Business Conduct

Adeva conducts business ethically, honestly, and in full compliance with applicable laws and regulations. This applies to every business decision in every area of the company.

Adeva’s Principles of Business Conduct

Adeva’s principles of business conduct define the way we do business. These principles are:

• We act with honesty, integrity and high ethical standards.
• We are transparent and candid, and we treat others with respect.
• We are responsible for keeping confidential information safe and secure.
• We honour our legal obligations and we are committed to following all applicable laws, rules and regulations.

Your Responsibilities

Adeva’s Business Conduct Policy and principles apply to employees, independent contractors, consultants, and others who do business with Adeva. You are expected to:

• Follow the policy. We must read, understand and comply with Adeva’s Business Conduct and all related company policies, principles and standards that apply to our daily work.
• Speak up. We all have an obligation to speak up about potential, suspected or actual violations of company policies or applicable laws.
• Ask questions. We must ask questions and seek advice if we are unsure about how to handle a situation or need guidance on where to find information.
• Raise Concerns. We are encouraged to raise concerns, even if they are difficult, and to ensure that our direct reports are comfortable raising issues.

Failure to comply with Adeva’s Business Conduct Policy, or failure to report a violation, may result in disciplinary action up to and including termination of employment or the end of your working relationship with Adeva.

Retaliation Is Not Tolerated

We are strictly prohibited from retaliating against anyone who seeks advice, raises a concern or reports misconduct.

Conflicts of Interest

A conflict of interest is any activity that is inconsistent with or opposed to Adeva’s best interest, or that gives the appearance of impropriety or divided loyalty. Avoid any situation that creates a real or perceived conflict of interest. Use good judgment, and if you are unsure about a potential conflict, talk to your manager or contact Human Resources. You shouldn’t use your position at Adeva to to obtain any favourite treatment for yourself or others with whom you have a significant relationship.

Outside Employment

Adeva employees must notify their manager before taking any other employment. In addition, any employee (full-time or part-time) who obtains additional outside employment or has an outside business must comply with the following rules.

Do not:

• Use any time at work or any Adeva assets for your other job or outside business. This includes using Adeva workspace, phones, computers, internet access, and any other Adeva assets or services.
• Use your position at Adeva to solicit work for your other employer or outside business.
• Participate in an outside employment activity that could have an adverse effect on your ability to perform your duties at Adeva.
• Use confidential Adeva information to benefit your other employer, or outside business.

Workspace Relationships

Personal relationships in the workplace may present an actual or perceived conflict of interest when one individual in the relationship is in a position to make or influence employment decisions regarding the other. If you find yourself in such a relationship, you must notify Human Resources so they may assist you in resolving any potential conflicts. Employees should not allow their relationships to disrupt the workplace or interfere with their work or judgement.

Harassment and Discrimination

Adeva encourages a creative, culturally diverse, and supportive work environment. Adeva is committed to providing a workplace free of discrimination and sexual harassment, as well as harassment or discrimination based on such factors as race, colour, creed, religion, sex, national origin, marital status, age, sexual orientation, gender identity characteristics or expression, genetic information, physical or mental disability, pregnancy, medical condition, or any other basis. Adeva will not tolerate discrimination or harassment of employees or non-employees with whom we have a business, service, or professional relationship. This applies to interactions with employees, customers, suppliers, and applicants for employment, and any other interactions where you represent Adeva.

If you feel that you have been harassed or discriminated against or have witnessed such behaviour, report the incident to any member of the Human Resources department, any supervisor or manager.

Confidential Employee Information

As part of your job, you may have access to personal information regarding other Adeva employees or applicants, including information regarding their employment history, personal contact information, compensation, health information, or performance and disciplinary matters. This information is confidential and should be shared only with those who have a business need to know. It should not be shared outside Adeva unless there is a legal or business reason to share the information and you have approval from your manager.

Public Speaking and Press Inquiries

All public speaking engagements that relate to Adeva’s business must be pre-approved by your manager. If you receive approval to make a public presentation at a business meeting or conference, you may not request or accept any form of personal compensation from the organisation that requested the presentation.

Drugs and Alcohol

Adeva cares about the health and safety of our employees. You are expected to comply with Adeva’s guidelines regarding alcohol, drugs, and smoking, whether it is in the workplace, at Adeva- sponsored events, or while conducting Adeva business. You are not permitted to be under the influence of any legal or illegal drug that impairs your ability to perform your job, and employees are prohibited from manufacturing, soliciting, distributing, possessing, or using any illegal drugs or substances in the workplace, or while working.

Protecting Adeva’s Assets and Information

At Adeva, we all have an obligation to protect Adeva’s property and to abide by the following guidelines:

• Watch what you say. Being aware of who is around you, and what they might learn from you is an important way we all protect Adeva’s secrets.
• Protect our stuff. Keeping track of Adeva assets and information entrusted to you, and preventing opportunities for loss, misuse, waste, or theft of Adeva property is everyone’s responsibility. Before disposing of Adeva assets, talk to your manager, get approval, and follow applicable policies.
• Set the example. Behaviours are contagious, so be a model for your co-workers and our partners. Follow our procurement procedures when acquiring goods or services, and use Adeva’s assets only for legal and ethical purposes.

Confidential Adeva Information

Never disclose confidential, operational, financial, or other business information without verifying with your manager that such disclosure is appropriate. Typically, disclosure of this information is very limited, and the information may be shared with vendors, suppliers, or other third parties only after a non-disclosure agreement is in place. Even within Adeva, confidential information should be shared only on a need-to-know basis.

The Adeva Identity and Trademarks

The Adeva name, names of products (such as Brysk), names of services (such as Joby), names of community spaces (such as The Hub), tag-lines (such as ”Enabling work without boundaries”), and logos (such as the familiar Adeva logo) collectively create the Adeva identity. Before publicly using the Adeva name, product names, service names, tag-lines, or the Adeva logo, review Adeva’s Corporate Identity Guidelines on how names and logos can be used and presented). Before using the product names, service names, tag-lines, or logos of third parties, check with the legal department.

Accuracy of Records and Reports

Accurate records are critical to meeting Adeva’s legal, financial, and management obligations. Ensure that all records and reports, including timecards, customer information, technical and product information, correspondence, and public communications, are full, fair, accurate, timely, and understandable.

Never misstate facts, omit critical information, or modify records or reports in any way to mislead others, and never assist others in doing so.

Records and Information Management

As an Adeva employee, you have a responsibility to manage records and information.

The definition of “records and information” is extremely broad. Information includes all documents and data; however, Records are a subset and must be kept because they have enduring business value, must be kept pursuant to other Adeva policies for legal, accounting and other regulatory requirements.

At times, Adeva may need to retain records and information beyond the period they would normally be kept. The most common reasons are litigation, other legal matters or audits.

Prevent Money Laundering

Money laundering is the process by which individuals or organisations try to conceal illicit funds or make these funds look legitimate. Money laundering is strictly prohibited. If you deal directly with customers or vendors, the following examples may be indications of potential money laundering:

• Attempts to make large payments in cash.
• Payments by someone who is not a party to the contract.
• Requests to pay more than provided for in the contract.
• Payments made in currencies other than those specified in the contract.
• Payments from an unusual, nonbusiness account.
• Transactions forming an unusual pattern such as bulk purchases of products or gift cards, or many repetitive cash payments.

Customer and Third-Party Information

Customers, suppliers, and others disclose confidential information to Adeva for business purposes. It is the responsibility of every Adeva employee to protect and maintain the confidentiality of this information. Failure to protect customer and third-party information may damage relations with customers, suppliers, or others and may result in legal liability.

Non-Disclosure/Confidentiality Agreements

When dealing with a supplier, vendor, or other third party, never share confidential information without your manager’s approval. Also, never share confidential information outside Adeva (for example, with vendors, suppliers, or others) unless a non-disclosure/confidentiality agreement is in place. These agreements document the need to maintain the confidentiality of the information. Original copies of non- disclosure agreements must be forwarded to the legal department. Always limit the amount of confidential information shared to the minimum necessary to address the business need.

Obtaining and Using Business Intelligence

Adeva legitimately collects information on customers and markets in which we operate. Adeva does not seek business intelligence by illegal or unethical means, and competitors may not be contacted for the purpose of obtaining business intelligence. Sometimes information is obtained accidentally or is provided to Adeva by unknown sources. In such cases, it may be unethical to use the information, and you should immediately contact your manager or the legal department, to determine how to proceed.

Your Obligation to Take Action

Always apply Adeva’s principles of business conduct, follow Adeva policies, and comply with laws and regulations. When you are unsure, take the initiative to investigate the right course of action. Check with your manager, Human Resources, Legal, Internal Audit, or Finance, and review our policies.

If you know of a possible violation of Adeva’s Business Conduct Policy or legal or regulatory requirements, you are required to notify your manager (provided your manager is not involved in the violation), Human Resources, Legal, Internal Audit or Finance. Failure to do so may result in disciplinary action.

Employees must cooperate fully in any Adeva investigation and keep their knowledge and participation confidential to help safeguard the integrity of the investigation.