Prohibited Conduct

Aevum Zenth maintains a zero-tolerance policy toward bribery, corruption, and improper payments. All forms of illicit facilitation are strictly prohibited, regardless of jurisdiction, amount, or cultural context.

• ✕ Offering, promising, authorizing, or providing any bribe, kickback, or improper gratuity to any government official, business associate, or private individual to influence a decision or obtain an improper advantage.
• ✕ Soliciting or accepting bribes, kickbacks, or facilitation payments in any form, including cash, gifts, entertainment, travel, or favors.
• ✕ Using charitable donations, sponsorship, or third-party intermediaries as a vehicle for improper payments or to circumvent anti-corruption laws.
• ✕ Falsifying records, invoices, or documentation to conceal corrupt transactions or create the appearance of legitimate business dealings.
• ✕ Engaging in political contributions or lobbying activities that violate applicable laws or create the appearance of undue influence over regulatory decisions.

All personnel must act in the best interest of Aevum Zenth at all times. Any personal, financial, or professional interest that could compromise—or appear to compromise—impartial judgment is prohibited unless formally disclosed and approved.

• ✕ Engaging in outside business activities or employment that compete with, are related to, or detract from duties to Aevum Zenth without prior written approval.
• ✕ Accepting gifts, entertainment, or hospitality from vendors, suppliers, or partners that could reasonably influence business decisions, except as permitted under the Gifts & Hospitality Policy.
• ✕ Awarding contracts, procurement decisions, or business opportunities to entities in which the employee, their family members, or close associates hold a financial interest.
• ✕ Holding board positions, equity stakes, or advisory roles in organizations that could create competing loyalties.
• ✕ Using position within Aevum Zenth to advance personal financial interests or those of family members, friends, or affiliated organizations.

Aevum Zenth is committed to maintaining a workplace free from harassment, discrimination, and hostile conduct. All personnel have the right to work in an environment of dignity and respect.

• ✕ Engaging in or permitting harassment of any kind, including sexual harassment, verbal abuse, physical intimidation, stalking, or hostile workplace behavior.
• ✕ Discriminating in hiring, promotion, compensation, assignment, or termination based on race, color, religion, sex, national origin, age, disability, sexual orientation, gender identity, veteran status, or any other protected characteristic.
• ✕ Retaliating against any individual who reports harassment, participates in an investigation, or supports a complainant.
• ✕ Making derogatory comments, displaying offensive materials, or engaging in conduct that creates a hostile or intimidating work environment.
• ✕ Tolerating or ignoring harassment or discrimination by colleagues, subcontractors, clients, or visitors to Aevum Zenth facilities.

All financial activities must be conducted with the highest standards of integrity, accuracy, and transparency. Manipulation of financial records or systems is strictly prohibited.

• ✕ Recording or approving false, misleading, or unsupported transactions, invoices, or expense reports.
• ✕ Establishing off-book accounts, shell entities, or undisclosed subsidiaries to conceal financial activities.
• ✕ Manipulating financial statements, accounting entries, or reporting to misrepresent the financial condition of any Aevum Zenth entity.
• ✕ Approving expenditures without proper authorization, supporting documentation, or business justification.
• ✕ Failing to maintain accurate records as required by applicable law, accounting standards, or Aevum Zenth internal controls.

The unauthorized access, disclosure, misuse, or destruction of data is strictly prohibited. All personnel must comply with applicable data protection laws and Aevum Zenth's Information Security Policy.

• ✕ Accessing, copying, transmitting, or disclosing personally identifiable information (PII), protected health information (PHI), or confidential business data without authorization or legitimate business need.
• ✕ Sharing passwords, bypassing access controls, or assisting others in circumventing information security measures.
• ✕ Using Aevum Zenth systems, networks, or devices for unauthorized purposes, including the installation of unapproved software or the storage of sensitive data on personal devices.
• ✕ Failing to report suspected data breaches, security incidents, or unauthorized access to the Information Security team within 1 hour of discovery.
• ✕ Disclosing proprietary technology, trade secrets, research findings, or confidential business strategies to unauthorized parties or competing organizations.

Aevum Zenth's physical, intellectual, and financial assets are to be used solely for legitimate business purposes. Theft, waste, and unauthorized personal use are prohibited.

✕ Stealing, embezzling, or converting company funds, equipment, inventory, or property for personal use or the benefit of unauthorized parties.
• ✕ Misusing company credit cards, expense accounts, or procurement systems for unauthorized purchases.
• ✕ Wasting company resources through gross negligence, including excessive personal use of facilities, technology, or travel benefits.
• ✕ Using company intellectual property, proprietary technology, or research results for personal gain or to benefit a competing organization.
• ✕ Failing to protect company assets from theft, damage, or unauthorized access through reasonable care and diligence.

All personnel must comply with applicable occupational health and safety regulations. No production target, financial goal, or operational pressure justifies compromising worker safety.

• ✕ Operating machinery, equipment, or vehicles without proper training, certification, or authorization.
• ✕ Failing to report unsafe conditions, near-misses, injuries, or hazardous exposures to the appropriate safety officer.
• ✕ Disabling, bypassing, or modifying safety interlocks, guards, ventilation systems, or protective equipment.
• ✕ Performing tasks under the influence of alcohol, illegal substances, or prescription medications that impair judgment or physical coordination.
• ✕ Pressuring or directing colleagues to violate safety procedures or to perform tasks without required personal protective equipment (PPE).

Aevum Zenth is committed to environmental stewardship and regulatory compliance across all operations. Deliberate environmental harm or regulatory circumvention is strictly prohibited.

• ✕ Illegally discharging, dumping, or releasing hazardous materials, wastewater, or emissions into the environment.
• ✕ Falsifying environmental permits, monitoring data, compliance reports, or testing results submitted to regulatory authorities.
• ✕ Failing to properly store, handle, transport, or dispose of hazardous substances in accordance with applicable laws and Aevum Zenth environmental standards.
• ✕ Concealing environmental incidents, spills, or contamination events from regulatory bodies, local communities, or Aevum Zenth's Environmental Compliance team.
• ✕ Operating in ecologically sensitive areas or extracting natural resources in violation of conservation laws, protected land designations, or indigenous land rights.

As a publicly traded conglomerate with securities listed on multiple exchanges, Aevum Zenth prohibits the misuse of material non-public information (MNPI) for securities trading or the tipping of others.

• ✕ Buying, selling, or recommending securities of Aevum Zenth or any affiliated entity while in possession of material non-public information.
• ✕ Providing MNPI to family members, friends, investment advisors, or any third party who may trade on that information ("tipping").
• ✕ Trading during designated blackout periods as defined by the Insider Trading Policy and trading window schedule.
• ✕ Failing to file required insider transaction reports (Form 4 or equivalent) within the mandated timeframe.
• ✕ Attempting to exploit MNPI through hedging transactions, options strategies, or transactions through intermediaries.

Fraudulent conduct undermines trust, exposes the organization to legal and financial risk, and is grounds for immediate disciplinary action.

• ✕ Submitting false, misleading, or fraudulent applications, claims, certifications, or representations to clients, regulators, government agencies, or business partners.
• ✕ Falsifying employment credentials, qualifications, background information, or professional licenses on employment applications or in performance records.
• ✕ Misrepresenting product capabilities, service standards, compliance status, or corporate performance in sales materials, press releases, investor communications, or public statements.
• ✕ Colluding with other bidders, suppliers, or organizations to manipulate pricing, procurement processes, or competitive outcomes.
• ✕ Falsifying time records, attendance logs, or productivity metrics to obtain unauthorized compensation or benefits.

Retaliation against individuals who report concerns, participate in investigations, or exercise their legal rights is itself a serious violation. Aevum Zenth maintains a strict non-retaliation policy.

• ✕ Taking adverse employment action (termination, demotion, reduced hours, undesirable reassignment, performance penalties) against anyone who has reported or participated in the investigation of a potential violation.
• ✕ Intimidating, threatening, harassing, or ostracizing individuals who raise concerns about compliance, ethics, or safety issues.
• ✕ Encouraging, directing, or pressuring others to retaliate against whistleblowers or cooperative witnesses.
• ✕ Retaliating against individuals who refuse to participate in unlawful or policy-violating conduct, even when directed by a supervisor or manager.
• ✕ Disclosing the identity of a whistleblower or complainant without their consent, except as strictly necessary for investigation purposes and authorized by the Compliance Office.

Aevum Zenth requires all personnel to report suspected violations of this policy or other misconduct promptly. Good-faith reports are protected and will never be used as the basis for adverse action.