CODE OF CONDUCT

Anti-Corruption, Anti-Bribery & Interaction with Public Officials

Atreus Global is committed to conducting business with the highest standards of integrity, transparency, and accountability. This Code of Conduct establishes the principles and guidelines related to Anti-Corruption, Anti-Bribery, and Interaction with Public Officials. This policy applies to all employees, management, consultant, advisors, vendors, and third parties acting on behalf of the Company.

Anti-Corruption & Anti-Bribery Commitment

Atreus Global strictly prohibits all forms of corruption and bribery, whether direct or indirect.
Employees and representatives must not:

• Offer, promise, give, or authorize any form of bribe
• Request, accept, or receive any improper advantage
• Facilitate unofficial payments (including facilitation payments)
• Engage in any activity that may create the appearance of improper influence

Gifts, Hospitality & Entertainment

Atreus Global strictly prohibits all forms of corruption and bribery, whether direct or indirect. Employees and representatives must not:

• Are not excessive in value or frequency, or create any improper obligation
• Are not intended to influence a business decision
• Do not create the impression of bias in any business transaction
• Comply with all applicable laws and regulations

Employees must seek approval in accordance with internal procedures before offering or accepting gifts or hospitality.

Political Activities

The Company respects employee’s political rights in accordance with applicable laws, provided such activities do not affect the Company’s reputation or business operations. Employees are strictly prohibited from:

• Using Company funds or resources for personal political activities
• Seeking reimbursement for political contributions or involvement

The Company complies with all applicable laws on political contributions, lobbying, and interactions with public officials. Company resources must not be used for political purposes unless explicitly permitted by law and authorized by the Company. Any suspected misuse of Company resources for political activities must be reported to the employee’s supervisor.

Conflict of Interest

A conflict of interest occurs when personal interests interfere with the interests of the Company. Employees must:

• Avoid involvement in decisions where a conflict exists
• Disclose any external roles, relationships, or affiliations that may create a conflict
• Inform their supervisor of any close relations working with or for the Company
• Obtain approval before accepting external positions or roles

All potential conflicts must be promptly disclosed and properly managed.

Reporting & Whistleblowing

All employees are encouraged to report any suspected violations of this Code of Conduct. Reports can be made through:

• HRGA & Compliance
• Whistleblowing Channels (Email, Website, WhatsApp)

Reports should be made in good faith and include relevant details. The Company will maintain confidentiality, protection against retaliation, keep the reporting person informed where possible, and handle all reports appropriately.

Consequences of Violation

Any violation of this Code may result in:

• Disciplinary action (including termination)
• Legal consequences in accordance with applicable laws

Responsibility & Compliance

All employees are responsible for:

• Understanding this Code
• Complying with its requirements
• Completing any required training

Management is responsible for:

• Promoting a culture of integrity
• Ensuring enforcement of this policy

Atreus Global believes that ethical business conduct is fundamental to sustainable growth and long-term success. All employees and stakeholders are expected to uphold these principles and contribute to a transparent and corruption-free business environment.