1. Introduction

At Omnithrive Limited, we uphold the highest standards of integrity, professionalism, and ethical behaviour across all areas of our operations. This Code of Conduct and Ethical Standards (the “Code”) outlines the fundamental principles that guide our behaviour in the workplace and in interactions with clients, partners, contractors, and the broader community.

Trust and accountability are central to our reputation, and it is the duty of every individual affiliated with the company to conduct themselves in a manner that reinforces this trust.

2. Scope of Application

This Code applies to all individuals associated with Omnithrive Limited, including but not limited to:

• Permanent and temporary employees
• Managers and board members
• Contractors, freelancers, and consultants
• Any third parties or representatives acting on the company’s behalf

3. Legal Compliance and Ethical Responsibilities

All individuals covered by this Code must act in accordance with applicable UK legislation and regulatory requirements. These include, but are not limited to:

• Employment law
• Health and safety regulations
• Equal opportunities and anti-discrimination legislation
• Data protection laws, including the UK GDPR
• All professional conduct must reflect honesty, transparency, and legality.

4. Workplace Conduct and Mutual Respect

We foster a working environment based on fairness, inclusivity, and respect. Harassment, bullying, intimidation, or any form of discriminatory behaviour is strictly prohibited.

We expect all staff to demonstrate courtesy, cooperation, and professional behaviour, contributing to a positive and respectful workplace culture that supports diversity and inclusion.

5. Avoidance of Conflicts of Interest

All representatives must avoid any conflict between personal interests and their professional responsibilities. This includes actual, perceived, or potential conflicts.

• Examples may include:
• Having financial stakes in vendors or competitors
• Performing external work that may interfere with company duties
• Using company resources or confidential information for personal gain
• All potential conflicts must be disclosed to management promptly.

6. Confidentiality and Data Security

All confidential information—whether relating to the company, clients, or colleagues—must be treated with the utmost care and confidentiality. Personal and business data must be protected in compliance with the UK General Data Protection Regulation (UK GDPR).

Access to such information must be limited to those who require it for their role, and disclosure should only occur under legal obligation or authorised approval.

7. Anti-Bribery and Corruption Commitment

We maintain a zero-tolerance approach to bribery and corrupt practices. It is strictly forbidden to offer, accept, or solicit bribes or improper payments, either directly or indirectly.

All personnel are expected to comply with the UK Bribery Act 2010 and to report any conduct that may raise ethical concerns.

8. Use of Company Property and Systems

All company assets—including IT systems, communication tools, and other resources—must be used responsibly and solely for authorised business purposes.

Any misuse, including for personal benefit or illegal activity, is prohibited and may result in disciplinary action.

9. Reporting Concerns and Protection Against Retaliation

We encourage all staff to speak up about any concerns related to unethical, illegal, or inappropriate behaviour. Reports should be made to a line manager, the HR department, or another appropriate internal channel.

Individuals who raise concerns in good faith will be supported and will not be subject to retaliation or adverse treatment for doing so. All concerns will be handled sensitively and investigated appropriately.

10. Reporting Misconduct

Any suspected breach of this Code must be reported to a supervisor, the HR department, or a designated compliance officer. All reports will be investigated fairly, and any breach may result in corrective action, up to and including termination of employment or legal proceedings.

11. Training and Continuous Awareness

All new staff members will receive training on this Code as part of their onboarding process. Periodic training will be provided to ensure continued awareness and adherence to the standards outlined.

12. Monitoring, Review, and Updates

This Code is reviewed annually or when there is a material change in the law, company structure, or business operations. Updates will be communicated promptly and made readily accessible to all relevant stakeholders.

Last Updated: May 2025