Code Of Ethics &
Business Conduct

This code outlines Enetsec’s commitment to ethical business practices and legal compliance. All employees, contractors, and stakeholders are expected to uphold these standards to protect the company’s integrity and reputation.

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This document serves as a foundation for Enetsec Corporation’s ethical practices

Code of Ethics

Code of Ethics Code Of Ethics & Business Conduct

1. Anti-corruption & Anti-bribery Policy

Purpose: To prevent bribery and corruption in all forms within Enetsec’s business activities.

Policy overview
  • . Bribes: Offering, giving, or accepting bribes is strictly prohibited. This includes direct or indirect offers,such as through third parties.
  • . Gifts and benefits: Only modest gifts and hospitality that are appropriate and customary may be accepted. Gifts or benefits that could influence business decisions are prohibited.
  • . Facilitation payments: Small payments to expedite services are prohibited except when personal safety is at risk.
Procedures
  • . Due diligence: Employees must assess all third parties for potential corruption risks.
  • . Training: Annual anti-bribery training is mandatory.
  • . Reporting: Any suspicions should be reported to the Compliance Officer or through the anonymous whistleblower system.
2. Third-party Engagement Policy

Purpose: To ensure that third parties (e.g., suppliers, vendors, contractors) align with Enetsec’s ethical standards.

Policy overview
  • . Due diligence: All third parties undergo a background check and ethical assessment before engagement.
  • . Contract requirements: Contracts must outline obligations for compliance with laws and Enetsec’s Code.
  • . Audit rights: Enetsec reserves the right to audit third parties periodically.
Procedures
  • . Initial screening: Legal and compliance teams perform risk-based due diligence.
  • . Ongoing monitoring: Periodic reviews and evaluations are conducted.
  • . Remediation: Third parties failing to meet standards must remediate immediately or face termination of engagement.
3. Gifts & Hospitality Policy

Purpose: To prevent conflicts of interest through inappropriate gifts or hospitality.

Policy overview
  • . Permitted gifts: Only nominal gifts (under $100) appropriate to the business relationship are permitted without approval.
  • . Prohibited gifts: Cash or equivalents, personal benefits, or gifts that could influence decisions.
  • . Approval process: A manager must report and approve Gifts above the threshold.
Procedures
  • . Recordkeeping: All gifts and hospitality must be recorded with value, purpose, and recipient details.
  • . Review: Compliance conducts periodic reviews of gift and hospitality records.
4. Anti-Money Laundering (AML) Policy

Purpose: To detect and prevent Enetsec from being used for money laundering activities.

Policy overview
  • . Customer due diligence (CDD): Verify clients’ identity and source of funds.
  • . Transaction monitoring: Regular monitoring for suspicious transactions.
  • . Reporting: Suspicious Activity Reports (SARs) must be filed when unusual transactions are identified.
Procedures
  • . CDD process: KYC (Know Your Customer) checks are mandatory for all new clients.
  • . Ongoing monitoring: Enhanced due diligence for high-risk clients or transactions.
  • . Employee training: Mandatory AML training and certifications are required for relevant employees.
Fraud Prevention Policy

Purpose: To identify, prevent, and respond to fraudulent activities within Enetsec.

Policy overview
  • . Fraudulent Actions: Any fraud, such as asset misappropriation or document falsification, is strictly prohibited.
  • . Internal controls: Enetsec implements controls to safeguard company assets and ensure accurate reporting.
  • . Response to fraud: Any suspected fraud will trigger a formal investigation.
Procedures
  • . Reporting: Employees must report suspicions immediately via the confidential reporting system.
  • . Audit & controls: Regular audits of high-risk areas.
  • . Disciplinary action: Disciplinary actions up to termination are taken for confirmed fraud cases.
Reporting violations and whistleblower protection

Enetsec encourages employees to report breaches of this Code or its policies and provides an anonymous reporting mechanism to protect employees from retaliation.

Reporting channels
  • . Anonymous reporting line available 24/7.
  • . Email: compliance@enetsec.com
  • . Direct reporting: employees can report directly to the Compliance Officer.
Compliance

Violations of the Code or related policies will result in disciplinary measures, including termination or legal action.

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