POLICIES & CERTIFICATES

We are committed to upholding the human rights of workers and treating them with dignity and respect, as understood by the international community. This applies to all workers, including temporary, migrant, student, and persons providing services under service contracts.

We prohibit forced or illegal labour, as well as involuntary or exploitative prison labour, slavery or human trafficking. This includes transporting, harbouring, recruiting, transferring or receiving persons using threat, force, coercion, abduction or fraud for labour or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility and unreasonable restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment agreement in their understandable language containing a description of terms and conditions of employment before they depart from their country of origin. No substitution or change(s) shall be allowed in the employment agreement upon arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms. All work must be voluntary, and workers shall be free to leave or terminate their employment according to Labour law.

We may not hold or otherwise destroy, conceal, confiscate, or deny employees access to their identity or immigration documents, such as government-issued identification, passports, or work permits unless such holdings are legally required. Employees shall not be required to pay employers’ or agents’ recruitment fees or other related fees unless local law requires them.

All Teltonika employees are required to perform tasks assigned responsibly and reliably and effectively manage their time without wasting company time and resources by taking part in unauthorized activities, including, but not limited to, trading, gambling, or political activities on the premises. They must act responsibly and sensibly, conducting themselves to uphold the Company's integrity, reputation, and values.

1) WORKING CONDITIONS AND EMPLOYMENT PRACTICES

We are committed to creating and sustaining a working environment where employees are treated with dignity and respect. We also require our suppliers to adopt and enforce a similar workplace code of conduct. Where local laws dictate any additional requirements, those will be applicable along with those mentioned here.

We comply and expect our suppliers to comply with the following:

• laws that promote safe working conditions and individual security; We comply with the legal provisions on working hours, rest days, public holidays and holiday entitlement and payment. The length of the working week does not exceed the requirements of national legislation. Our employees may only work overtime with their written consent, except in exceptional cases, as the Labour Code provides. Employees' working and rest time arrangements shall comply with local legislation and shall not affect the work-life balance of employees. Working hours are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations.

• laws prohibiting forced labour ;

• prohibitions on the employment of underage children : We prohibit illegal child labour and all forms of forced forms of forced labour.The term “child” refers to any person under the age of 16, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is highest. The use of legitimate workplace learning programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardise their health or safety, including night shifts and overtime. We ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights under applicable laws and regulations. We provide appropriate support and training to all student workers. In the absence of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks;
• prohibitions on human trafficking ; and laws that ensure freedom of association and the right to engage in collective bargaining.

We work to protect the rights of all Teltonika employees; that’s why we:

• Pay fair wages. Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees shall be provided with a timely and understandable wage statement for each pay period that includes sufficient information to verify accurate compensation for work performed.
• Support the rights of all employees;
• Value diversity and inclusion.
• Not engage in or support discrimination of any form.

Commit to ensuring a workplace free of harassment and abuse for employees.

We commit to a workforce free of harassment and unlawful discrimination. We do not engage in discrimination based on race, colour, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way. We are committed to providing all employees with a work environment that is conducive, safe and free from discrimination and harassment. Employees should always treat their colleagues and other persons with respect and consideration. We will not tolerate any acts of discrimination or harassment and will investigate all complaints and incidents fairly and promptly. We prohibit any form of retaliation or intimidation against anyone for making good faith reports concerning allegations of discrimination, harassment, violation of the Code, or any other allegations of improper behaviour. Any employee found guilty of such acts shall be subjected to disciplinary action, including termination/dismissal from service.

We respect what each individual brings to Teltonika, including background, education, gender identity and/or expression, race, ethnicity, citizenship, language, origin, social status, faith, beliefs or views, sexual orientation, age, disability, health condition, family and marital status, membership in a political party, trade union or association, religion, intent to have a child, as well as, that the employee is using or has used the rights indicated in the local labor law, cultural expertise, other prohibited statutory grounds established by laws.

We establish fair disciplinary, grievance, and termination procedures.

We have a procedure for receiving reports of workplace violence, harassment, threats, and other workplace misconduct.

We have a written Employment contract with each employee in a language they understand.

We do not use or benefit from any kind of forced or involuntary labor.

We respect the rights of its employees to associate freely, join or not join trade unions and/or employees’ councils in accordance with national laws and international conventions.

2) COMPLIANCE TO LOCAL LAW AND REGULATIONS

We expect all employees, regardless of hierarchy, positions, and nationalities, to comply with all laws, regulations, codes of practice, and legal, regulatory, and licensing requirements applicable to the jurisdictions where it operates.

We expect all employees to refrain from any activities that negatively impact Teltonika’s interests or reputation, including but not limited to any actions in the workplace or elsewhere that, at the company’s discretion, are related to violent behavior, moral misconduct, or are considered criminal offenses under applicable laws, regulations, and legal requirements, regardless of whether the employee has been charged or convicted.

Employees who violate the law, our Code, or our policies may be subject to disciplinary action, including termination. We expect everyone to do their part to protect Teltonika's reputation and our customers.

As a global company, there may be limited circumstances where local law or other legal requirements differ from the standards outlined in our Code. We comply with applicable local laws and our Code. If you become aware of a conflict between our Code and other legal requirements, please get in touch with us at [email protected]

3) HEALTH AND SAFETY

We recognize that a safe and healthy work environment minimizes the risks of work-related injury and illness and enhances the quality of products and services, consistency of production, worker retention, and morale. We also recognize that ongoing worker input and education are essential to identifying and solving health and safety issues in the workplace.

Recognized management systems, such as ISO 45001 and the ILO Guidelines on Occupational Safety and Health, were used as references in preparing the Code and may be valuable sources of additional information.

We are committed to providing a healthy and safe work environment for all business stakeholders, including employees, customers, business partners, and visitors. Every stakeholder has a personal responsibility to support this commitment.

We are obliged to carry out their duties in a safe manner, without causing harm to themselves or others, and to report any potentially unsafe situations immediately.

We prohibit employees from working under the influence of drugs or alcohol substances because that can create a safety hazard and affect your judgment.

WE KEEP OUR WORKPLACE SAFE BY:

• Ensure that Teltonika employees are offered a safe, secure, and healthy working environment, including, but not limited to, protection from fire, accidents and processes, and substances and techniques that are unsafe, unhealthy, toxic, or harmful.
• Established and enforced a written health and safety policy and relevant procedures in a language that all employees understand and that is in accordance with industry, national and international standards and customer requirements.
• Knowing how to recognise potential workplace risks and reporting any safety concerns or non-compliance with law or internal safety procedures.
• Appointing a health and safety specialist or other representative responsible for health and safety in the workplace.
• Following the law, safety procedures, Teltonika Code and policies.
• Ensuring that Teltonika employees are provided with the Personal Protective Equipment (PPE) and training necessary to safely perform their positions' functions.
• Offering feedback to colleagues if they are not working safely and accepting feedback when offered.
• Finding ways to make our workplace safer.
• Expecting to work towards using ISO 45001.

We are encouraged to report workplace safety issues using internal systems or other existing local reporting processes.

Our procedures and systems are to be in place to prevent, manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate employees' return to work.

1) OCCUPATIONAL HEALTH AND SAFETY

Employees who use chemicals or flammable substances in the course of their work, work with electrical equipment, work at height, or drive vehicles must have identifiable and measurable safety and health requirements and must be subject to control through appropriate design, engineering and administrative controls, preventive maintenance, and health and safety and fire safety instructions, and through regular training in health and safety and fire safety and life safety for workers.

Where risks cannot be adequately controlled by these means, employees must be provided with suitable, well-maintained personal protective equipment and educational material on the risks associated with the work. Reasonable steps must also be taken to prevent pregnant women and/or nursing mothers from working in an environment that poses a significant risk, eliminate or reduce any health and safety risks in the workplace for pregnant women and nursing mothers, including those related to their work tasks, and provide suitable facilities for nursing mothers.

2) EMERGENCIES PREPAREDNESS

We commit to identifying and assessing potential emergencies and events, ensuring that their impact is minimised through the implementation of comprehensive emergency management plans and response procedures. These include emergency reporting systems, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, clear and unobstructed evacuation routes, adequate exit facilities, and effective recovery plans. Our emergency preparedness measures are designed to protect human life, the environment, and property, ensuring a swift and coordinated response to any emergency.

3) OCCUPATIONAL INJURY AND ILLNESS

Procedures and systems were to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage employee reporting; classify and record injury and illness cases; provide necessary first aid; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.

4) INDUSTRIAL HYGIENE

We have identified, assessed and controlled employees' exposure to chemical, biological and physical agents. Potential risks are eliminated or managed through proper design, engineering and administrative controls. Where risks cannot be adequately managed by such means, we provide employees with suitable, well-maintained personal protective equipment and instructions on using it.

5) PHYSICALLY DEMANDING WORK

We have identified, assessed, and controlled the risks of physically demanding tasks for workers, including manual handling, heavy or repetitive lifting, prolonged standing, and repetitive movements.

6) MACHINE SAFEGUARDING

Our production and other machinery are evaluated for employees' health and safety hazards. Where machinery presents an injury hazard, physical guards, interlocks, and barriers are to be provided and properly maintained.

7) SANITATION, FOOD, AND HOUSING

Employees are to be provided access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labour agent are to be maintained to be clean and safe and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting, heat and ventilation, individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

8) HEALTH AND SAFETY COMMUNICATION

We provide workers with appropriate workplace health and safety information and training in a language they can understand, on all identified workplace hazards to which workers are exposed, including but not limited to mechanical, electrical, chemical, fire and physical hazards. Information relating to the safety and health of employees shall be clearly displayed on the premises or placed where workers can see and access it. Employees shall be instructed in occupational health and safety and fire safety before starting work. Employees are encouraged to comply with occupational safety and health requirements.

We recognise that environmental responsibility is integral to producing world-class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimised while safeguarding the health and safety of the public. Recognised management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful sources of additional information.

We integrate responsible environmental principles into our business decisions and are dedicated to increasing efficiency throughout Teltonika. We support environmentally friendly and sustainable business practices. Our environmental standards are:

1) ENVIRONMENTAL PERMITS AND REPORTING

We ensure that all required environmental permits, approvals, and registrations (e.g., discharge monitoring) are obtained, maintained, and kept current. Additionally, we strictly adhere to their operational and reporting requirements.

2) POLLUTION PREVENTION AND RESOURCE REDUCTION

We minimise or eliminate emissions, pollutant discharges, and waste generation at the source through measures such as pollution control equipment, process modifications in production, maintenance, and facilities, or other effective methods.

We conserve natural resources - including water, fossil fuels, minerals, and virgin forest products - through strategies such as process modifications, material substitution, reuse, conservation, recycling, or other sustainable practices.

3) HAZARDOUS SUBSTANCES

We identify, label, and manage chemicals and other hazardous materials to ensure their safe handling, movement, storage, use, recycling, reuse, and disposal.

4) SOLID WASTE

We implement a systematic approach to identifying, managing, reducing, and responsibly disposing of or recycling solid waste (non-hazardous).

5) AIR EMISSIONS

We characterise, routinely monitor, control, and treat air emissions - including volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting chemicals, and combustion by-products. We also conduct regular monitoring of our air emission control systems to ensure optimal performance.

6) MATERIALS RESTRICTIONS

We are to adhere to all applicable laws, regulations and customer requirements regarding the prohibition or restriction of specific substances in products and manufacturing, including labelling for recycling and disposal.

7) WATER MANAGEMENT

We implement a water management program that documents, characterises, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater must be characterised, monitored, controlled, and treated as required before discharge or disposal. We regularly monitor the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

8) ENERGY CONSUMPTION AND GREENHOUSE GAS EMISSIONS

We track and document energy consumption and all relevant Scope 1 and 2 greenhouse gas emissions at the facility and/or corporate level. We actively seek cost-effective methods to improve energy efficiency, reduce energy consumption, and minimise greenhouse gas emissions.

We, in order to fulfil social responsibility and achieve success in the marketplace, commit to upholding the highest standards of ethics, including:

1) BUSINESS INTEGRITY

We commit to upholding the highest standards of integrity in all business interactions. We adhere to a zero-tolerance policy prohibiting any forms of bribery, corruption, extortion, and embezzlement

2) NO IMPROPER ADVANTAGE

We commit to not promising, offering, authorising, giving, or accepting bribes or any other means of obtaining undue or improper advantage. This prohibition includes the promising, offering, authorising, giving, or accepting of anything of value, either directly or indirectly through a third party, to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

3) DISCLOSURE OF INFORMATION

We commit to conducting all business dealings transparently and accurately, reflecting them in our business books and records. Information regarding our labour practices, health and safety measures, environmental practices, business activities, structure, financial situation, and performance must be disclosed in accordance with applicable regulations and prevailing industry standards. The falsification of records or misrepresentation of conditions or practices within the supply chain is unacceptable.

1) CONFIDENTIALITY

We acknowledge that during our employment at Teltonika, we will have access to and/or will possess trade secrets and other Confidential Information of Teltonika and its suppliers, clients and business partners, including, without limitation, Teltonika’s business plans, negotiations, non-public financial information and statements, details of suppliers, clients and business partners, pricing and credit techniques Teltonika action plans and/or projects, technological solutions, information concerning dealings, transactions or affairs of Teltonika, program codes, software design know-how, research and development activities, private processes, and books and records.

To protect the Confidential Information and the goodwill of Teltonika, we must agree to and undertake that both during and after the term of the employment, employees shall hold in the strictest confidence and shall not, without the express written permission of Teltonika, divulge, furnish, transfer or make accessible to anyone, directly or indirectly, orally or in writing to any person, including but not limited to members of your family, use for any purpose for your own account or benefit or any person or entity.

2) INTELLECTUAL PROPERTY

Teltonika is committed to respecting and protecting its intellectual property rights and those of others. This includes protecting all information, including customer and supplier information, to ensure the protection of intellectual property rights.

Teltonika’s intellectual property, including, but not limited to, patents, trademarks, copyrights, domain names, and design rights, is a valuable asset. All employees and business partners are expected to respect, protect, and not misuse these assets. We take legal measures to protect the innovations and developments that drive our business forward.

Teltonika acknowledges the importance of respecting third parties' intellectual property and ensuring compliance with all relevant intellectual property laws and regulations.

Employees must return all of Teltonika’s property, including confidential documents, upon leaving the company. Employees are also prohibited from disclosing or misusing any confidential information and/or intellectual property obtained and/or used during their employment.

Аny employee – made invention, design, or improvement related to Teltonika’s business shall be considered the exclusive intellectual property of Teltonika in accordance with applicable laws and employment agreements.

3) PRIVACY

Teltonika is committed to protecting the reasonable privacy expectations of personal information of everyone it does business with, including suppliers, customers, consumers, and employees. When personal information is collected, stored, processed, transmitted, and shared, Teltonika complies with privacy and information security laws and regulatory requirements.

We are committed to respecting the privacy of individuals, including employees and customers.

4) CORRUPTION PREVENTION

We value honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, government officials, and all other parties that Teltonika is involved in business dealings with. This applies to all Teltonika employees, directors, and independent contractors worldwide.

All company personnel must be informed and comply with the Anti-Corruption clause. If any personnel fail to comply with the Anti-Corruption clause, they will be subject to disciplinary action, up to and including termination of employment or other relationship with the Company.

5) ANTI-BRIBERY

Teltonika has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorised payments directly or indirectly made, offered or promised to make, kickbacks, benefits or advantages to any person, individual, organisation or entity are prohibited by this clause.

Bribery involves exchanging or offering something of value to improperly influence a business decision or obtain a business advantage. Bribes can take many forms, including giving cash, gift cards, entertainment, inappropriate discounts, hiring a family member or a friend of someone you seek to influence, or even making specific charitable contributions.

6) GIFTS

It is allowed in Teltonika to give and receive appropriate, lawful business gifts and entertainment in connection with working at Teltonika, provided that all such gifts and entertainment satisfy the general principles outlined in this Code, constitute a standard business courtesy, and are not given or received with the intent or prospect of influencing the decision-making or other conduct of the receiving person.

If you, as Teltonika’s employee, receive a gift that you believe you should not have accepted, you must notify your manager or e-mail to trust channel [email protected], who will determine the following steps to be taken. Depending on the circumstances, you may retain the gift, donate to a charity of your choice or return it to the grantor.

7) CONFLICT OF INTEREST

We declare/disqualify ourselves from handling transactions that put us in a position of conflict, whether perceived or real.

We comply with reporting and disclosure requirements regarding potential or actual conflicts of interest and disclose any matters that could reasonably be expected to interfere with our professional conduct and duties. A conflict of interest arises when our personal interests interfere with Teltonika's job or ability to make objective decisions on behalf of Teltonika.

Employees of Teltonika should not engage in any business dealings outside that involve or could appear to involve a conflict between their personal interests and the interests of Teltonika.

Employees must not have direct or indirect financial or business interests when dealing with Teltonika’s stakeholders when engaged on Teltonika's behalf.

Employees must not take advantage of any opportunity for personal gain that rightfully belongs to Teltonika. Instead, they must report any potentially compromising situation to their supervisors promptly.

8) CHARITABLE DONATIONS AND TRANSPARENT SPONSORSHIPS

Charity and sponsorship from Teltonika may include:

• charity and sponsorship funds;
• budgetary institutions;
• associations;
• public organisations;
• public institutions;
• religious communities, associations and religious centres;
• branches (divisions) of international public organisations;
• other legal persons (except for political parties) whose activities are regulated by special laws and the purpose of the activity whereof is not profit-seeking, while the profit received may not be allocated to their participants.

Charity and sponsorship of political parties are strictly prohibited.

9) ANTI-MONEY LAUNDERING

As a company, we are committed to complying with all applicable laws and regulations aimed at combating money laundering by identifying every counterparty we do business with.

Please find more about Teltonika AML Policy at https://teltonika-iot-group.com/about-us/policies-certificates/prevention-of-money-laundering-policy .

1) TRADE RESTRICTION

Teltonika complies with trade restrictions imposed by the EU and US and takes technical measures to assure compliance.

Please find more about Teltonika Trade Compliance at https://teltonika-iot-group.com/about-us/policies-certificates/prevention-of-money-laundering-policy .

2) RESPONSIBLE SOURCING OF MINERALS

Teltonika has a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture do not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Teltonika exercises due diligence on the source and chain of custody of these minerals and makes its due diligence measures available to customers upon request.

Teltonika establishes a management system whose scope is related to the content of this Code. Our management system is designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products; (b) conformance with this Code;(c) identification and mitigation of operational risks related to this Code; and (d) continual improvement.

Teltonika is committed to operating in a manner that is compatible and constantly improving with our Integrated Management System (IMS), which is designed to meet the requirements of lasted editions of ISO 9001, ISO 14001, ISO 45001, ISO 13485 and ISO 27001 standards. The management system contain the following elements:

1) COMPANY COMMITMENT

Integrated management system policy statements affirming Teltonika’s commitment to compliance and continual improvement, endorsed by executive management and posted in the facility in the local language.

2) MANAGEMENT ACCOUNTABILITY AND RESPONSIBILITY

Teltonika clearly identifies senior executive and company representative[s] responsible for ensuring the implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.

3) LEGAL AND CUSTOMER REQUIREMENTS

Teltonika has identified, monitored, and understood applicable laws, regulations, and customer requirements, including the requirements of this Code.

4) RISK ASSESSMENT AND RISK MANAGEMENT

Teltonika has identified legal compliance, environmental, health and safety, labour practice, and ethics risks associated with its operations. It has determined the relative significance of each risk and implemented appropriate procedural and physical controls to manage identified risks and ensure regulatory compliance.

5) IMPROVEMENT OBJECTIVES

Teltonika has established written performance objectives, targets, and implementation plans to improve its integrated management system performance, including periodic assessments of its progress in achieving those objectives.

6) TRAINING

Teltonika has established training programs for managers and workers to implement company policies, processes, and improvement objectives and meet applicable legal and regulatory requirements.

7) COMMUNICATION

Teltonika has established a process for communicating clear and accurate information about its policies, practices, expectations, and performance to workers, suppliers, and customers.

8) EMPLOYEES FEEDBACK, PARTICIPATION AND GRIEVANCE

Teltonika has established ongoing processes, including an effective grievance mechanism, to assess employees’ understanding of company practices and conditions covered by this Code, obtain feedback on or report violations, and foster continuous improvement.

9) AUDITS AND ASSESSMENTS

Teltonika has established periodic self-evaluations to ensure conformity with legal and regulatory requirements, the content of the Code, and customer contractual requirements related to the integrated management system.

10) CORRECTIVE ACTION PROCESS

Teltonika has established a process for timely correcting deficiencies identified through internal or external assessments, inspections, investigations, and reviews.

11) DOCUMENTATION AND RECORDS

Teltonika has established and maintains documents and records to ensure regulatory compliance and conformity with company requirements, while ensuring appropriate confidentiality to protect privacy.

12) SUPPLIER RESPONSIBILITY

Teltonika has established a process to communicate Code requirements to suppliers and monitor their compliance with the Code.

Everything we communicate about Teltonika can impact our reputation, coworkers, and Teltonika’s brand. We ensure the information we communicate is reliable, consistent, and accurate, so only certain people are authorised to speak on Teltonika’s behalf.

All media requests for information and interviews should be referred to the Global Brand Development structural unit. No comments regarding Teltonika, its business products, services, strategy, or practices should be made without prior approval from Management.

We adhere to this clause for platforms including but not limited to X, LinkedIn, Instagram, Facebook, WeChat, YouTube, Flickr, Twitch, blogs, wikis or any other tool or service that facilitates interactions over the internet.

We are respectful towards others when conducting business on behalf of Teltonika or when we identify/could be identified as Teltonika employees. Teltonika has zero tolerance for racism, bigotry, misogyny, expressed or implied threats of harassment or physical harm, or hate speech.

We are encouraged to speak about Teltonika and share news and information, but only authorised and trained spokespeople may speak on behalf of Teltonika and issue official Teltonika responses. We avoid posting content that might contain legal conclusions, financial information, intellectual property that belongs to other companies, or defamatory or inflammatory language.

A Code of Conduct for Teltonika‘s Property and Assets outlines the guidelines and principles for properly using, maintaining, and protecting an organisation's resources. These rules ensure that company assets are used ethically, responsibly, and efficiently to support the organisation’s goals and operations.

1) ETHICAL USE

We ensure that company assets and resources are used only for legitimate business purposes and only with proper authorisation. We encourage respectful and careful handling of all company resources to avoid damage, loss, or misuse.

2) COMPLIANCE WITH LAWS

We ensure compliance with all applicable laws and regulations related to the use and management of company assets. We promote respect for and protection of the company’s intellectual property rights, including patents, trademarks, and copyrights.

3) PROTECTION AND SECURITY

We ensure that measures are taken to protect company assets from theft, vandalism, and unauthorised access. We encourage protecting electronic resources, including data and information systems, with appropriate security measures.

4) EFFICIENT USE

We ensure that company resources are used efficiently, avoiding unnecessary waste or excessive use. We encourage being mindful of costs and striving to optimise asset usage to reduce expenses.

5) RESPONSIBILITY

We encourage taking responsibility for the company assets entrusted to you and promptly reporting any damage or loss, ensuring that company asset usage and maintenance records are accurately kept.

6) MAINTENANCE AND REPORTING

We ensure that company assets are regularly maintained and kept in good condition. We encourage promptly reporting any issues, failures, or damage to the relevant department or management.

7) PERSONAL USE

We encourage limiting personal use of company assets and ensuring that it does not interfere with business operations or violate company policies. We prohibit using company assets for personal gain or in ways that could harm the company’s interests.

8) RETURN OF ASSETS

We ensure that company assets are returned when leaving the company or after using the assets has ended. We encourage ensuring that returned assets are in good condition, excluding normal wear and tear.

By implementing this code of conduct regarding company assets and resources, we promote a culture of responsibility, accountability, and respect, ensuring that the organisation’s resources are effectively managed and protected.

Cybersecurity is a core focus in everything we do. We are dedicated to protecting our customers, their data, and our internal information while ensuring transparency and accountability in our security practices. This commitment extends through all stages of product development and operational processes.

We:

• Integrate Cybersecurity by Design: Ensure that cybersecurity is an essential element in every phase of our design and development process.
• Prioritize Customer Data Security: Ensure that our products and services are secure and designed to protect customer data from threats.
• Promote Transparency: Operate transparently by making our vulnerability reports public, enabling customers and stakeholders to stay informed about our security measures and updates. Our security vulnerability reports
• Raise Awareness of Cybersecurity Risks: If we identify any actual or potential cybersecurity issues, please speak up immediately.
• Collaborate with Cybersecurity Experts: Engage our internal cybersecurity experts to ensure we follow best practices for secure development and data protection.

By adhering to these principles, we ensure that we maintain the highest level of security and transparency, fostering trust with our clients and partners.

1) COMMITMENT TO INTEGRITY

At Teltonika, we are committed to maintaining the highest ethical standards, transparency, and accountability. We encourage all employees, partners, and stakeholders to report any suspected wrongdoing, unethical behaviour, or violations of our Code of Conduct.

2) WHAT TO REPORT

Whistleblowing applies to any concerns related to:

• Fraud, corruption, or financial misconduct.
• Violations of company policies or legal regulations.
• Harassment, discrimination, or workplace misconduct.
• Health, safety, or environmental violations.
• Data privacy breaches or misuse of confidential information.

3) REPORTING CHANNELS

If you witness or suspect misconduct, you are encouraged to report it confidentially through the following channel: [email protected].

All reports will be treated with strict confidentiality, and we ensure that whistleblowers are protected against retaliation.

4) PROTECTION AGAINST RETALIATION

Teltonika strictly prohibits any form of retaliation against whistleblowers who report concerns in good faith. Any act of retaliation will be subject to disciplinary action.

5) ANONYMITY AND CONFIDENTIALITY

Reports can be made anonymously. However, providing contact details can help us conduct a more thorough investigation. We are committed to handling all reports responsibly and ensuring the privacy of all parties involved.

Below are links to detailed Teltonika policies referenced in the Code. Please be noted that this is not an exhaustive list of policies:

• Integrated Management System policy
• Warranty and repair policy
• Privacy policy
• Terms of service
• Recruitment data policy
• Data processing agreement
• Cookies policy

Failure to comply with the Code is viewed as a serious matter that can lead to disciplinary action, up to and including termination of employment or dismissal, as well as criminal charges. Such disciplinary action may be taken against supervisors who condone, permit, or know of improper conduct.

Concerns or questions about Human Resources issues: Contact your local HR employee

AML/CFT/Sanctions related questions: [email protected]

Compliance with local law and regulations: [email protected]

Data privacy-related questions: [email protected]

Any acts of discrimination or harassment: [email protected]

Whistleblowing: [email protected]

The following standards were used in preparing this Code and may be useful sources of additional information. Each participant may or may not endorse the following standards.

Responsible Business Alliance (RBA)

ILO Fundamental Conventions

Eco-Management & Audit Scheme (EMAS)

Ethical Trading Initiative

ILO Code of Practice in Safety and Health

ISO 14001 and related standards – Environmental management

National Fire Protection Agency

OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas

OECD Guidelines for Multinational Enterprises

Universal Declaration of Human Rights

United Nations Convention Against Corruption

United Nations Global Compact

United States Federal Acquisition Regulation

Social Accountability International (SAI) SA 8000

United Nations (UN) Guiding Principles on Business and Human Rights

United Nations Convention on the Rights of the Child

United Nations Convention on the Elimination of All Forms of Discrimination Against Women

ISO 45001 – Occupational health and safety management systems

We hereby confirm that we have taken part in and fully understand the Teltonika Supplier Code of Conduct.

We confirm that we are fully aware of all relevant laws in the countries where we operate and the international standards referred to in this policy.

We agree to comply with this Teltonika Code of Conduct and to take responsibility for informing our suppliers, sub-suppliers, producers, and business partners involved in the production of goods and services for Teltonika about the requirements in this policy.