The following Code of Conduct and Ethics Policy applies to all agents, employees, contractors, interns and volunteers of Mangosat, referred to as “members”.

Mangosat’s foundation is based upon the trust which our clients and employees have in the performance and integrity of Mangosat. Such trust depends on the personal conduct and capability of our agents and staff and their desire to jointly create value for our clients and business partners. The following principles represent the minimum standard for our agents and staff.

Conduct of Business: Members must comply with all applicable laws, rules, and regulations when conducting business. Members must conduct themselves with honesty, fairness, dignity, and integrity, and should avoid any conflict between private and business interests. Members should take care that they conduct themselves in their private life in a manner that does not bring Mangosat into disrepute.

Human Rights and Labor Practices: To ensure respect of all internationally proclaimed human rights by avoiding causation of and complicity in any human rights violation, heightened attention shall be paid to ensuring respect of human rights of specific vulnerable rights holders or groups of right holders such as women, children or migrant workers, or of (indigenous) communities.

Prohibition of Forced Labor: Neither use nor contribute to slavery, servitude, forced or compulsory labor and human trafficking.

Prohibition of Child Labor: Employ no workers under the age of 15 or, in those countries subject to the developing country exception of the ILO Convention 138, employ no workers under the age of 14 • Employ no workers under the age of 18 for hazardous work according to ILO Convention 182.

Working Hours, Wages & Benefits for Employees Recognise the legal rights of workers to form or join existing trade unions and to engage in collective bargaining; neither disadvantage nor prefer members of employee organisations or trade unions • Adhere to all applicable working-hours regulations globally • Pay fair wages for labor and adhere to all applicable wage and compensation laws globally • In the event of cross-border personnel deployment adhere to all applicable legal requirements, especially with regard to minimum wages.

Health & Safety of Employees Act in accordance with the applicable statutory and international standards regarding occupational health and safety and provide safe working conditions • Provide training to ensure employees are educated in health and safety issues • Establish a reasonable occupational health & safety management system.

Grievance Mechanism Provide access to a protected mechanism for their employees to report possible violations of this Code of Conduct.

Non-Discrimination: Mangosat does not tolerate discrimination or harassment in the workplace, based on criteria such as age, disability, ethnic origin, gender, race, political attitude, or workers’ representative activities, religion, or sexual orientation.

Environment Protection: Act in accordance with the applicable statutory and international standards regarding the environment. Minimise environmental pollution and make continuous improvements in environmental protection • Establish a reasonable environmental management system.

Confidential Information: The safeguarding of client related data is an important foundation for the trust of our clients. Confidential and sensitive information and records of the client, be it of private or corporate or with regard to the affairs of Mangosat or its employees, must be kept secret in a suitable manner from colleagues who do not require such data to properly perform their tasks. This applies equally to third parties. If someone without clear authority consistently tries to obtain confidential information, the involved persons must notify the Managing Director. Mangosat cooperates with all competent public and regulatory authorities.

No Insider Trading: Confidential, price-sensitive information may only be acted on or passed on if the transfer of information is necessary for legitimate business reasons (“Need to know-Principal”). Anyone who has such information may not recommend or initiate transactions—with respect to any securities or other financial instruments—the price of which may be affected by such information. The Managing Director must be informed immediately if a member has reason to believe information is being or has been shared that violates insider trading regulations.

Communication: All communications of Mangosat are required to be full, fair, accurate, timely, and understandable. The dissemination of information to the public concerning Mangosat is to be handled by authorised spokespersons only. If a member appears in public or takes part in public discussion in a manner, he/she might be considered as representative of Mangosat without being authorised to do so, then he/she should make clear that he/she acts as a private person.

Client Information and Advice: Members must not seek to mislead the market or clients in any manner. When working with a client, appropriate care shall be taken that the client receives information which is necessary for a reasonable decision by the client. This includes product information and advice given. Members shall not provide advice and/or recommendations regarding products in which they are not appropriately licensed to sell.

Conflicts of Interest: Conflicts of interest can cast doubt on the integrity and professionalism of Mangosat. Potential conflicts of interests must be identified at the earliest reasonable opportunity. If they cannot be avoided, any conflict situation must be handled fairly. A conflict of interest occurs whenever our personal interests interfere in any way with our ability to perform our jobs objectively and in the best interests of the company. Members must therefore refrain from entering into relationships or transactions that might impair their judgment as to what is best for the company. Even relationships that create the appearance of a conflict of interest should be avoided. In addition, conflicts of interest cannot be circumvented by acting through someone else, such as a friend or family member. Any member who is presented with a transaction or relationship that could create a conflict of interest must bring the transaction or relationship to the attention of their manager.

Complaints Management: Mangosat must deal with complaints from all clients or suppliers or former clients or suppliers promptly and fairly and in accordance with applicable laws and regulations. Members are required to cooperate with any requests for statements or documentation.

Financial Reporting: Mangosat is dedicated to providing accurate, timely, and understandable financial statements. This is required by all who are responsible for the company’s and/or its entity’s finance, control, and accounting functions (Financial Professional). Each Financial Professional is subject to and in dependence of its specific professional role within Mangosat and responsible for establishing and maintaining effective disclosure controls and procedures and internal controls and procedures for financial reporting.

Fair Competition, Anti-Trust Laws and Intellectual Property Rights: Act in accordance with national and international competition laws and do not participate in price fixing, market or customer allocation, market sharing or bid rigging with competitors • Respect the intellectual property rights of others.

Export Control and Customs: Comply with the applicable export control and customs regulations.

Responsible Mineral Sourcing: Take reasonable efforts in its products the use of raw materials which originate from Conflict-Affected and High-Risk Areas and contribute to human rights abuses, corruption, the financing of armed groups or similar negative effects.

Supply Chain Use reasonable efforts to make its suppliers comply with the principles of this Code of Conduct • Comply with the principles of non-discrimination with regard to supplier selection and treatment.

No Corruption or Bribery: Bribery is the offering, giving, or receiving of anything of value with the intention of inducing a person to act or to reward a person for having acted. Items of value can include, but are not limited to: • Cash and cash equivalents • Gifts, meals, entertainment, and travel • Political contributions • Charitable donations • Job offers Corruption includes the solicitation of a bribe, whether or not coupled with a threat of demand if refused. Mangosat does not tolerate any form of bribery or corruption. Irrespective hereof, situations may arise which do not constitute corruption or bribery but may allow the judgement of our members, clients, and business partners to be compromised. Members are prohibited from accepting any gift that may influence their judgment on company matters as it pertains to the donor.

Acceptance of Gifts and other Benefits: The acceptance of gifts and entertainment by members (including their family members) may present a conflict of interest. While members are permitted to accept gifts of nominal value, they are prohibited from accepting anything that might influence their judgment on company matters affecting the donor or that might be accompanied by any express or implied understanding that the recipient is in any way obligated to take some action that would benefit the donor, to the detriment of the company, in exchange for the gift. Similarly, members may accept entertainment, but only insofar as it is reasonable in the context of the business at hand and facilitates the company’s interests. When practical and appropriate, hospitality should be reciprocated. Members are strictly prohibited from soliciting gifts, gratuities, or business courtesies for the benefit of any family member or friend.

Gratuities to Representatives of Public Institutions: Holders of public offices, representatives of public institutions, members of public services, or authorities and politicians are mandated with the pursuit of public welfare. They should therefore not receive gifts, invitations, or other gratuities which might put their independence from business interests into question. Before making any payment, or giving anything of value, to a government official, members should consult with the company’s General Counsel.

Protection of Company Assets: Safeguarding the company’s assets is the responsibility of all members. Theft, carelessness, and waste have a direct impact on the company’s profitability. Assets should be used efficiently and maintain such assets with care and respect, while guarding against waste and abuse. Look for opportunities to improve performance while reducing costs. The use of company time, materials, assets, or facilities for purposes unrelated to the company’s business, or the removal or borrowing of company property, is prohibited, except where such use or removal is for purposes of supporting the occasional community service activity that has been endorsed by the company and where such use or removal has been approved by a supervisor. For those purposes, the company’s assets include cash, inventory, equipment, computer software, computer data, vehicles, records or reports, non-public information, intellectual property, or other sensitive information or materials, as well as telephone, voicemail, or email communication.

Prevention of Money Laundering and Illegal Activities: Mangosat is fully committed to the international fight against money laundering and the financing of terrorism and applies a risk-based, “know-your-client” policy in line with applicable laws and regulations. Members must neither be engaged in nor tolerate any illegal activity in connection with Mangosat in their workplace. This applies in particular to any infringement of anti-trust regulations and any support of tax evasion, including but not limited to, any kind of complicity in tax fraud.

Consequences of Non-Compliance: Failure to comply can expose members and Mangosat to reputational as well as legal and regulatory sanctions. Disciplinary proceedings by a regulatory body in the case of severe compliance misconduct may result in a reprimand, fine, withdrawal, or suspension of authorisation to conduct business either for the entire unit or members. In addition, failure to comply, which constitutes a breach of member’s contractual obligations, may result in disciplinary actions by Mangosat.

Protection of Members in Case of Communication about Illegal or Questionable Activities: If a member becomes aware of any illegal or questionable activity in Mangosat, he/she shall inform the Managing Director. No member who communicates bona-fide a concern, shall be exposed to retaliation based on this communication, even if the concern eventually proves to be unfounded. Such communications may be made anonymously.

Ethical Conduct of Business: The goals of this Code can only be achieved with the contribution of all. It is everyone’s personal responsibility to adhere to this Code of Conduct. All members are encouraged to contact their Managing Director when detecting that someone has done something improperly. This can help to prevent small problems leading to big problems.

Page last modified: Feb 23, 2023 @ 6:32 am