Code of conduct

1. Purpose

This Code of Conduct sets out the standards of ethical and professional behaviour expected of everyone who works at or with HLD Group. It reflects our values and our legal and social obligations, and it protects our people, our customers, and our reputation.

2. Scope

This Code applies to all officers, employees, contractors, and, where relevant, partners and suppliers acting on our behalf. Compliance with the Code is a condition of engagement.

3. Our standards of behaviour

• Act with honesty, integrity, and fairness in all dealings
• Comply with the law and with company policies
• Treat colleagues, customers, and the public with respect and dignity
• Protect the confidentiality, integrity, and availability of information entrusted to us
• Use company and customer resources responsibly and only for legitimate purposes
• Speak up about wrongdoing and support those who do

4. Respectful workplace

HLD Group is committed to a workplace free from discrimination, harassment, sexual harassment, bullying, and victimisation, consistent with applicable anti-discrimination and work health and safety law. Everyone is entitled to be treated with respect. Breaches are taken seriously and may be reported under the Whistleblower and Speak-Up Policy or to People and Culture.

5. Conflicts of interest

Personnel must avoid situations where personal interests conflict, or appear to conflict, with the interests of HLD Group or its customers. Actual, potential, and perceived conflicts must be disclosed promptly and managed. This includes outside employment, financial interests, personal relationships affecting work decisions, and gifts or hospitality that could improperly influence a decision.

6. Gifts, hospitality, and improper payments

Gifts and hospitality must be modest, transparent, and never given or received to influence a decision improperly. Bribery and corruption in any form are strictly prohibited, as set out in the Anti-Bribery and Corruption Policy.

7. Protecting information and assets

• Confidential and customer information is protected under our data and security policies
• Company assets are used appropriately under the Acceptable Use Policy
• Intellectual property, of HLD Group and of others, is respected
• Personal data is handled lawfully under the Data Processing Policy

8. Integrity in business dealings

• We compete fairly and comply with competition and consumer law
• We do not make false or misleading claims about our services
• We deal honestly with customers, suppliers, regulators, and auditors
• We keep accurate records and do not falsify information

9. Raising concerns

Anyone who becomes aware of conduct that may breach this Code, the law, or company policy is encouraged and, in many cases, expected to raise it. Concerns may be raised under the Whistleblower and Speak-Up Policy, which protects those who report in good faith from retaliation.

10. Framework alignment and enforcement

This Code supports our obligations under applicable employment, anti-discrimination, anti-bribery, privacy, and consumer law, and aligns with SOC 2 CC1.1 (commitment to integrity and ethical values) and ISO 9001 quality management expectations. Breaches may result in disciplinary action up to termination, and referral to authorities where the law requires. This Code is reviewed at least annually.