Our Ethical Values

3. Integrity

Integrity is one of the foundations of BATEL’s corporate culture. We are committed to acting honestly, transparently, accurately and responsibly in all business relationships and activities. For us, integrity means doing the right thing, honoring our commitments and building trust through consistent and ethical conduct.

4. Compliance with Laws and Regulations

BATEL complies with all applicable laws, regulations, contractual obligations and recognized business practices in every country where it operates. This commitment includes local labor laws, international trade regulations, health and safety requirements, environmental legislation and other applicable legal frameworks.

Expected Behaviors:

• Understand and comply with the legal and regulatory requirements relevant to your duties and responsibilities.
• Exercise due care to protect BATEL from legal, financial and reputational risks.
• Seek guidance whenever there is uncertainty regarding legal or ethical obligations.
• Conduct all business activities in accordance with applicable laws, regulations and ethical standards.

5. Information Management

BATEL is committed to protecting the confidentiality, integrity and proper use of all sensitive and proprietary information. This includes product development projects, strategic business plans, pricing information, customer data and internal financial reports.
The privacy and confidentiality of information relating to employees, customers, suppliers and other stakeholders must be respected at all times. Such information may not be disclosed to third parties without proper authorization or legal justification.

Expected Behaviors:

a) Protect confidential information and ensure it is accessible only to authorized individuals.

b) Do not reproduce, disclose or share confidential information without proper authorization or a legal basis.

c) Handle personal data responsibly and use it only for legitimate business purposes.

d) Never use confidential information for personal benefit or for the benefit of third parties.

e) Avoid discussing confidential matters in public places or unsecured environments.

f) Do not create, distribute or share false, misleading or inaccurate information regarding BATEL or any related individuals.

6. Relationships with Customers, Suppliers and Other Stakeholders

Employees must avoid personal financial relationships that could compromise professional judgment or create conflicts of interest with customers, suppliers or other stakeholders. Borrowing money or assets for personal purposes from customers, suppliers or other stakeholders, or lending money or assets to them, is not permitted. Likewise, obtaining personal goods or services at significantly discounted prices or free of charge may be considered an improper benefit and may result in disciplinary action, including termination of employment.

7. Communication

BATEL values transparent, responsible and respectful communication. Only authorized individuals may make public statements or communicate with the media on behalf of the Company.

Expected Behaviors:

a) Follow BATEL’s official communication and disclosure procedures when responding to media inquiries or requests from third parties.

b) Do not represent BATEL in any public or official capacity unless specifically authorized to do so.

8. Social Media

BATEL respects freedom of expression and encourages responsible use of social media. Employees are expected to communicate respectfully, exercise sound judgment and avoid actions that could harm the reputation of BATEL or individuals associated with the Company.

Expected Behaviors:

a) Refrain from sharing information, images or content that could damage BATEL’s reputation or disclose confidential information.

b) Do not use BATEL’s logo, corporate identity elements, promotional materials or branded items in unauthorized or inappropriate ways.

c) Obtain the necessary approvals before sharing photographs, comments or content relating to employees, workplace activities or BATEL operations.

9. Company Assets

BATEL is committed to the responsible, ethical and efficient use of all company assets, whether tangible or intangible. Protecting company resources is essential to ensuring their long-term value, sustainability and effectiveness.

Expected Behaviors:

a) Use company assets with care and take reasonable measures to prevent damage, loss, misuse or waste.

b) Respect and protect all BATEL intellectual property, including technical drawings, designs, specifications, software, procedures, trademarks and internal documents, whether registered or unregistered.

c) Do not use BATEL’s materials, equipment, facilities or corporate identity assets for personal purposes or for the benefit of third parties.

d) Promptly report any theft, fraud, misuse or unauthorized use of company assets.

10. Impartiality

Impartiality requires employees to exercise independent professional judgment and to ensure that decisions are not influenced by personal biases, conflicts of interest, external pressures or the improper influence of others.

11. Anti-Corruption and Anti-Money Laundering

BATEL maintains a zero-tolerance approach to corruption, bribery and money laundering. We are committed to conducting business ethically, transparently and in full compliance with applicable laws and regulations.

Expected Behaviors:

a) Employees must not request, solicit or accept gifts, benefits or advantages that could compromise their objectivity or create a sense of obligation. Gifts of nominal value, such as promotional items or customary seasonal gifts, may be accepted where permitted by company policy and applicable laws. Any gift exceeding acceptable limits must be reported and handled in accordance with BATEL procedures.

b) Never offer, promise, authorize or provide any improper payment, benefit or advantage to public officials, business partners or private individuals in order to obtain or retain business or secure an improper advantage.

c) Do not participate in, facilitate or support any activity that may constitute money laundering or other financial misconduct.

d) Cooperate fully with official investigations, audits and regulatory reviews, and do not obstruct or interfere with such processes.

e) Comply with BATEL’s Anti-Corruption Policy and all applicable anti-bribery and anti-corruption legislation.

12. Labor Relations and Human Rights

At BATEL, we are committed to fostering a workplace built on respect, equality and inclusion. Our people practices are guided by internationally recognized human rights principles and supported through participatory management, equal opportunities for development, merit-based advancement and safe working conditions.

12.1 Professional Competence and Due Care

Professional competence and due care require employees to maintain the knowledge, skills and judgment necessary to perform their responsibilities effectively. This includes delivering high-quality service, acting in accordance with professional standards and exercising care in all business activities.

Expected Behaviors:

a) Apply your knowledge, skills and experience responsibly while maintaining respectful and effective communication.

b) Take advantage of learning and development opportunities offered by BATEL to support continuous professional growth.

c) Managers are expected to support their teams through constructive guidance, mentoring and performance feedback, while promoting ethical conduct and professional development.

12.2 Non-Discrimination

BATEL values diversity and is committed to providing an inclusive workplace free from discrimination. Discrimination based on ethnicity, religion, culture, age, gender, nationality, political opinion, marital status, sexual orientation, disability or any other protected characteristic is not tolerated.

Expected Behaviors:

a) Maintain respectful, professional and inclusive communication in all workplace interactions, regardless of position, role or seniority.

b) Ensure that decisions related to recruitment, performance evaluation, promotion, compensation and termination are based solely on merit, qualifications, performance and business requirements.

12.3. Violence

BATEL does not tolerate any form of verbal, psychological or physical violence in the workplace.

Expected Behaviors:

a) Refrain from any conduct involving verbal, written or physical aggression, intimidation, threats or behavior that creates a hostile or unsafe environment.

b) The possession or use of weapons is prohibited except where expressly permitted by applicable laws and company regulations.

12.4 Harassment and Sexual Harassment

BATEL maintains a zero-tolerance approach to all forms of harassment, including bullying, mobbing and sexual harassment.

Expected Behaviors:

a) Never use your position, authority or influence to intimidate, harass or take unfair advantage of others.

b) Avoid conduct that is offensive, degrading, humiliating or psychologically harmful.

c) Refrain from using sexually explicit language, inappropriate jokes, unwanted advances or any form of unwelcome behavior of a sexual nature.

d) Managers are expected to take appropriate action to prevent, address and report incidents of harassment.

12.5. Drugs and Alcohol

The possession, use, distribution or consumption of illegal drugs in the workplace is strictly prohibited. Employees must not report to work under the influence of alcohol or any substance that may impair their judgment, performance or safety.

Expected Behaviors:

a) Do not possess, use, distribute or consume prohibited substances during working hours or on BATEL premises.

b) Do not attend work while under the influence of alcohol, drugs or any substance that could negatively affect performance, safety or workplace conduct.

12.6 Conflicts of Interest

Employees must avoid situations in which personal interests could conflict, or appear to conflict, with the interests of BATEL.

Expected Behaviors:

a) Avoid activities, relationships or commitments that may interfere with professional responsibilities or the interests of the Company.

b) Do not engage in personal commercial activities within the workplace or during working hours.

c) Ensure that procurement, operational and business decisions are made objectively and are not influenced by personal interests or relationships.

d) Promptly disclose any actual, potential or perceived conflict of interest to management.

12.7 Child Labor, Forced Labor and Human Trafficking

BATEL is committed to respecting human rights and maintains a zero-tolerance policy toward child labor, forced labor, modern slavery and human trafficking.

Expected Behaviors:

a) Immediately report any suspected or identified cases involving child labor, forced labor or human trafficking.

b) Do not engage with, support or conduct business with individuals or organizations known to participate in such practices.

12.8. Political Party Activities

BATEL respects the right of employees to participate in the democratic process and engage in lawful political activities in their personal capacity.

Expected Behaviors:

a) Conduct political activities outside working hours and without using BATEL’s name, resources, facilities or assets.

b) Ensure that personal political views are not presented as the official position or opinion of BATEL.

12.9 Occupational Health and Safety

BATEL is committed to providing a safe, healthy and secure working environment for all employees, contractors and visitors.

Expected Behaviors:

a) Contribute to maintaining a safe, accessible and orderly workplace.

b) Comply with all applicable health, safety and security procedures, policies and instructions.

c) Immediately report unsafe conditions, incidents, hazards or potential risks to the appropriate personnel.

12.10 Compliance with Corporate Policies and Procedures

All employees are expected to understand and comply with BATEL’s policies, procedures and internal controls.

Expected Behaviors:

a) Familiarize yourself with the policies and procedures relevant to your role and apply them consistently.

b) Managers are expected to lead by example and provide the guidance, training and support necessary to ensure compliance.

13. Protection of Children and Young People

BATEL maintains a zero-tolerance approach to the abuse, exploitation or mistreatment of children and young people in any form.

Expected Behaviors:

a) Immediately report any suspicion, concern or incident involving the abuse or exploitation of children or young people.
b) Cooperate fully with any investigation or safeguarding process relating to such concerns.

14. Customers

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Treat all customers fairly, respectfully and professionally.

b) Be responsive, proactive and accountable in addressing customer needs and expectations.

c) Represent BATEL with integrity and professionalism, fostering long-term relationships built on trust, reliability and mutual respect.

15. Suppliers and Independent Contractors

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Select business partners based on objective technical, commercial and professional criteria, without favoritism or bias.

b) Give preference to suppliers and contractors that demonstrate responsible environmental, social and governance practices.

c) Ensure that suppliers and contractors comply with BATEL’s ethical standards and all applicable laws and regulations.

16. Competitors

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Do not engage in activities that restrict, distort or unfairly influence competition.

b) Compete fairly and professionally, avoiding false statements, misleading information or unfair practices directed at competitors.

c) Conduct all commercial activities with integrity and in compliance with applicable competition laws and regulations.

17. Trade Associations

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Obtain appropriate authorization before representing BATEL in chambers of commerce, industry associations, professional organizations or sector working groups.

b) Limit discussions to legitimate industry matters such as regulatory developments, economic policies, taxation, technical standards and sector-wide challenges.

c) Do not disclose confidential, proprietary or commercially sensitive information during formal meetings or informal discussions.

18. Society

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Consider the broader impact of business decisions on society and local communities.

b) Conduct all activities in accordance with BATEL’s policies, procedures and applicable legal requirements.

19. Environment

BATEL is committed to conducting its activities in an environmentally responsible manner. In support of global sustainability goals and international best practices, we continuously work to reduce the environmental impact of our products, operations and business activities.

a) Comply with all applicable environmental laws, regulations and requirements in every country where we operate or export.

b) Promote environmentally responsible materials, technologies and practices throughout product design, manufacturing and supply chain activities, while seeking to minimize impacts on human health and ecosystems.

Code of Ethics Governance

The relevant departments within BATEL are responsible for overseeing the implementation, monitoring and continuous improvement of this Code of Ethics. Their role is to ensure that these principles remain effective, relevant and consistently applied throughout the organization.

All employees, managers, business partners, suppliers, contractors and representatives acting on behalf of BATEL are expected to comply with this Code and uphold its principles in their professional activities.
BATEL’s ethical culture is founded on integrity, accountability, transparency and continuous improvement. Everyone working with or for BATEL is expected to contribute to a responsible, fair and sustainable future by maintaining the highest standards of ethical conduct.

August 2025 - Revision 1