Scope and Adherence to the Code

This code of conduct is to demonstrate our commitment to ensuring everything is measured against the highest standards of ethical business conduct and that we are respectful, open and honest. We expect all of our employees and Board members to know and uphold our values and guidelines described in this document. Failure to do so can result in disciplinary action, including termination of employment. We also expect members of our extended workforce such as contractors or temporary staff and contractors to follow the Code in connection with their work for us and we reserve the right to terminate our relationship if they fail to do so. We encourage people to speak up, share their views, make suggestions and voice any concerns or suspicions about anyone’s conduct or instances where there may be non-compliance with our code of conduct or the law and report any potential misconduct to their line manager, our quality assurance team, and our HR team immediately to allow those concerns and suspicions to be promptly investigated and responded to. Reported concerns by employees are kept confidential and we protect our employees against retaliation. Employees will never be penalised for compliance with these policies and procedures, even if we lose business or money as a result. Everybody must take personal responsibility for abiding with this code of conduct and this includes our most senior managers and directors, who take a personal interest in these matters.

Prevention of Bribery and Corruption

Xenkom aims to be successful in a freely competitive market. Every successful offer must come about honestly and be lawful. Therefore, we will deal with any instance of suspected bribery or corruption seriously and operate a zero-tolerance policy toward bribery and corruption and report illegal patterns of behaviour. It is our policy to comply with all laws, rules and regulations governing bribery and corruption in Bangladesh. Any actual instance will result in disciplinary action against those involved, up to and including termination of employment or contract, and reporting of those persons to relevant regulatory and criminal authorities. This policy extends to all of our business dealings and transactions in all countries in which we and/or our subsidiaries and associates operate. Bribery is the offering, promising, giving or accepting of any undue pecuniary or other advantage or by another person such as but not limited to a public official, at national, local or international level, a political party, party official or candidate, and a director, officer, employee or agent of another organisation or an individual in order to obtain or retain a business or other advantage other than by legitimate and proper means. Each employee is personally responsible for compliance with the prohibition of corruption and bribery and their respective group guidelines. Employees must report behaviour patterns which breach the prohibition of corruption and bribery and other provisions, or relevant suspicious facts without delay. Employees submitting these reports do not risk being disadvantaged in any way unless the report is submitted improperly and without good cause. Sponsoring or donations to non-political organisations for deserving causes must be transparent but not in expectation of any rewards or with the aim of influencing pending actions.

Confidentiality and Conflicts of Interest

Confidential information consists of any information that is not, or not yet, public. It includes trade secrets, scientific data, business, marketing and service plans, consumer insights, engineering and manufacturing ideas, product recipes, designs, databases, records, employee personal information, salary information or any other non-published financial details or data. Xenkom’s continued success depends on the use of its confidential information and its non-disclosure to third parties. Unless authorised by management or required by law, employees shall not disclose confidential information. To the extent that confidential information needs to be disclosed to third parties, it must be appropriately protected by, i.e. non-disclosure agreements reviewed by the legal function within the organisation. This obligation will continue beyond termination of employment. Employees must use their best efforts to avoid unintentional disclosure by applying special care when handling, storing or transmitting confidential information. We also expect members of our extended workforce such as contractors or temporary staff and contractors to follow the Code in connection with their work for us and we reserve the right to terminate our relationship if they fail to do so. Xenkom respects that third parties have a similar interest in protecting their confidential information. In case third parties, such as suppliers or customers, share confidential information with Xenkom, such information shall be treated with the same care as if it was Xenkom's confidential information. If an individual not normally involved in customer interactions is required to give a presentation or update on the company to an external party only the most recent and approved company presentation materials are permitted for use.

Use of Company Resources

Employees must behave honestly, respect company assets and never engage in fraudulent or dishonest conduct involving the assets or the financial reporting of the company or any third party. Any such conduct may not only entail disciplinary sanctions but may also result in criminal charges. Xenkom’s financial records are the basis for managing our business and fulfilling its obligations to various stakeholders therefore any financial record must be accurate and in line with our accounting standards. Employees shall safeguard and only make proper and official use of our assets. All employees must seek to protect our assets from loss, damage, misuse, theft, fraud, embezzlement and destruction. These obligations cover both tangible and intangible assets including trademarks, know how, confidential or proprietary information and information systems. To the extent permitted under applicable law Xenkom reserves the right to monitor how its assets are used by employees including inspection of email and any other data kept on the company's network terminals. When in doubt, employees should consult their manager, the finance dept or HR as appropriate.

Data Protection

Xenkom complies with the legal provisions governing how we deal with commercial and personal data. Large quantities of data are collected in both written and electronic form in our company. They include among others, commercial customer and supplier data as well as personal data from current and former employees. Both the company and its employees exercise the greatest degree of care in dealing with this data. Employees involved in the processing of personal data must comply with the following rules in doing so: • the processing of personal data must be fair and lawful and also be for specific and legitimate business purposes. • It should be properly managed. Personal data must be protected against unauthorised access, processing and damage.

Health & Safety

The safety of our employees and third parties is of the highest priority to Xenkom . We strictly comply with all company and government health and safety principles and so create a healthy safe and motivating working environment with the aim of preventing injuries and accidents. Meanwhile, we ensure that we know what to do if an emergency occurs at our workplace. It is prohibited to work while impaired or intoxicated by legal or illegal substances including alcohol or prescription medications and drugs. Report any observations that may compromise health & safety, however severe, to your management immediately. Inform your line manager, safety officer or HR manager about all breaches injuries and accidents according to the company health and safety policy. Xenkom expects all employees to observe and respect the laws of the legal system applicable in each jurisdiction as well as complying with all internal policies, directives and guidelines. Every member of staff must be aware that a violation can lead to sanctions under penal or liability law and disciplinary consequences through to dismissal.

Laws and Internal Rules

It is therefore important that everyone knows the laws and the internal relevant for their sphere of work. In case of doubt, employees can consult their superiors, legal department or the local management team. If you are encouraged or forced into illegal behaviour by competitors or a supplier you must distance yourself from this immediately and inform senior management. Above all, managers have an important role model function and must set an example through their personal conduct. They are responsible for avoiding any violation of laws in their areas of responsibility that could have been prevented by proper information and supervision.

Obligation of Partners

Xenkom expects its partners (namely manufacturers, service providers and suppliers) to make an active contribution to implementing the contents of our code of conduct. We do not tolerate any illegal or irregular behaviour by us our suppliers. Our suppliers are also to comply strictly with the prohibition of bribery and corruption. We expect our suppliers to have suitable programmes for environment, occupational health and safety, risk management and compliance. We also expect our suppliers to comply with the fundamental employee and human rights contained in international conventions programmes and standards. In particular, this includes the prohibition of child and slave labour.

Responsibility and Role Models

Xenkom’s reputation is recognized by customers and suppliers. That is why every employee is expected to promote the good name of Xenkom – everywhere and at all times are expected to act as role models. Above all, our managers must set an example through their personal conduct and are expected to act as role models. They are responsible for fully complying with all laws in their sphere of responsibility through proper handling of information and supervision but also by taking decisions or conducting activities that are consistent with Xenkom’s values of honesty, fairness and respect.