1. WE ARE THE INNOVATIVE CONNECTIONS

We choose to play a role in knowledge transfer: We are in journey of becoming a global player in Knowledge & Technology transfer, especially North-South.

We are driven by values: Hills Connect is proudly driven by values. Our core values are brave, transparent, and efficient. We endeavour to set the example in all aspects of our business as well as sustainability. We constantly ask ourselves: what more can we do, what can we do better? Following laws and rules is only the beginning – it is our values that drive our behaviour.

To live up to our values, we speak up when we have concerns, we listen to others’ concerns, and we ask when in doubt.

We are committed to sustainability: For Hills Connect, sustainability is about realising concrete actions that will help us fulfil our mission: ‘To contribute to sustainable society’’. This means considering and optimising trade-offs between the social, economic, and environmental impacts of all our operations. Our aim is to ensure a positive total contribution to society.

2. WE LEAD WITH VALUES

We honour our Code: The Hills Connect Code is a single set of values for all our employees, a guideline that explains our approach to ethical business practices, human and labour rights, as well as environmental values. These values guide our work and are applied wherever we operate.

The Code will help you:

• Comply with laws and regulations
• Make the right, ethical decisions in your daily work
• Live by Hills Connect values and safeguard our reputation
• Know where to go for support and guidance when you need it
• Report on behaviour and actions you are concerned about.

It does not:

• Limit your right as an employee to speak publicly about matters of public concern
• Attempt to streamline the thinking of all our employees – we promote diversity of thought
• Have all the answers – when in doubt, ask before you act!

We make the right decisions:  At Hills Connect, complying with the law is only the beginning – doing what’s right requires us to look deeper and to consider if what we are doing, or witnessing is ethical. In addition to adhering to laws and regulations, we should always use our moral compass and company values to guide us in making the right decisions.

We speak up and we listen: A culture of openness and honesty is key to making us successful in the long run. Living up to our values is not only about complying with rules – being value-driven also gives us a competitive advantage at a time when customer and employee interest for business ethics is growing. Reporting on concerns helps us address challenges before they develop into bigger problems and fix issues that have already surfaced. It also helps us build trust not just within Hills Connect but also with our external stakeholders.

Question behaviour or actions that do not seem right and speak up. Whenever you think a colleague or business partner may be violating the values presented in this Code, it is your responsibility to report it. All reported cases are investigated by Hills Connect Management team – and we make sure not to take action against anyone accused of wrongdoing before the accusation has been thoroughly reviewed. Any findings are recorded, reviewed, and reported to our Board of Directors.

Proven cases of non-compliance with the Hills Connect Code, like taking or giving bribes, will lead to various actions such as disciplinary action, changes in our processes, and even legal action. Disciplinary measures will always be fair and consistent.

You should always feel safe and comfortable speaking up – which is why Hills Connect will protect anyone who raises an honest concern. We do not tolerate any retaliation against a person who in good faith reports misconduct.

You do not need to know all the facts; you only must believe that the information you are providing is true. However, it is not acceptable to knowingly make false accusations, lie to investigators, or interfere with an investigation. To enable a culture of speaking up, we also need to listen up. All concerns and different views, even dissenting ones, should be welcomed, heard, and addressed by the employee’s manager. Managers must make their employees feel that they are listened to and that their opinions matter, even if the topic is difficult to talk about. Managers also have the responsibility to forward serious complaints to the management team for further investigation and actions. We also listen to what goes on around us. If you hear comments like these, you may be witnessing a violation of the Hills Connect Code and should contact your manager for advice: ”Wake up – this is business. Everyone is doing this.” ”I’m sure you’re right, but at the moment we cannot afford to be totally ethical.” ”This is a different culture. In this country, this is the way we do business.”

3. WE DO RIGHTS THINGS

We comply with the law: “Do what’s right” – these words should guide all Hills Connect employees in their everyday work. This means that we always comply with all applicable local, national, and international laws, regulations, and voluntary commitments wherever we do business. It is of the utmost importance that you are aware of and adhere to all laws and regulations that apply to your work – including our company policies. Where local laws or regulations differ from the Hills Connect Code, we must make sure that we meet both standards. But playing by the rules is not enough – we go beyond compliance whenever possible and always strive to be better. We also require all agents, consultants, and business partners who may work on behalf of Hills Connect to comply with these same laws and practices.

We have a zero tolerance for corruption: Our success as the knowledge transfer company is founded on the products and services we provide, not on unethical or illegal behaviour such as corruption. Corruption – the abuse of power for personal gain – comes in various forms such as bribery, excessive business entertainment, and conflicts of interest.

We never pay bribes or facilitation payments: We have a zero tolerance for bribery or facilitation payments. We strive to ensure that external business partners acting on our behalf are aware of and share our commitment to doing business ethically.

We avoid excessive business entertainment: We compete and do business based only on quality and competence. We do not offer or accept gifts, hospitality, or expenses payments that are of unreasonably high value, or that could inappropriately affect business decisions – or even create this impression. We ensure that rebates, commissions, donations, and sponsorships are made transparently.

We avoid conflicts of interest: For Hills Connect to remain a successful knowledge transfer company, all business transactions must be conducted with the best interests of Hills Connect in mind. This means that we avoid all conflicts of interest. A conflict of interest is when you are involved in something in your personal life that could influence your work at Hills Connect and make it difficult for you to make decisions in the best interest of Hills Connect. These types of personal considerations or relationships should never impact your work at Hills Connect. Also avoid situations where it might appear to an outsider that you have a conflict of interest.

Examples of potential conflicts of interest:

• Taking on an outside job that could conflict with your work at Hills Connect.

• Signing a contract with a business that is managed or owned by a member of your family without permission of the management team.

• Acting as a corporate director, board member, or consultant in another company without informing the management team. You do not need permission to be involved in non-profit or charitable organisations.

How do I do what is right?

• Do not offer, promise, or accept bribery, facilitation payments, illegal rebates, or any other unethical payments – even if such payments are common in the local culture.

• Gifts or hospitality should never be offered in ways that make recipients feel that the giver expects something in return. They should not be extravagant, excessive in value, or offered too often.

• You should never give or accept cash or cash equivalents.

• Consult your manager if you think you may have a conflict of interest.

• If you suspect your personal life or relationships may impact your decision making, make sure a colleague with no ties to your situation makes the decision (when hiring someone, for example).

• Always ensure you have your manager’s approval and record who made the

final decision.

We know our business partners: Hills Connect works with different business partners all over the world. When we know who our business partners are, we can reduce the risk of becoming involved in unethical, illegal, or criminal activities. Always conduct careful due diligence before selecting a business partner. As a company, we are not only responsible for the actions of our employees, but also for the actions of anyone who represents us. We are committed to fully comply with applicable trade sanction programs and anti-money laundering and terrorist financing laws throughout the world. We do not engage in transactions with parties that are subject to trade sanctions or participate in money laundering or criminal tax evasion. All financial activities should be carried out transparently and recorded accurately.

We compete fairly: Hills Connect’ high-quality products and services as well as our talented and committed employees are what makes us successful and competitive. Supporting free and fair competition in the market works in our interest and benefits society at large.

We believe that all companies should be able to trade and compete with us as they wish, as long as they follow local laws and regulations just as we do. We never get involved in fixing prices artificially high or low or take part in any other practices or agreements that restrict competition. We do not exchange confidential information with competitors.

How do I do what’s right?

• As a rule, do not agree on price fixing, output levels, market sharing, or customer allocations.

• Do not share confidential market-related information with competitors. The way to do this is to avoid all unnecessary contacts with our competitors. – always make sure you have a well-founded and lawful reason to contact a competitor. All unnecessary contacts with our competitors should be avoided. If a competitor instigates a discussion relating to market-related issues, stop the discussion immediately and inform the management.

• Do not make public price announcements or share commercially sensitive information with external parties without first consulting the management team.

• Make sure you get legal advice before making any agreements with competitors.

We protect our assets and value privacy: Innovation is at the core of Hills Connect transformation journey and we want to protect what is ours to remain competitive. In your work, you probably use computers, mobile phones, applications, and other technology that belong to Hills Connect. They should primarily be used for their intended business purpose – neither professional nor private use of company-provided technology or equipment may conflict with Hills Connect’s interests, policies, or guidelines. Naturally, all use must also be in line with applicable laws and regulations.

We protect sensitive information: Working for Hills Connect means that you are trusted to treat any sensitive information you learn in your work with absolute confidentiality. Sharing sensitive information with outsiders or using it for your personal gain may hurt Hills Connect.

Do your part to protect it. To prevent market abuse, we also set restrictions on share trading, disclosure, and other use of inside information.

We value privacy: Digitalisation brings great opportunities for Hills Connect but it also presents challenges such as how to treat the personal data of our employees, customers, suppliers, and other stakeholders. Collecting and processing this data will always be done with specified and legitimate business purposes and in compliance with applicable laws.

How do I do what’s right?

• Protect the technology and equipment entrusted to you and only use them in legal and ethical ways. Respect copy rights only install authorised software on company computers, and steer clear from unsecured websites.

• Do not store offensive or obscene material (such as pornography) on company owned devices.

• Only discuss sensitive information in private settings and with people who are authorised to do so. Avoid discussing it with family or friends; in public places like restaurants, hotel lobbies, or public transport; at trade association meetings; or on social media.

• Do not re-use the same password on multiple sites. Leaked access credentials are very easily tested against other services, especially if the username is the Hills Connect email address.

• Also remember that you may not use non-public company information to buy or sell stocks or securities – or for other personal gain.

• All collection and processing of personal data must have a clear and justified business purpose and comply with applicable laws. It should be relevant and necessary to the work you are doing.

• Only collect the amount of personal data necessary for the specified purpose, make sure it is accurate and up-to date, and delete it from all folders when outdated or no longer needed.

• Be fully transparent about how the data will be used.

• Keep all personal data safe and secure. Only authorised employees and external parties with a justified reason should view the data.

We communicate clearly and transparently: It is important for Hills Connect that our stakeholders understand and trust us. This means that we must communicate with them in a clear, transparent, and timely manner and make sure that everything we write or say, both internally and externally, is true and balanced. We also listen to our stakeholders to understand their views.

Hills Connect must follow the rules and regulations set for stock markets and financial reporting. Certain company information, for example, must be shared with all stakeholders at the same time.

Not all Hills Connect employees can speak on behalf of the company. Our main corporate spokespersons are the Chairman of Board of Directors and Managing Director. When needed, our Board of Directors will appoint and support other spokespersons.

How do I do what’s right?

• If you are not an appointed spokesperson, do not publicly speak on behalf of Hills Connect. If you receive a request for comment, always forward them to the correct spokesperson.

• When on social media, especially if you can be identified as a Hills Connect employee, conduct yourself in line with the Hills Connect Code and be clear about your views being your own, not Hills Connect.

• When using your company email, remember that you are representing Hills Connect. Act professionally and with integrity.

• Do not share confidential information about Hills Connect, our customers, suppliers, or other business partners on the internet.

• Respect copyrights and do not engage in communications that may cause damage to the reputation of yourself, your colleagues, or Hills Connect.

• Never share anything that may be seen as a threat, harassment, or bullying.

4. WE CARE FOR PEOPLE AND THE PLANET

We stay safe: Hills Connect wants everyone home safe, every day – our own employees and all our partners. Our goal is zero accidents, and we work every day towards that goal.

At Hills Connect, safety starts with management, but it is also everyone’s personal responsibility to work safely. We believe in creating an open safety culture where everyone can give feedback and make observations about safe and unsafe behaviour and conditions in a constructive way. When we make good choices and decisions about safety and let each other know when we need to do better, all accidents can be prevented.

We promote diversity: We believe diversity strengthens our competitiveness and strive to reflect the societies where we operate. Diverse working teams enable us to explore different perspectives and challenge our way of thinking, contributing to better decision making.

Diversity to us means various aspects of diversity including gender, age, skills, experiences, culture, and personality.

We respect human rights: Hills Connect adheres to internationally recognised human and labour rights and standards, and they must be applied to all our employees. We do not tolerate discrimination against anyone based on their ethnicity, age, gender, disabilities, sexual orientation, religious beliefs, political opinions, family status, social origins, or other such characteristics.

Similarly, we do not condone any form of harassment including violence, sexual harassment, punishment, or abuse of any kind. We do not allow forced or child labour.

We respect our employees’ right to organise themselves, join or not join associations and trade unions, and collectively bargain with the company. Where needed, we seek to facilitate other forms of worker representation.

We are a responsible neighbour: We respect the cultures, customs, and values of local communities and build relationships with them to strengthen mutual understanding, while at the same time striving to live by the values stated in the Hills Connect Code.

We respect the environment: Hills Connect requires its employees and partners to comply with all applicable legal environment requirements and demonstrate continual improvement of its environmental performance.