Code of Conduct

1. Foreword

At COMPREDICT, we believe that how we work is as important as what we achieve. This Code of Conduct reflects our shared commitment to doing business the right way — with integrity, respect, and responsibility.

Dr. Stéphane Foulard, CEO

2. Introduction

At COMPREDICT, we are committed to conducting our business with integrity, transparency, and respect for all stakeholders. This Code of Conduct sets forth the ethical and legal standards that all employees, management, and business partners are expected to uphold in their daily activities. It serves as a guide to ensure compliance with laws, promote ethical behavior, and foster a responsible and sustainable corporate culture. By living these principles every day, we strengthen our reputation as a trusted and reliable organization within the industry.

3. Compliance with Laws and Regulations

COMPREDICT strictly adheres to all applicable national and international laws, ensuring that our operations align with legal requirements and ethical expectations. We expect our employees to act lawfully and to uphold the highest standards of business integrity. Key areas of legal compliance include:

• Competition and antitrust regulations: We do not engage in any form of anti-competitive behavior, including price-fixing, bid-rigging, or monopolistic practices.
• Anti-corruption and anti-bribery laws: We prohibit any form of bribery, whether direct or indirect, and expect our employees to avoid conflicts of interest that could compromise their professional integrity.
• Data protection and privacy laws: We safeguard personal and corporate data and ensure compliance with GDPR and other applicable regulations.
• Export control and trade compliance laws: Employees must ensure that all international trade activities comply with relevant sanctions and export control regulations.
• Environmental protection and sustainability regulations: We integrate environmentally responsible practices into our business model to minimize ecological impact and promote sustainable operations.

All employees must familiarize themselves with the legal requirements relevant to their roles. Employees are encouraged to seek legal or compliance guidance whenever unsure. Failure to comply with legal or regulatory requirements may result in disciplinary actions, including termination of employment and legal consequences.

4. Ethical Business Practices

4.1 Fair Competition

COMPREDICT supports free and fair competition as a cornerstone of our business success. We do not participate in any agreements or activities that could distort market fairness. Employees must avoid exchanging confidential information with competitors or engaging in activities that could be perceived as collusion.

4.2 Anti-Corruption and Anti-Bribery

COMPREDICT has a zero-tolerance policy toward bribery and corruption. Employees must never offer, give, solicit, or accept any form of bribery, including facilitation payments, gifts, or entertainment that could influence business decisions. Any engagement with public officials must be transparent and comply with strict legal and ethical standards.

4.3 Conflicts of Interest

Employees must avoid any personal or financial interests that could compromise their ability to make objective business decisions. Any potential conflicts must be disclosed to management. Common examples of conflicts of interest include:

• Holding financial interests in competitors or suppliers
• Engaging in personal business activities that conflict with company interests
• Accepting gifts or hospitality that could influence professional judgment

4.4 Prevention of Money Laundering and Fraud

We are committed to preventing money laundering, terrorism financing, and fraudulent activities. Employees must conduct thorough due diligence when dealing with third parties and report any suspicious transactions or activities to the compliance team or management.

5. Respect for Human Rights and Labor Standards

5.1 Human Rights

COMPREDICT supports and respects internationally recognized human rights as outlined in the United Nations Global Compact. We ensure that our business activities do not contribute to human rights abuses and that our supply chain partners adhere to the same ethical standards.

5.2 Diversity, Equity, and Inclusion

We are committed to fostering an inclusive workplace where all employees are treated with dignity and respect. Discrimination based on race, gender, age, disability, religion, sexual orientation, or any other protected characteristic is strictly prohibited. We promote equal opportunities for career advancement and professional development. We also promote inclusive hiring practices and equitable access to training and leadership roles.

5.3 Workplace Safety and Health

We prioritize the health and safety of our employees by ensuring that all workplace environments adhere to strict safety protocols. Employees must comply with occupational health and safety regulations, participate in relevant training, and report unsafe conditions immediately.

6. Protection of Assets and Information

6.1 Responsible Use of Company Resources

Employees must use company assets, including IT systems and equipment, responsibly and for legitimate business purposes. Misuse of company resources for personal gain is prohibited.

6.2 Confidentiality and Data Protection

All employees must safeguard sensitive company information, intellectual property, customer information, and personal data in compliance with applicable data protection laws. Sharing proprietary information with unauthorized parties is strictly forbidden.

6.3 Cybersecurity and IT Security

As a technology-driven company, we emphasize the importance of cybersecurity and information security. Employees must follow best practices for data security, as defined in our information security policies, especially including:

• Using strong passwords and multi-factor authentication
• Reporting any suspicious emails or cyber threats
• Avoiding unauthorized access to company systems
• Avoid installing unauthorized software or using unapproved devices on company networks

7. Environmental Responsibility

7.1 Sustainable Business Practices

We are dedicated to minimizing our environmental impact and promoting sustainable practices in our operations. Employees should strive to reduce waste, optimize resource use, and support environmentally friendly initiatives. We seek to reduce carbon emissions and enhance energy efficiency. We also expect our suppliers and partners to operate with similar environmental responsibility.

7.2 Compliance with Environmental Regulations

All business activities must align with local and international environmental laws. Employees must be aware of their responsibilities in maintaining sustainability standards and reducing ecological harm.

8. Reporting Misconduct

Employees and business partners are encouraged to report any suspected violations of this Code of Conduct. Reports can be made confidentially via the COMPREDICT compliance email.

Retaliation against individuals who report concerns in good faith is strictly prohibited. All reported violations will be thoroughly investigated, and appropriate corrective actions will be taken. Employees are expected to cooperate fully in compliance investigations.

9. Commitment and Enforcement

Compliance with this Code is mandatory for all employees and business partners. Violations may result in disciplinary actions, including termination of employment or business relationships. Regular training sessions will be conducted to ensure that all employees understand and adhere to the Code.

This Code will be reviewed and updated periodically to reflect changes in laws, best practices, and company values.

By following this Code of Conduct, we reinforce our commitment to ethical business practices, legal compliance, and a culture of integrity. Together, we uphold the values that define COMPREDICT and contribute to a responsible and sustainable business environment.