Code of Ethics / Code of Conduct for 528

3. Compliance with Laws and Regulations

All employees and representatives of 528 must:

Where local practices conflict with this Code, the stricter requirement applies.

4. Human Rights and Fair Labour Practices

528 respects internationally recognised human rights standards, including those of the International

Labour Organization (ILO).

We commit to:

• Prohibiting child labour, forced labour, and human trafficking

• Ensuring freedom of association and the right to collective dialogue

• Providing equal opportunities without discrimination based on gender, age, origin, religion, disability,

sexual orientation, or any other protected characteristic

• Maintaining a safe and healthy workplace, with specific attention to cold-work environments

• Treating all employees with dignity and respect

Harassment, intimidation, or abusive behaviour is not tolerated.

5. Health, Safety and Well-Being

The safety and well-being of employees is a core responsibility of 528.

We commit to:

• Providing a safe working environment, including specific controls for cold storage and freezer work

• Supplying appropriate Personal Protective Equipment (PPE)

• Offering safety training and clear procedures

• Encouraging employees to stop work if unsafe conditions arise

• Supporting physical and mental well-being, including respect for rest periods and the right to

disconnect

All employees must follow safety instructions and report unsafe situations.

6. Anti-Corruption and Anti-Bribery

528 applies a zero-tolerance policy toward bribery and corruption.

It is strictly prohibited to:

• Offer, promise, give, request, or accept bribes or improper advantages

• Use intermediaries to circumvent anti-corruption rules

• Influence business decisions through personal benefits

This applies to interactions with customers, suppliers, agents, and public authorities.

Gifts and Hospitality

• Modest business hospitality may be acceptable if reasonable, transparent, and infrequent

• Cash or cash-equivalent gifts are never permitted

• Gifts or hospitality that could influence, or appear to influence, decisions are prohibited

• When in doubt, employees must seek approval from management

7. Conflicts of Interest

Employees must avoid situations where personal interests conflict with the interests of 528.

This includes:

• Personal or family relationships with suppliers, customers, or competitors

• Financial interests that may affect impartial decision-making

• External activities that interfere with professional responsibilities

Any potential conflict of interest must be declared promptly to management.

8. Fair Competition and Market Conduct

528 competes fairly and ethically.

Employees and representatives must not:

• Engage in price-fixing, bid-rigging, or market-sharing agreements

• Exchange confidential or commercially sensitive information with competitors

• Abuse a dominant market position

All marketing and sales activities must be honest, accurate, and transparent.

9. Protection of Company Assets and Information

All company assets—physical, financial, and digital—must be used responsibly.

This includes:

• Protecting machinery, products, and materials from misuse or theft

• Safeguarding confidential business information

• Using IT systems and data responsibly and securely

Employees must comply with internal IT and information-security rules.

10. Data Protection and Privacy

528 respects privacy and complies with the General Data Protection Regulation (GDPR).

We commit to:

• Processing personal data lawfully, fairly, and transparently

• Collecting only data that is necessary for legitimate business purposes

• Protecting personal data against unauthorised access or loss

• Respecting the rights of customers, employees, and partners

All employees handling personal data must follow applicable privacy procedures.

11. Environmental Responsibility and Ethical Business Conduct

Ethical conduct at 528 includes responsibility for environmental and societal impact.

Employees and partners are expected to:

• Use energy, water, and materials responsibly

• Reduce waste where possible

• Support sustainable sourcing and logistics decisions

• Act consistently with 528’s environmental and sustainability commitments

Unethical environmental practices are treated as ethical violations.

12. Whistleblowing and Speak-Up Culture

528 encourages an open and transparent culture where concerns can be raised without fear.

• Employees and external parties may report suspected misconduct, unethical behaviour, or violations

of this Code

• Reports can be made confidentially via the designated whistleblowing channel

Retaliation against whistleblowers is strictly prohibited

All reports will be handled objectively and, where necessary, investigated.

13. Responsibilities and Enforcement

Violations may result in disciplinary measures, contract termination, or legal action.

14. Continuous Improvement

This Code is part of 528’s broader commitment to responsible business conduct and sustainability.

• It is reviewed periodically

• It evolves with legal, ethical, and stakeholder expectations

• Feedback is welcomed to improve clarity and effectiveness

15. Acknowledgement

All employees and relevant business partners are expected to acknowledge and respect this Code of

Ethics & Code of Conduct.