Introduction

Kairos Engineering is committed to conducting its business in accordance with the highest standards of integrity, accountability, and transparency. This Code sets out the ethical principles and standards of conduct expected from all employees, management, contractors, subcontractors, and third parties acting on behalf of the Company.

Purpose

The purpose of this Code is to:

• Promote honest and ethical conduct in all business activities
• Ensure compliance with all applicable laws, regulations, and industry standards
• Protect Company assets, reputation, and stakeholder interests
• Encourage a culture of responsibility, respect, and accountability
• Guide employees and partners in making sound ethical decisions

Scope

This Code applies to:

• All Kairos Engineering personnel at every level and location
• All subcontractors, consultants, suppliers, and vendors working on behalf of the Company
• All internal and external business interactions conducted in the Company’s name

Key Principles

Compliance with Laws and Regulations

We comply with all applicable local, national, and international laws, including anti-corruption, anti-bribery, labour, safety, and environmental regulations in every jurisdiction where we operate.

Zero Tolerance for Bribery and Corruption

We strictly prohibit the offering, giving, soliciting, or receiving of bribes or any form of corrupt payment.

Facilitation payments, kickbacks, or unlawful incentives of any kind are not permitted.

Fair Dealing

We conduct business fairly and transparently with clients, competitors, and stakeholders.

We do not engage in manipulation, concealment, misrepresentation, or abuse of privileged or confidential information.

Conflict of Interest

Employees and officers must avoid situations where personal interests conflict, or appear to conflict, with the interests of the Company.

Any actual or potential conflict must be promptly disclosed to management for review and resolution.

Confidentiality

We safeguard confidential and proprietary information belonging to the Company, our clients, and business partners.

Sensitive information may only be shared with proper authorization and for legitimate business purposes.

Anti-Discrimination and Respect

We foster a respectful, diverse, and inclusive workplace.

Discrimination, harassment, intimidation, or abuse based on race, gender, religion, age, disability, or any legally protected status will not be tolerated.

Whistleblower Protection

Employees and stakeholders are encouraged to report unethical or unlawful behaviour without fear of retaliation.

We maintain confidential grievance and whistleblowing channels to ensure concerns are raised, investigated, and resolved appropriately.

Implementation and Monitoring

 All employees receive training on this Code upon employment and at regular intervals thereafter.

Compliance is monitored through internal controls, audits, and performance reviews.

Violations of this Code may result in disciplinary action, including termination of employment and potential legal consequences.

Reporting Concerns

To report unethical behaviour or raise concerns, employees may contact:

• Their Line Manager or Supervisor
• The HSE or Compliance Officer
• The Anonymous Whistleblower Hotline (details provided internally)
• All reports will be treated confidentially and investigated promptly and fairly.

Governance and Oversight

The Compliance and Ethics Committee is responsible for the governance, interpretation, and enforcement of this Code. The Committee reports directly to executive leadership and ensures that ethical breaches are properly investigated, addressed, and resolved.

This Code is central to the Company’s reputation, operational excellence, and long-term success. Every employee and partner is responsible for upholding its principles and acting with integrity in every situation.

We do not simply comply; we lead with ethics.