Vanderbilt International Code of Conduct

Vanderbilt International is committed to sustaining the highest degree of integrity in all relations with potential, current, and past customers, both in terms of normal commercial confidentiality, and the protection of all personal information gathered while providing the company’s services.

We extend the same standards to all our customers, suppliers, and associates.

A. Ethics

1. We always conduct our own business honestly and honourably and expect our clients and suppliers to do the same.

Our strategic support and the methods used take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and suppliers.

2. Our actions and advice will always conform to the relevant law.

We believe that all businesses and organizations should avoid causing any adverse effect on the human rights of people in the organizations we deal with, the local and wider environments, and the well-being of society at large.

3. We conduct our activities professionally and with integrity.

We try to be fully objective in our judgment and any support and services that we give are never influenced by anything other than the best interests of our customers.

4. Employees must comply with all applicable laws and regulations.

Vanderbilt International will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery.

5. Any breaches of this policy will result in immediate termination and, when applicable, prosecution to the fullest extent of the law.

B. Privacy and Confidentiality

1.When dealing with or handling financial and personal information about customers or others with whom the company has interactions and relations, ensure the following principles:

1) Collect, use, and retain only the personal information necessary for the business. Whenever possible, obtain any relevant information directly from the person concerned.

2) Use only reputable and reliable sources to supplement this information.

3) Retain information only for as long as necessary or as required by law.

4) Protect the physical security of this information.

5) Limit internal access of personal information to those with a legitimate business reason for seeking that information.

6) Use information only for the purposes for which it was originally obtained.

7) Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.

2. E-mails: Company emails should be used for business purposes only, and consequently all email traffic is considered company property. To comply with national law Vanderbilt reserves the right to monitor emails and internet use.

3. Telephone conversations: These will not be monitored, except where specifically agreed with the employees or a third-party for training or other cases.

4. Personnel files (employment and medical records):All HR related documents both physical and electronic are confidential and are kept segregated from all other business and commercial related documents, in locations where access is restricted. Physical documents are stored in locked cabinets or similar.

They are only disclosed for legitimate reasons.

Employment records are only released to any other person if required by law - and then only with the written permission from the employee.

C. Diversity, Gender Balance, and Equal Opportunities

1. We at Vanderbilt value and encourage diversity. This promotes gender balance for managerial positions. Priority is given to underrepresented gender – given equal qualifications - and to increase diversity during the recruitment process.

2. We always attempt to be fair and unbiased in our judgment. We are never influenced in our decisions or actions by issues of gender, race, creed, colour, age, or personal disability.

D. Child labour

1. At Vanderbilt, we recognize the rights of every child which need to be protected always- from economic exploitation and physical, mental, or any other abuse or harmful interference that would minimize, limit, or diminish their education opportunities, health, or social wellbeing.

The definition applied for “child” here, is a person under the age of 16,which could have legal restrictions or implications regarding the type of work they can perform in certain r countries.

2. Vanderbilt strictly prohibits any form of forced or bonded labour or illegal workers.

E. Drug or/and Alcohol Abuse/ Harassment

1. Vanderbilt International expects its employees to conduct themselves in a business-like manner. Drinking, gambling, fighting, swearing, and similar unprofessional activities are strictly prohibited while on the job.

2. Employees must not engage in sexual harassment or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

3. Vanderbilt provides an environment of respect and dignity where everyone is treated equally and fairly.

F. Competition

1. Vanderbilt does not participate in unfair, erroneous, ambiguous or misleading comparisons, anti-competitive agreements, or activities. Employees must avoid any anticompetitive arrangements and unethical business practices with any of our partners or competitors.

2. Employees should avoid investing in or acquiring a financial interest for their accounts in any business organization that has a contractual relationship with Vanderbilt International or that provides goods or services, or both.

G. Bribery

Gifts, Donations, and Entertainment

1. Employees must not accept entertainment, gifts, or personal favours nor facilitation payments that could, in any way, influence, or appear to influence, business decisions in favour of any person or organization with whom or with which Vanderbilt International has, or is likely to have business dealings.

2. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with the organization might be inclined to, or be perceived to, place them under obligation to return the preferential treatment.

3. Vanderbilt strictly prohibits the acceptance of secret commissions from suppliers or others.

4. Purchasing and Sales activities must be handled with the utmost integrity. Therefore, no Vanderbilt employee should give nor accept gifts, entertainment offers, or gratuities which could influence the customer’s or employee’s decision making.

5. In the nature of business relationships, there can still be small gifts, hospitalities, and expenses that are common. These must be handled with careful consideration and should only be accepted or given on an acceptable and moderate level.

Conflict of Interest

1. Vanderbilt expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the company.

Employees must not use their positions or the knowledge gained because of their positions for private or personal advantage.

2. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

3. Conflicts could include: employing a family member, using confidential insider knowledge, personal financial interest, outside company activities.

H. Fraud

1. Vanderbilt enforces strict principles to prevent fraud and dishonesty.

If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that Vanderbilt can promptly investigate further.

2. When an employee’s position requires spending company funds or incurring any reimbursable personal expenses, that individual must use good judgment on Vanderbilt’s behalf to ensure that good value is received for every expenditure.

3. Company funds and all other assets of Vanderbilt International are to be used for company purposes only and not for personal benefit. This includes the personal use of organizational assets, such as computers for example.

I. Records and Reports

1. True and trustworthy records of many kinds are necessary to meet legal and financial obligations. For Vanderbilt, keeping records (both in paper and electronic form) and their integrity is vital.

2. Vanderbilt’s books and records must reflect in an accurate and timely manner all business transactions. The responsible employee(s) in Finance must completely disclose and record all assets, liabilities, or both, and enforce these requirements.

3. Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to: False expense or attendance, financial or similar reports and statements, false advertising, deceptive marketing practices, or other misleading representations.

J. Environment and Sustainability

1. Vanderbilt is pledged to comply to be in accordance with the applicable statutory and international standards regarding environmental protection.

There are continuous efforts to minimize environmental pollution and make continuous improvements in environmental protection throughout its value chain. We are working to safeguard our environment by reducing pollution, reducing the amount of waste, and enforcing regulations that keep our water and air clean.

Vanderbilt is taking precautions for its employees not to be harmed by any environmental-related impacts.

2. There is an EHS (Environmental and Health and Safety) plan in place that describes in detail what we do to comply with our standards and requirements.

We are dedicated to implementing a sustainable environmental framework that is innovative and long-lasting.

Vanderbilt expects all employees to help and take responsibility for the execution of this approach.

From our customers, we expect (as in T&C):

Pursuant to the European Union’s Directive on Waste Electrical and Electronic Equipment (WEEE) and the European Union's Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS), the organizational and financial responsibility for the removal and processing of waste originating from any electrical and electronic equipment shall, unless otherwise agreed, be transferred to the customer upon delivery. The customer undertakes to assume responsibility, on the one hand, for the collection and removal of waste originating from the electrical and electronic equipment subject to the contract and, on the other hand, for its processing and recycling.