Anti-Corruption Policy

Proffer is committed to conducting business with the highest level of integrity and transparency. Corruption, bribery, and unethical business practices erode trust and violate our core values.

We strictly prohibit any form of bribery, facilitation payments, or corrupt activities, whether directly or indirectly, through third parties or intermediaries. All employees, business partners, and suppliers are required to adhere to anti-corruption laws and ethical standards. Any attempt to influence business decisions through unlawful means will result in strict disciplinary action, including termination and legal consequences.

To uphold our commitment, we have established rigorous compliance training, internal reporting mechanisms, and due diligence procedures to prevent corruption. Employees are encouraged to report any suspicious activity through our confidential whistleblowing system without fear of retaliation. Our anti-corruption framework ensures that ethical business conduct remains at the heart of our operations.

Code of Business Ethics

We believe that ethical business practices form the foundation of a successful and reputable organization. Our Code of Business Ethics outlines the principles and expectations for all employees, ensuring integrity, fairness, and accountability in all professional activities.

Employees are expected to:

• Uphold honesty and transparency in all business dealings.
• Avoid conflicts of interest that may compromise their professional integrity.
• Respect confidentiality and protect company assets.
• Foster a culture of respect, diversity, and inclusion.
• Comply with all applicable laws and regulations.

Any violation of the Code of Business Ethics may result in disciplinary action, including termination. Employees are encouraged to report ethical concerns through our designated compliance channels, where they will be handled with confidentiality and impartiality.

Competition Law Policy

We are dedicated to promoting fair competition and compliance with all applicable antitrust and competition laws. We believe that ethical and lawful business practices drive innovation, consumer trust, and market integrity.

Employees and business partners must not engage in anti-competitive behaviors, such as price-fixing, bid-rigging, or market allocation. We are committed to transparent and fair business dealings, ensuring that our clients receive the best value without any unfair trade practices.

To prevent violations, Proffer provides mandatory training on competition law compliance. Employees must disclose any potential conflicts that could lead to anti-competitive conduct. Any suspected breaches should be reported immediately to our legal and compliance teams.

Conflict of Interest Policy

At Proffer, we require all employees and business partners to act in the company’s best interests, avoiding any personal, financial, or professional conflicts that may compromise decision-making.

A conflict of interest arises when personal relationships or financial interests interfere with professional duties. Employees must disclose any potential conflicts, including outside employment, family ties with vendors, or personal investments in competing businesses.

We have implemented strict disclosure procedures and regular compliance reviews to ensure transparency and ethical conduct. Any failure to disclose conflicts of interest may lead to disciplinary action, up to and including termination.

Supplier Standards of Conduct

Proffer expects all suppliers and business partners to uphold the highest ethical, social, and environmental standards. Our Supplier Standards of Conduct outline the principles that govern our business relationships.

Suppliers must:

• Adhere to labor laws and human rights regulations.
• Ensure fair wages, safe working conditions, and non-discriminatory practices.
• Comply with environmental protection laws and sustainability initiatives.
• Maintain transparency in financial and contractual obligations.

Failure to comply with these standards may result in contract termination and legal consequences. Proffer conducts regular supplier audits to ensure adherence to these principles.

Protection & cybersecurity policies

Our Company Data Protection Policy demonstrates our commitment to safeguarding the personal and confidential information of employees, customers, stakeholders, and all other relevant parties. We are dedicated to ensuring that data is gathered, stored, and processed transparently, fairly, and in respect of individual rights.

Scope

This policy applies to all parties who provide personal information to the company, including employees, job candidates, customers, suppliers, contractors, consultants, and any other external entities we collaborate with.

Who is Covered?

• Employees of the company and its subsidiaries.
• Contractors, consultants, partners, and external entities with occasional access to company data.
• Anyone acting on behalf of the company and involved in handling personal data.

Policy Elements

The company collects and processes personal data in a manner that respects privacy rights. The data we handle includes, but is not limited to, names, addresses, usernames, passwords, photographs, social security numbers, financial data, and other identifiers.

• Data Collection: Data will be collected transparently, with the knowledge and consent of the individuals involved.
• Data Usage: We will only use data for lawful and legitimate purposes, ensuring compliance with all relevant legal requirements.

Our Data Will Be:

• Accurate and kept up-to-date.
• Collected fairly, only for lawful purposes.
• Processed in accordance with legal and ethical guidelines.
• Protected against unauthorized or unlawful access, ensuring data security.

Our Data Will Not Be:

• Shared informally or without proper consent.
• Stored indefinitely; retention periods will be defined.
• Transferred to countries or organizations lacking adequate data protection measures.
• Disclosed to third parties outside of those agreed upon by the data subject, unless required by law.

Our Obligations to Data Subjects:

We are committed to the following:

• Transparency: Inform individuals about the data we collect and how it will be used.
• Access Control: Let people know who has access to their data.
• Data Modifications: Allow individuals to request modifications, corrections, or deletions of their data when applicable.
• Data Protection: Take appropriate steps to safeguard data in case of loss, corruption, or compromise.

Actions to Protect Data:

We are committed to taking the following actions:

• Limit access to sensitive data, ensuring only authorized personnel can access it.
• Implement clear procedures for transparent data collection and usage.
• Train employees on data privacy and security best practices.
• Establish reporting procedures for data breaches or misuse.
• Ensure compliance with data protection agreements or contracts.
• Implement data protection measures (e.g., encrypted storage, secure data transfer, document shredding, restricted access, etc.).

Disciplinary Consequences:

Strict adherence to this policy is mandatory. Any breach of the policy may result in disciplinary action and, if necessary, legal consequences.

Data Protection Policy

Data security and privacy are fundamental to Proffer’s operations. We are committed to protecting personal and business data from unauthorized access, breaches, and misuse.

Our data protection policy ensures compliance with global data privacy laws, including GDPR and other applicable regulations. We implement strict data-handling protocols, including:

• Encryption and secure storage of sensitive information.
• Access controls and role-based permissions.
• Regular cybersecurity audits and risk assessments.

Employees, clients, and business partners are required to adhere to these data protection measures. Any data breaches must be reported immediately to our security team for prompt resolution.

Cyber Security Policy

With increasing digital threats, Proffer prioritizes cybersecurity to safeguard business continuity and client trust. We employ a comprehensive cybersecurity framework, covering:

• Threat detection and incident response mechanisms.
• Secure network infrastructure and endpoint protection.
• Employee cybersecurity awareness training.

All employees must follow cybersecurity best practices, including secure password management and phishing awareness. Any breach of cybersecurity protocols will result in disciplinary action, reinforcing our commitment to digital security.

Workplace Health & Safety (WHS) Policy

We are committed to maintaining a safe and healthy workplace for all employees, contractors, and visitors. We recognize that workplace health and safety (WHS) is a critical component of our business success and the well-being of everyone involved. This policy outlines the responsibilities of the company and its employees to ensure a safe and productive working environment.

This policy is not contractual in nature and does not grant contractual rights. It is discretionary, and the company reserves the right to modify or remove it at any time. Contractual rights and obligations are governed by the terms set forth in individual employee contracts.

As a Person Conducting a Business or Undertaking (PCBU), we are committed to:

• Integrating WHS into all operational aspects.
• Identifying hazards, assessing risks, and implementing strategies to reduce the likelihood of injury or damage.
• Ensuring compliance with all relevant health and safety laws.
• Developing and implementing safe systems of work.
• Providing adequate training, supervision, and safety information.
• Designing, purchasing, and maintaining safe work environments and machinery.
• Ensuring that all workplace activities are safe and do not pose undue risks to health.
• Promoting safe behavior at all levels.
• Consulting with employees and other stakeholders on safety matters to enhance decision-making.
• Supporting injury management and rehabilitation efforts for affected employees.

Responsibilities of Employees and Contractors:

All employees and contractors are expected to:

• Adhere to safe work practices and follow all safety instructions and rules.
• Report any unsafe conditions or equipment immediately to management.
• Not misuse, damage, or interfere with any safety equipment or measures.
• Perform duties in a way that ensures the health and safety of themselves and others.
• Encourage colleagues to maintain a safe and healthy environment.
• Cooperate with management and colleagues to ensure safety responsibilities are met.

Communication and Consultation:

We value employee participation in our safety system and believe that effective communication and consultation improve safety decision-making. Employees are encouraged to provide feedback on safety issues and suggest improvements to policies or procedures. This will be done through regular staff meetings, safety briefings, and other communication channels.

Management will actively engage with employees to update and review safety policies, ensuring continuous improvement.

Workplace Injuries—Rehabilitation and Return to Work:

We are proactive in managing workplace injuries. Our approach focuses on ensuring a safe, timely, and sustainable return to work for injured or ill employees. Our commitment includes:

• Prompt notification of injuries.
• Ongoing communication and consultation to develop a suitable return-to-work program.
• Clear accountability for injury management.
• Providing meaningful work and support during the rehabilitation process.
• Ensuring timely medical intervention and return-to-work planning.

We will ensure that:

• Injuries are reported early.
• Injured employees are provided with appropriate resources and duties during rehabilitation.
• Positive support is given throughout the recovery process.
• We review incidents and accidents to implement preventive measures and improve safety practices.
• Management will work closely with employees to review and update this policy regularly, ensuring the effectiveness of our workplace health and safety efforts.

Diversity & Inclusion Policy

Proffer fosters a workplace culture that values diversity, equity, and inclusion. We are committed to providing equal opportunities for all employees, regardless of race, gender, disability, or background.

Our policies promote fair hiring, inclusive leadership, and bias-free decision-making. Employees are encouraged to contribute to an inclusive work environment where diverse perspectives drive innovation and collaboration.

Employee Relations Policy

At Proffer, we recognize that strong employee relations are key to a productive and positive work environment. We are committed to:

Open communication and conflict resolution mechanisms.

Employee well-being and professional growth opportunities.

Fair treatment and non-discriminatory workplace policies.

Employees have access to grievance resolution channels to voice concerns without fear of retaliation. Our HR team ensures compliance with labor laws and fosters a culture of respect and mutual understanding.

Prevention of Sexual Harassment Policy

Proffer maintains a zero-tolerance policy toward sexual harassment in the workplace. We are dedicated to fostering a safe and respectful work environment for all employees.

Any form of harassment, including verbal, physical, or digital misconduct, is strictly prohibited. Employees are encouraged to report incidents through our confidential grievance system. All complaints will be investigated promptly, and appropriate disciplinary actions will be taken to maintain workplace integrity.

Drug and Alcohol Policy

Purpose:

To maintain a safe, productive, and quality-oriented workplace, we are committed to eliminating alcohol and drug misuse, which can harm employee health, safety, and company property. This policy complies with the Alcohol, Drug-Free Workplace Act of 1988.

Employee Assistance:

Employees voluntarily seeking help for addiction will be supported, including using paid time off and being referred to treatment providers. Employees in safety-sensitive roles or those with prior violations may be required to undergo follow-up testing. However, once a drug test is initiated, the employee may lose the opportunity for treatment leave.

Work Rules:

• Employees are prohibited from using, possessing, or being under the influence of illegal drugs or alcohol while working, on company premises, or while conducting company-related work offsite.
• The presence of illegal drugs or alcohol in the body system is forbidden during work.
• Prescription drugs must not impair work performance. Employees must consult with doctors and disclose any work restrictions.

Testing Requirements:

• Pre-employment: Applicants must pass a drug test before hire.
• Reasonable suspicion: Employees may be tested if there are signs of impairment. Refusal to test is treated as a positive result and can lead to termination.
• Post-accident: Employees involved in accidents that cause damage or injury will be tested. Refusal to test results in immediate termination.

Testing Procedures:

Testing may include breath alcohol or urine drug tests. Positive test results will be reviewed by a medical officer, who will give the employee a chance to explain the results. If a second test shows no evidence of drug use, the employee will be considered to have passed.

Consequences:

Employees who refuse testing or test positive will be subject to discipline or termination. Those testing positive may be offered a “last chance” program, including follow-up testing, but failure to comply will lead to termination.

Confidentiality:

Test results and medical information will be kept confidential, with access restricted to authorized personnel as required by law.

Inspections:

Employees may be asked to cooperate in searches of their person, work area, or property for drugs, alcohol, or contraband. Failure to cooperate will result in disciplinary action, up to termination.

Crimes Involving Drugs:

Employees must not use, distribute, or possess illegal drugs at work or while conducting company business. Off-duty drug-related convictions must be reported to HR within five days, or the employee may be discharged.

Definitions:

• Company premises: All locations and vehicles owned or operated by the company.
• Illegal drug: Substances controlled by federal law, not prescribed by a licensed professional.
• Under the influence: Alcohol level ≥.04, or a confirmed positive drug test.

Environment Policy

We acknowledge that our business activities impact the environment, and we are committed to continually improving our environmental performance. We aim to minimize our ecological footprint and assist our clients in reducing theirs.

Scope

This policy applies to all Proffer offices, data centers, employees, and suppliers.

Commitments

• Compliance: Adhere to all relevant environmental laws and regulations.
• Resource Efficiency: Optimize the use of energy, water, and other resources to reduce waste and emissions.
• Sustainable Practices: Integrate environmental considerations into our business operations and decision-making processes.
• Employee Engagement: Educate and encourage employees to adopt environmentally responsible behaviors.
• Continuous Improvement: Regularly assess and enhance our environmental management practices.

Implementation

We will establish measurable environmental objectives and monitor progress through regular audits and reviews. We will collaborate with stakeholders to promote sustainability and share best practices.

Health & Safety Policy

The health and safety of Proffer employees are of utmost importance, and the overall well-being of our people is core to our activities and success.

Scope

This policy applies to all Proffer employees, contractors, and visitors across all locations.

Commitments

• Safe Work Environment: Maintain workplaces that are free from hazards and promote well-being.
• Compliance: Adhere to all applicable health and safety laws and regulations.
• Risk Management: Identify, assess, and mitigate health and safety risks associated with our operations.
• Training and Awareness: Provide employees with the necessary training and resources to perform their duties safely.
• Continuous Improvement: Regularly review and enhance our health and safety practices.

Implementation

We will establish health and safety objectives, conduct regular risk assessments, and implement appropriate control measures. We will foster a culture where health and safety are integral to our operations and encourage employees to report concerns without hesitation.