TOGETHER WITH INTEGRITY OUR BUSINESS CODE OF CONDUCT

Every one of us is responsible for knowing, safeguarding – and representing – this code.

What is the code?

The code of conduct is a document that sets forth our expectations of behavior for employees of the company. It is not meant to cover every situation, but covers a variety of areas and refers employees to the proper policies that apply to specific matters.

Who must follow the Code?

The Code applies to all of our directors, officers and employees.

What is expected of employees?

We expect you to be familiar with the provisions of this document and adhere to the spirit and language of the Code. You should ask questions about things that are unclear or for which you need guidance. You are expected to report any issues you notice where the values of the company and the Code do not appear to have been applied. Refer title “Expect of Each Other” in this document for more detail.

What if I have questions?

If you have questions relating to fair, ethical and lawful business conduct or feel there may have been a violation of any of our policies or guidelines, you should discuss the matter with your supervisor. If you feel it is not appropriate under the circumstances to involve your direct supervisor or supervisor’s manager in the matter, you may contact the Chief Executive Officer, Chief Financial Officer or Chief Legal Officer.

Expect of Each Other

Integrity can take years to build, but it can be lost in a moment. We need to be focused and thoughtful about how we represent NEWTLA SNS to others

• Know and follow the code
• Aim to do the right thing, the first time, every time
• Don’t engage in actions unless you are sure they are ethical
• Speak up: ask questions and raise concerns when issues arise

We deliver high-quality technology and services, and we always follow the laws of the different countries in which we work. Sometimes these laws vary from place to place and could even conflict. This Code is your guide to help you navigate and understand what is expected of you.

Our Code and the NEWTLA SNS internal requirements represent the standard of business care expected everywhere we work, from everyone who works for NEWTLA SNS, even when local laws are less developed or less stringent.

This Code and its underlying principles apply to all NEWTLA SNS employees, officers, directors, and contractors. We also expect our vendors, suppliers, agents, and other third-party business partners working on our behalf to comply with our Code and uphold our high ethical standards.

Principles of Conduct

We are committed to maintaining ethics and compliance culture wherever we do business. We recognize that our reputation for integrity and compliance is reflects our core values, safety, integrity, collaboration and innovation.

• NEWTLA SNS directors, all employees must comply with applicable laws of the countries where they operate.
• NEWTLA SNS obliged to adopt highest ethical level while dealing with customers/clients.
• All the communication must be transparent, accurate with timely response and maintain high level of confidentiality.
• We commits to the compliance of contractual terms and condition d all applicable laws and regulations and perform all contractual obligations strictly.

Raise Your Voice

We all feel a sense of ownership at NEWTLA SNS. If we see something that is not working, we want to fix it. If something can be better, we try to improve it. Similarly, if you see something wrong, something that goes against our values and the principles – you must speak up.

You can raise questions or report your concerns in many ways:

• To your manager at your location
• To HR representative
• To member of Compliance Team

Working the Safe Way

Nothing is more important that the health and safety of our lives. If anything – a job, procedure, project, and travel – can’t be done safely and securely, we will not do it.

Ensuring the health and safety of our employees, our customers and the public is a core value of NEWTLA SNS. Compliance with all applicable regulations and laws governing employee health and safety, as well as strict compliance with our policies and procedures, are a requirement of employment. Every employee is required to work safely at all times to prevent injury to yourself or others and to prevent damage to property. This includes familiarity and compliance with company and customer safety requirements and proper use, operation, and handling of tools, equipment and materials.

You are responsible for complying with all applicable employee safety and health laws of each state, country and locality, as well as all applicable company and customer standards and policies, where business is conducted.

We deliver on this promise through five key principles:

• We Do Not Compromise – Our HSE Principles.
• We Speak Up and Stop the Job – Each of us has the authority and responsibility to stop or not start, any work activity if hazards or risks pose a threat HSE.
• We Plan Ahead
• We Support Employees – We aim for our employees and their families to be healthy and feel empowered in and out of the workplace.
• We Continuously Improve – We will set, measure and review our HSE objective and targets.

Team Work and Protecting Against Harassment and Discrimination

Equal Employment Opportunity - It is our policy to comply with the employment laws, including employment discrimination laws, in each jurisdiction in which we do business. You are expected to respect the employment rights of others so there is no unlawful harassment, discrimination or retaliation in the conduct of our business.

Diversity and Respect - We value all employees as individuals for who they are, and we expect you to do the same. By respecting and valuing differences, we will enhance teamwork and build a competitive advantage.

Unlawful Harassment, Discrimination and Retaliation - NEWTLA SNS does not tolerate discrimination of any kind and we forbid any form of harassing behaviors among our employees, or by or against any of our customers, or third parties with whom we engage. NEWTLA SNS prohibits all forms of discrimination, including discrimination in employment, employment-related decisions, and business dealings. Discrimination includes any prejudicial treatment due to an individual’s race, color, ancestry, age, sex, sexual orientation, gender identity or expression, religion, disability, ethnicity, national origin, veteran status, marital status, pregnancy, or any other representation category that may be recognized locally.

If you encounter or become aware of unlawful harassment by anyone, including supervisors, fellow employees or customers, you must bring the issue to the attention of responsible NEWTLA SNS management. If the issue is with your direct supervisor, you should bring the complaint to the attention of that person’s supervisor or the President of Corporate Human Resources. NEWTLA SNS will investigate the matter and take appropriate action to end any unlawful harassment, discrimination or other inappropriate conduct found, including disciplining the offending individual, if appropriate.

To the extent practicable, the privacy of all persons involved will be respected and complaints kept confidential.

Accurate Financial Records, Effective Internal Controls & Record keeping practices

Accordingly, the integrity of our recordkeeping and reporting systems must be respected at all times. Our company records include routine documents such as time cards, expense reports, and test reports & other records, accounting entries, cost estimates and contract proposals. It is your responsibility to ensure the records and accounts under your care are accurate and supported. We also are required to maintain a system of internal accounting controls to ensure compliance with applicable laws, generally accepted accounting principles and NEWTLA SNS policies. The use of NEWTLA SNS assets for any unlawful purpose is prohibited.

No undisclosed or unrecorded NEWTLA SNS fund or asset shall be established for any purpose.

No false, artificial or misleading entries shall be made in the books and records of NEWTLA SNS for any reason. Any payments made or received by NEWTLA SNS, whether in cash or otherwise, must promptly and accurately be recorded on our books.

No payment on behalf of NEWTLA SNS shall be approved without adequate supporting documentation nor made with the intention or understanding that any part of such payment is to be used for any unlawful purpose.

If you have a doubt as to any practice or proposed course of conduct, you should consult with a superior before proceeding further.

All of our accounts must be clearly identified on our books and records in the name of the company entity.

All cash payments received must be promptly recorded on the books of account and deposited in an account maintained with a bank.

Prohibition of Acts Bribery

NEWTLA SNS prohibits any form of corruption. In this sense, the business partners are prohibited from giving or receiving undue payments of any kind, such as gifts, kickbacks or favors that violate the legal uses of the market or that, based on value, characteristics or circumstances, could reasonably be expected to alter the development of commercial, administrative or professional relations.

Competition and Conflict of Interest

As a consequence of the principle of ethical conduct and zero tolerance regarding any act of corruption, NEWTLA sns has the obligation to behave in a manner that is consistent with said principles in those matters where there may be a certain type of competition or direct or indirect conflict of interest, while taking the necessary measures to attempt to avoid making decisions affected by a possible conflict of interest.

Ethics Channel (Hotline)

NEWTLA SNS available to all associates, business partners, third/related party info@holtline.com with complete confidentiality.

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