Purpose and Commitment

At Vertel Corporation the Code of Conduct and Business Ethics serves as the foundation for all personal and professional actions. It outlines the standards of behavior expected of every member of the organization regardless of rank location or function. Our commitment is to build a workplace and a brand based on respect integrity and transparency. These values are not optional but essential to our collective success and reputation.

Scope of Application

This policy applies to all employees members of the Board of Directors senior executives interns contractors suppliers consultants and any third parties acting on behalf of Vertel Corporation or its subsidiaries. It applies equally across all sectors of operation including construction entertainment and finance and across all countries where Vertel maintains a presence.

Ethical Decision-Making Framework

Employees and representatives of Vertel are expected to exercise sound judgment and make decisions that reflect the values and principles of the organization. When faced with uncertainty individuals should ask themselves whether the action complies with the law aligns with company values would be publicly acceptable and would stand up to scrutiny by regulators clients and peers. When in doubt they are encouraged to seek guidance from supervisors legal counsel or compliance officers.

Integrity and Personal Responsibility

All Vertel personnel must act honestly and in good faith in all matters concerning the company. Dishonesty including falsification of documents misrepresentation of facts or theft of any kind is strictly prohibited. We value accountability and expect every individual to take ownership of their behavior. Compliance with internal rules and external laws is non-negotiable and applies to all aspects of work including recordkeeping procurement reporting and client interaction.

Conflicts of Interest

Employees must not allow personal interests to interfere with their professional duties. A conflict of interest arises when an individual’s private relationships activities or financial interests may compromise or appear to compromise their loyalty to Vertel. All potential conflicts must be disclosed to the relevant department or compliance team. Examples include personal business ventures competing with Vertel accepting gifts from vendors or making hiring decisions based on familial relationships. Vertel maintains procedures for the proper disclosure review and management of such conflicts.

Anti-Corruption and Bribery

Vertel maintains a global zero-tolerance policy on corruption bribery kickbacks and improper influence. No one may offer give request or accept any form of bribe whether in cash services favors travel or gifts that could be perceived as influencing a business outcome. This standard applies to all government officials clients suppliers contractors and third parties. The company maintains anti-corruption training audit trails and internal control measures to prevent and detect violations. Any suspected breach must be reported immediately.

Fair Competition and Legal Compliance

Vertel respects and adheres to all laws governing fair competition and market conduct in every jurisdiction where we operate. Employees must avoid anti-competitive behavior such as collusion price fixing bid rigging or misuse of trade secrets. We comply with international sanctions and export control laws and ensure that our operations do not support unlawful or unethical activities in any form.

Respect for Diversity and Inclusion

Diversity in background experience and thought is a strength that drives innovation and collaboration. Vertel is committed to creating a respectful inclusive and non-discriminatory work environment. Harassment abuse intimidation and bias of any kind are unacceptable. We promote equal access to opportunities and resources regardless of age race gender identity religion disability sexual orientation or nationality. Any report of discrimination or harassment is treated seriously and addressed with discretion and fairness.

Confidentiality and Information Protection

Information is one of Vertel’s most valuable assets. Employees must safeguard confidential proprietary and sensitive information relating to the company clients partners and employees. Sharing such information internally or externally without authorization is prohibited and may lead to disciplinary or legal consequences. Confidentiality obligations extend beyond the term of employment. Employees are also required to use company resources such as emails databases and documents appropriately and for business purposes only.

Responsibilities of Managers and Executives

Leaders at Vertel bear a heightened responsibility to model ethical behavior and foster a culture of compliance and openness. They must ensure that their teams understand and apply this Code in daily operations. Managers should make themselves available for questions concerns and ethical discussions and they are accountable for identifying and addressing risks within their departments.

Reporting and Whistleblower Protection

Vertel maintains formal procedures for reporting suspected ethical violations or misconduct. Reports may be made anonymously through internal channels or whistleblower hotlines. The company strictly prohibits retaliation against anyone who raises concerns in good faith. Each case is investigated promptly and thoroughly. The identity of whistleblowers is kept confidential to the extent permitted by law. Vertel ensures that corrective action is taken when violations are confirmed and uses those learnings to improve controls.

Continuous Improvement and Training

Ethical conduct is not a one-time obligation but a continuous responsibility. Vertel conducts regular training sessions on ethics and compliance across all departments. The Code of Conduct is reviewed annually and updated in accordance with new legal requirements societal expectations and operational realities. All personnel are required to acknowledge and understand the current version of the policy and to act as ambassadors of our ethical culture.