Threod Code of Business Conduct

1. Why we have this Code

Threod Systems AS and all subsidiaries or companies belonging to the same group (hereinafter Threod) commit to this behavioural rulebook that translates core values into actionable, day-to-day guidelines. Threod Code of Conduct exists to clarify behavioural expectations, prevent misconduct, to ensure a safe, unified, and legally compliant workplace.
At Threod, how we work matters as much as what we build.
We operate in a field where trust, reliability and responsibility are essential. Our customers, partners, colleagues and communities rely on our judgment, professionalism and integrity.
This Code sets out the standards that guide our decisions and behaviour. It provides a practical framework for acting with integrity, exercising sound judgment and raising concerns whenever a situation appears unclear, unsafe or inconsistent with our values.

2. Who this Code applies to

This Code applies to everyone working for or on behalf of Threod, including employees, managers, board members, contractors, consultants and trainees.
We also expect our suppliers, partners and representatives to uphold the same standards.
Every business decision should reflect integrity, safety, legality and professional responsibility.

3. Our values

At Threod, our values shape how we work with each other and how we conduct business.
Stay curious: We ask questions, explore new ideas and create solutions beyond the obvious.
Mind your words: We speak truthfully, keep our word and communicate in a clear and considered way.
Show respect: We treat people with dignity, fairness and professionalism.
Take ownership: We take responsibility for our decisions and actions, and we act with care in everything entrusted to us.

When facing a difficult decision, ask:
• Is it legal?
• Is it honest?
• Is it consistent with our values?
• Would I be comfortable if it became public?
Where the answer remains unclear, pause and seek guidance.

4. Equal treatment, diversity and workplace conduct

We promote a respectful, inclusive and professional work environment where people can contribute and perform effectively while being themselves.
We treat everyone with dignity, fairness and respect. In all employment-related decisions, including recruitment, remuneration, training, promotion and task allocation, we rely on equal treatment and objective, fair criteria.
We value diversity and maintain a workplace culture where people are treated with consideration across differences in race, religious beliefs, political opinions, sex, age, national origin, mother tongue, sexual orientation, neurodiversity, marital or partnership status, disability or other comparable characteristics.
We recognise that people may communicate, process information, interact socially and organise their work in different ways. We therefore encourage clear, respectful and inclusive communication practices and reasonable flexibility in working methods where appropriate.
We communicate in line with generally accepted standards of courtesy and professional conduct. We also refrain from discrimination, harassment, bullying, intimidation, physical or verbal violence, threats and any form of punishment.

5. Human rights and labour standards

We respect and apply internationally recognised human rights and conduct our business in a lawful and responsible manner.¹
We ensure that our actions remain fully separate from any contribution to, support for, or concealment of human rights violations in any part of Threod’s operations or value chain. We uphold lawful and fair working conditions throughout our operations and expect the same approach in our business relationships.
Child labour forced or compulsory labour, human trafficking, and every form of unlawful labour exploitation are incompatible with our values and standards. We refrain from any conduct that could contribute to, support or conceal such practices, and we act in accordance with applicable labour laws and internal policies.

6. Health, safety and security

Safety and security form part of professional conduct at Threod. We are all responsible for contributing to a safe, secure and healthy working environment.
We follow applicable health, safety and security requirements, use equipment and facilities responsibly, protect our working environment, and report hazards, incidents and near misses without delay. Where risks are identified, we take appropriate and timely action.
When visiting customer, supplier or partner facilities, we comply with all local security regulations, safety protocols and site-specific instructions. We respect local customs, including appropriate dress codes and social norms, and maintain a neutral, professional stance at all times. We keep company and partner equipment secure, use workspaces responsibly, and leave every workspace in its original, tidy condition.
Pressure, deadlines, or convenience should never outweigh safety or security. Where a risk appears, it should be addressed promptly and responsibly.

7. Environment and sustainability

We recognize that environmental responsibility forms part of responsible business conduct.
In the development of products and in the operation of our facilities, we seek to keep environmental impact as low as reasonably possible. We use energy, materials and other resources with care, comply with applicable environmental requirements and take environmental considerations into account in our decisions and day-to-day work.
We also encourage responsible environmental practices in our business relationships and support technology and innovation that contribute to more sustainable solutions.

8. Conflicts of interest

We identify, avoid and appropriately manage situations where personal interests interfere, or appear to interfere, with the interests of Threod.

A conflict of interest may arise from personal relationships, outside working place and hours financial interests, side businesses or the use of company information or position for personal benefit.
Examples include:
• involvement in decisions concerning family members or close associates
• a financial interest in a supplier, customer or competitor
• use of internal information for personal gain
• giving or receiving advantages that influence business judgment

A potential conflict may arise without wrongdoing, yet it should always be disclosed promptly so it can
be assessed and handled properly.

Employees must promptly disclose any actual, potential or perceived conflict to their manager or the
appropriate company representative.

9. Gifts, hospitality and anti-corruption

Threod stands for clean and honest business.
We reject bribery, improper benefits and every form of corrupt conduct. Our decisions and business relationships must remain fair, lawful and free from improper influence.
Gifts and hospitality must be modest, lawful, infrequent and appropriate to the business relationship. They should reflect good judgment and should never create a sense of obligation or appear to influence independent judgment. Cash or cash equivalents are unacceptable.
Particular care is required in dealings involving public authorities, defence-related transactions, intermediaries, agents and international business partners.
Any offer, request or arrangement that could be perceived as improper must be declined and promptly reported to the appropriate manager or compliance representative.

10. Fair dealing and fair competition

We compete honestly and lawfully.
We deal fairly and in good faith with customers, suppliers, partners, competitors, and public authorities. We present information truthfully and make business decisions fairly and honestly.
We also follow competition laws. We avoid unlawful agreements and avoid sharing sensitive market information with competitors.

11. Confidentiality and data protection

Many people trust us with sensitive information. We protect that trust.
We protect Threod’s trade secrets and other confidential information obtained through our work. We also respect the confidential information of customers, partners and other third parties.
We access, use and share confidential information solely for legitimate business purposes and only with authorised persons. The detailed content of this obligation is defined in employment agreements, non-disclosure agreements and applicable laws and regulations.
We handle personal data carefully, securely and in accordance with applicable law.

12. Information security and IT use

We are committed to ensuring the confidentiality, integrity and availability of our information, systems
and technologies.
More detailed requirements are set out in our internal IT and cybersecurity policies, including rules on password management, access controls and data handling. In our day-to-day work, we:
• protect company systems, networks and data from unauthorised access, disclosure, alteration or loss
• use company IT resources, including devices, networks and software, responsibly and solely for authorised purposes
• handle sensitive information, including technical data and defence-related information, securely and share it solely with authorised persons
• protect credentials, use approved tools and report any suspected breach, weakness or loss without delay

13. Sanctions, export control and international trade compliance

Because of the nature of our business, compliance with sanctions, export control and related trade rules is essential.
We conduct all activities on behalf of Threod in compliance with applicable sanctions, export control laws, embargoes and other trade restrictions.
We make sure that all transactions, shipments, transfers of technology and services are permitted under applicable EU, Estonian and other relevant jurisdictions’ sanctions and export control regimes. We also verify that customers, suppliers, intermediaries and other counterparties are free from applicable sanctions or restrictions.
We ensure that end-users and end-use are lawful and consistent with export control requirements. We remain attentive to warning signs, including unusual payment structures, unclear end-use, or requests to route goods through third countries without clear business justification, and we escalate such concerns promptly.
We refrain from participating in arrangements designed to circumvent or obscure the true end-user, end-use or destination of products or services.

14. Company assets and resources

We are responsible for using company assets carefully, lawfully and for legitimate business purposes. This includes physical property, equipment, systems, materials, funds, intellectual property, information and working time.
We protect assets from loss, theft, damage, waste and misuse. We also respect the property and assets of customers, suppliers and partners entrusted to us.

15. Public communication

Threod values professional knowledge, thoughtful public discussion and the open sharing of expertise. We encourage our people to contribute to their fields, share insights and reflect the company’s culture in a professional way, while keeping confidentiality, security and Threod’s legitimate interests in mind.
Public statements on behalf of Threod, especially on official positions, commercial matters, customers, partners, projects or media inquiries, are made only by authorised persons or in coordination with the appropriate internal contact.
Where a matter falls outside a person’s authorisation, it should be referred to the appropriate authorised representative. We also protect internal information and ensure that public communication remains truthful, responsible and aligned with Threod’s professional standards.

16. Speaking up

At Threod, raising concerns forms part of how we work.
Where something appears wrong, unsafe or inconsistent with our values, raise it promptly. In many cases, the best place to start is with your manager. You may also turn to HR, management or another reporting channel provided by the company.
Speaking up helps us address issues early, learn from mistakes and protect the trust we build with each other and with others.
People who ask questions, share concerns or help clarify a situation in good faith should feel supported in doing so.

17. Responsibility and consequences

We are all responsible for following this Code.
Managers carry an additional responsibility to lead by example, support good judgment and create an environment in which everyone feels valued and able to speak openly.
Where conduct falls short of this Code, the situation will be addressed fairly and in line with its seriousness.

18. Final note

This Code is built on a simple principle:
Act with integrity, even when circumstances are difficult. Where the right path feels unclear, rely on our
values, seek guidance and use sound judgment.
By doing so, we protect each other, maintain trust, support responsible high-quality decisions and the integrity of our work against poor judgment, unnecessary risk and preventable harm.