards and customs must also be
taken into account.

Where legal regulations exist, there is no room for interpretation. In case of uncertainty or questions, the direct supervisor or the Legal & Compliance department is always available to provide appropriate advice and decision support.

ADHERENCE TO RULES

Due to its international activities, the NTS Group is subject to a wide range of social, political, and legal conditions that must be observed. Violations of these conditions, particularly those that violate the legal system of a country, can cause considerable financial damage to the company and permanently damage the reputation of our Group.

It goes without saying that we comply with applicable laws and internal rules. We reject any form of corruption and bribery and act in the interests of the NTS Group. In the event of a conflict of interest, we disclose the situation immediately and in full!

INTEGRITY AND COMPLIANCE WITH THE LAW

All business activities and decisions must comply with the applicable laws and other external and internal regulations. All employees are urged to inform themselves comprehensively about the laws, internal guidelines, and other regulations applicable to their respective areas of responsibility and to consult with their supervisors in cases of doubt. Country-specific laws must also be observed.

DISCLOSURE OF CONFLICTS OF INTEREST

Employees are expected to always act in the interests of the NTS Group.
Nevertheless, employees may find themselves in situations where their personal or financial interests conflict with those of the company. Such conflicts of interest must be disclosed immediately and in full to the relevant supervisor.

AGAINST CORRUPTION AND MONEY LAUNDERING

All employees are strictly prohibited from offering or accepting benefits if this is intended to influence business transactions in an improper manner or could even give rise to such an impression. The only exceptions to this rule are gifts of minor value and hospitality within the scope of customary business practices. All other gifts must be refused or returned. Offering or accepting money or monetary benefits is never permitted. We do not tolerate any activities that violate money laundering regulations.

We’re all in this together

PEOPLE AND WORK ENVIRONMENT

Respect, openness, and appreciation characterize our collaboration. We act thoughtfully, independently, transparently, and cultivate an appreciative, friendly working environment.

Based on the UN Charter, the European Convention on Human Rights and the ILO Core Labor Standards of the International Labor Organization, human rights are considered fundamental values that must be respected and observed. The corporate culture of the NTS Group recognizes that every person is unique and valuable and should be respected for their individual abilities. We therefore do not tolerate any form of discrimination, bullying, or sexual harassment — in whatever form — and promote an environment characterized by appreciation and cooperation. We welcome diversity and believe it contributes to a successful team.

CAREFUL SELECTION OF BUSINESS PARTNERS

The careful selection of our business partners is a central component of our corporate activities. We attach great importance to ensuring that our partners share our values and are also committed to responsible and ethical business practices. Even when initiating business relationships, we take care to obtain sufficient information to be able to make a well-founded assessment of the integrity, reliability, and professionalism of our counterpart.

Our goal is to build long-term partnerships based on trust, fairness, and shared values. In doing so, we consider not only the immediate collaboration, but also the entire supply chain. A clean and ethically sound supply chain is essential to guarantee social and environmental standards and ensure that our business activities are in line with the principles of sustainability and responsibility.

PROTECTING THE ENVIRONMENT

Protecting our environment is a central component of our corporate strategy and is reflected in all aspects of our actions. We are committed to conducting our business activities in a responsible and environmentally conscious manner. We strive to minimize the ecological impact of our activities, use resources sustainably and energy-efficiently, and actively contribute to reducing environmental pollution.

We motivate our employees to act in an environmentally conscious manner and involve them in measures to protect the environment and comply with environmental standards

PROTECTION OF FAIR COMPETITION

Transparent and fair conduct in the market ensures the interests and competitiveness of the NTS Group as a whole in the long term. Restrictions on free competition and violations of competition and cartel laws are incompatible with the corporate philosophy and culture as well as the self-image of the NTS Group.

In particular, no agreements may be made with competitors regarding prices, price-relevant information, or other business topics that determine or influence competitive behavior. This applies not only to written agreements, but also to verbal agreements and coordinated practices.

We promote a respectful working environment and carefully select business partners to ensure ethical standards and sustainable supply chains.

Protecting the environment through responsible action is just as important to us as complying with competition and cartel law to ensure transparency
and fairness.

HANDLING OF INFORMATION AND DATA

RESPONSIBLE COMMUNICATION

Responsible communication is an essential part of our actions, and this applies to all employees, both in a professional and private context. Especially on social media, we expect that no statements are made that violate applicable laws, hurt other people, are malicious or discriminatory, or could damage the reputation of our company. Each and every one of us is responsible for respectful and constructive communication that reflects our values and strengthens trust in our organization.

FINANCIAL RESPONSIBILITY

All relevant information is disclosed in a timely and accurate manner and in accordance with applicable accounting and disclosure regulations. Reports, records, and documents must always be complete and accurate; manipulation or misleading entries are unacceptable in any form. We comply with tax law regulations and reject any form of tax evasion or fraud without exception.

CORRECT REPORTING

We place great importance on transparent, truthful, and orderly reporting. Another focus is on sustainability reporting. In line with the principle of “do good and talk about it,” we highlight our environmental, social, and ethical contributions in order to build trust and transparency. The rule here is that all information communicated must be based on verifiable facts and always be truthful in order to promote our credibility.

CONFIDENTIALITY & HANDLING OF INTERNAL INFORMATION

Confidential information of any kind obtained in the course of professional activities may not be used to pursue personal interests, nor may it be made available for the use of third parties. It must be ensured that company information of any kind is always kept secure. When external partners (e.g., subcontractors, suppliers, consultants) are involved, appropriate confidentiality agreements must be concluded.

DATA PROTECTION AND PRIVACY

We are unreservedly committed to the principles of data protection. Personal data will therefore only be processed if there is a corresponding legal basis and always in compliance with data protection principles.

The disclosure of personal data both within the company and externally is permitted exclusively within the framework of the statutory provisions. In addition, the relevant confidentiality agreements of the respective service contracts apply.

DEALING WITH ARTIFICIAL INTELLIGENCE

We only use artificial intelligence (AI) for legally permitted purposes, namely to increase the efficiency of processes, simplify work steps, and improve customer service, and within the limits of the law. We use AI results exclusively under careful supervision and after human verification of the results for factual accuracy, correctness, and context. In addition, we ensure transparency and explicitly point out the use of AI when it is employed.

As part of our commitment to transparent and truthful reporting, we disclose relevant information in a timely and proper manner. We communicate responsibly and in accordance with our values.

We protect confidential information and data from unauthorized access and disclosure! We are committed to the transparent and responsible use of AI.

CONSEQUENCES OF NON-COMPLIANCE

Violations of the rules of conduct and principles set out here cause us lasting damage and can result in a wide range of consequences and sanctions for us. These include financial and criminal consequences, which can have adverse effects not only on our entire group of companies, but also on each individual.

Therefore, NTS will take action in the event of any violations of laws or internal regulations and will take appropriate measures to resolve the matter. Failure to comply may result in criminal, civil, and labor law measures

Violations of the principles of conduct set out here can result in serious sanctions for the individual concerned, but also for the entire NTS Group.

If you have any questions or uncertainties, you can contact your supervisor or Legal & Compliance at any time. Everyone is encouraged to report any perceived grievances or violations internally so that we can take appropriate
action.

REVISIONS AND CHANGES

Our Code of Conduct applies throughout the entire NTS Group and is issued by the management. Our international environment and our business
developments are dynamic variables, which is why this code is regularly reviewed to ensure it remains up to date and is adapted as necessary.

The Legal & Compliance department is responsible for revising and maintaining the Code of Conduct, ensuring that all changes comply with legal and ethical requirements. This way, we ensure that the Code always reflects our values and serves as a reliable guide for responsible conduct.

CONTACT AND REPORTING OFFICE

The Legal & Compliance department is responsible for the specific coordination and content-related support of the implementation of our compliance measures.

We encourage all employees, partners, and interested parties to contact us directly with any questions or suggestions. Through open communication and the commitment of everyone involved, we want to ensure that compliance is not just an obligation on paper, but is actively practiced and leads to tangible results.

If employees of the NTS Group become aware of violations of this Code of Conduct, legal regulations, or other internal guidelines, they are encouraged to report this immediately.

The report can be made directly to the immediate supervisor, the Human Resources department, or the Legal & Compliance department.

In addition, we have set up a reporting platform for anonymous tips, which is accessible at any time via our website or via our reporting system. All incoming reports are carefully investigated and treated confidentially.

In order to promote open and trusting communication, it is expressly stated that employees who report incidents in good faith will not face any negative
consequences whatsoever. This also applies to other persons who contribute important information to the investigation of such misconduct.

Contact: Legal & Compliance Department compliance@nts.eu

Reporting offices are: