CODE OF CONDUCT

Table of contents

Version 1.0 · Effective 2 November 2026

About this Code

In this Code, “ECOFACTOR”, “we” and “us” mean the companies operating under the ECOFACTOR brand: ECOFACTOR Sp. z o.o. (Poland), ECOFACTOR TECH UK LIMITED (United Kingdom) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Ukraine).

We supply EV charging equipment, develop and run charge point management software and operate public charging networks. Our customers, partners, public authorities and the drivers who use our chargers need to be able to trust us. This Code sets out the standards of behaviour that make that trust possible.

The Code applies to everyone who works for or on behalf of ECOFACTOR. We expect our suppliers and business partners to follow equivalent standards, as set out in our Supplier Code of Conduct.

Our values

  • Integrity — we act honestly and transparently in all our dealings.
  • Innovation — we build technology that makes EV charging smarter and more reliable.
  • Collaboration — we work as one team across countries, functions and partners.
  • Accountability — we take responsibility for our actions and their consequences.

Obeying the law

We comply with the laws of every country in which we operate, including Poland, the United Kingdom and Ukraine, and the other countries where we sell our products. Where local law sets a stricter standard than this Code, we follow local law. Where this Code is stricter than local law, we follow this Code. If you are unsure whether something is lawful, ask before you act.

Respect at work

  • We treat colleagues, customers, partners and the public with respect.
  • We do not tolerate harassment, bullying, intimidation or discrimination on any ground protected by law, including sex, age, disability, race, ethnic origin, nationality, religion or belief, sexual orientation and gender identity.
  • We make decisions on hiring, pay and promotion on merit.
  • We respect our people’s right to join or not to join a trade union or workers’ representation, as provided by law.
  • We never use forced, bonded or child labour. Our commitments are set out in our Human Rights Policy.

Health and safety

Charging equipment involves high voltage and work on public sites. Safety comes first.

  • Follow the safety rules, training and procedures that apply to your work.
  • Never work on electrical equipment unless you are qualified and authorised to do so.
  • Stop work if it is unsafe and report hazards, incidents and near misses promptly.
  • Take reasonable care of your own safety and that of others, including members of the public at our charging sites.

Product safety and quality

We place on the market only products that meet the safety and technical requirements that apply to them. We do not hide or play down product defects or safety issues. Anyone who becomes aware of a potential safety issue with an ECOFACTOR product must report it immediately.

Anti-bribery and corruption

We have zero tolerance for bribery and corruption. We never offer, promise, give, request or accept a bribe, kickback or improper advantage, whether directly or through a third party. We do not make facilitation payments. Gifts and hospitality must be modest, infrequent, transparent and never given or received in cash or during a tender. Full details are in our Anti-Bribery and Corruption Statement.

Conflicts of interest

Avoid situations where your personal interests, or those of people close to you, conflict with the interests of ECOFACTOR. Declare any actual, potential or perceived conflict to your manager before you take part in a related decision, for example:

  • a financial interest in, or a role with, a customer, supplier or competitor;
  • a family or close personal relationship with someone at a supplier, customer or public authority you deal with;
  • outside work that competes with ECOFACTOR or affects your duties.

Fair competition

We compete on the merits of our products and services. We do not agree prices, bids, customers or markets with competitors, we do not exchange competitively sensitive information with them, and we do not abuse any strong market position. In public tenders, we follow the procurement rules strictly and never seek inside information.

Sanctions and export controls

We comply with the sanctions and export control rules of the European Union, the United Kingdom, Ukraine and the United Nations, and with other sanctions regimes where they apply to us. We do not deal with sanctioned persons or entities and we do not supply our products, software or technology where this is prohibited, including in breach of the restrictive measures adopted in response to Russia’s war against Ukraine. We take proportionate steps to check our customers, partners and supply routes before we engage with them.

Money laundering, fraud and tax evasion

We deal only with legitimate business partners and funds. We do not take part in or facilitate money laundering, fraud or tax evasion, whether by ECOFACTOR or by anyone else. Report unusual payment requests, such as payments to third parties, to unrelated countries or in cash.

Honest communication and marketing

  • We describe our products, their capabilities and their limitations accurately.
  • Environmental claims must be specific, accurate and supported by evidence. We do not use vague claims such as “eco-friendly” or “green” without substantiation.
  • We do not make false or misleading statements about competitors.
  • Only authorised persons may speak to the media or make public statements on behalf of ECOFACTOR.
  • On social media, make clear that personal views are your own, and never share confidential information.

Data protection and confidentiality

  • We respect the privacy of our customers, drivers, employees and partners and handle personal data in line with applicable data protection law, including the GDPR, the UK GDPR and the Law of Ukraine “On Personal Data Protection”.
  • Use personal data only for the purpose for which it was collected and access only the data you need for your work.
  • Protect confidential information of ECOFACTOR and of our customers and partners. This duty continues after your work with us ends.
  • Report suspected data breaches immediately to info@ecofactor.eu.

Company assets and information security

Use ECOFACTOR equipment, systems, software, intellectual property and funds only for legitimate business purposes. Do not bypass security controls, share passwords or access systems or data you are not authorised to use. Our charge point management system and charging network are connected infrastructure: report any security weakness or suspicious activity immediately.

Accurate records

Our books, records, reports and tender submissions must be complete, accurate and honest. Never create false or misleading entries, hide transactions or destroy records that must be kept.

Environment

We aim to reduce the environmental impact of our operations and products and comply with environmental law in every country where we operate. Our commitments are set out in our Environmental Policy.

Speaking up

If you see or suspect a breach of this Code, the law or our policies, speak up. You can talk to your manager or report through our speak-up channel at info@ecofactor.eu, including anonymously. Details are on our Report a Concern page (https://ecofactortech.com/legal/report-a-concern/). We do not tolerate retaliation against anyone who raises a concern in good faith.

Consequences of breach

Breaches of this Code may lead to disciplinary action, up to and including dismissal, or to termination of a contract with a contractor or business partner, in line with applicable law. Some breaches are also criminal offences and may be reported to the authorities.

Responsibility and review

The management of each issuing company is responsible for applying this Code within its company. Managers must lead by example and make sure their teams know the Code. This Code is reviewed at least once a year and whenever our activities or the law change materially.

Document control

Version 1.0 · Effective 2 November 2026 · Owner: Legal (in-house) · Approved by: adopted by ECOFACTOR Sp. z o.o. (Management Board), ECOFACTOR TECH UK LIMITED (directors) and ТОВ «ЗАРЯДНІ МЕРЕЖІ» (Director)