Supplier Code of Conduct

INOVIVO Group

May 09, 2025

Table of contents

1. Introduction 1.1. Our company and its core values 1.2. The scope of our Supplier Code of Conduct 1.3. The purpose of our Supplier Code of Conduct 2. Compliance 3. Ethical business practices 3.1. Anti-bribery and corruption 3.2. Avoiding insider trading 3.3. Anti-money laundering 3.4. Confidentiality 3.5. Conflicts of interest 3.6. Fair competition 3.7. Compliance with international trade restrictions 3.8. Prevention of tax evasion and accurate reporting 4. Intellectual property rights and trademarks 5. Human rights and fair labour practices 5.1. Humane treatment and anti-harassment 5.2. Avoidance of discrimination 5.3. Working hours, wages and benefits 5.4. Health and safety conditions 5.5. Prohibition of child or forced labor 5.6. Privacy 6. Environmental protection and sustainability

1. Introduction

1.1. Our company and its core values

Inovivo Group is one of the leading IT and business consulting firms in Hungary. The Inovivo Group includes the following companies: Inovivo Group Ltd., Onespire Ltd., Mindspire Consulting Ltd., and ShareLine Ltd. The management of the companies belonging to the Inovivo Group hereby declare the norms of ethics deemed to be particularly important during daily operations. By conveying a value system, this code of conduct defines the expected ethical behavior and the norms of actions in accordance with our corporate values. At Inovivo Group, we are committed to upholding our core values of trust, respect, transparency, and open communication. During our operations, we only cooperate with Suppliers that comply with the present ethical guidelines of Inovivo Group. Suppliers shall use management systems to facilitate compliance and continual improvement with these principles. By implementing and maintaining management systems, Suppliers help support Inovivo Group’s commitment to excellence, compliance, and sustainable business practices, ensuring a reliable and trustworthy partnership.

1.2. The scope of our Supplier Code of Conduct

This Supplier Code of Conduct (hereinafter: “SCOC”) applies to all Inovivo Group’s suppliers providing services, human resources or products to the Inovivo Group, such as independent contractors, subcontractor companies, partners, recruitment agencies, licensees and lessors, regardless of their specific role or the products or services they deliver (hereinafter: “Suppliers”).

1.3. The purpose of our Supplier Code of Conduct

All companies of Inovivo Group conduct business ethically, and we expect the same from our Suppliers. Our Company’s present SCOC outlines our expectations and offers guidance to help our Suppliers meet these standards. This SCOC sets the highest standards of integrity and honesty for all Suppliers of companies belonging to Inovivo Group. Our SCOC is a system of interrelated components, all of which work together to create a culture of integrity. We expect all our Suppliers to familiarize themselves with this SCOC and to adhere to its principles. Our Suppliers are also expected to be aware of and comply with all relevant state, provincial, and international laws and regulations applicable to their operations, wherever they conduct business. Failure to comply with this Code may result in termination of the contractual relationship with Inovivo Group. Szabolcs István Homola Chairman of the Board of Directors Inovivo Group Ltd.

2. Compliance

Inovivo Group expects all Suppliers to strictly adhere to all relevant laws, regulations, and ethical standards, as well as all the guidelines outlined in this SCOC, which incorporates the following key principles:

• Ethical business practices
• Intellectual property rights and trademarks
• Human Rights and fair labor practices
• Environmental protection and sustainability

3. Ethical business practices

3.1. Anti-bribery and corruption

Inovivo Group strictly prohibits any form of bribery or corruption in connection with its activities. Bribery, corruption, embezzlement and extortion are illegal and Suppliers must avoid any form of bribery, unlawful inducements or related practices with business or government contacts, including through intermediaries. The Inovivo Group enforces a zero-tolerance policy towards bribery and corruption in all forms, regardless of local customs or practices. All business partners, both individuals and organizations, have to uphold these standards globally, irrespective of their location. Inovivo Group is dedicated to full compliance with all relevant anti-bribery and anti-corruption laws in the regions where it operates. Inovivo Group expects its Suppliers to similarly adhere with these laws and to be able to demonstrate compliance upon request. Suppliers shall conduct their business in an ethical manner and act with integrity. Suppliers, including their employees, contractors, and agents, are strictly prohibited from directly or indirectly offering or giving payments or benefit intended to influence any party. Suppliers shall not offer, pay, request or accept any bribe to acquire or retain any business. Suppliers shall establish effective anti-bribery, fraud prevention, and reporting mechanisms.

3.2. Avoiding insider trading

Suppliers shall not unlawfully use any inside (not publicly available) information in their possession or acquired for financial gain nor shall they disclose such insider information to any unauthorized person. Suppliers shall also not disseminate information that affects the trading of financial instruments obtained during their business relationship with Inovivo Group.

3.3. Anti-money laundering

Suppliers must comply with all applicable anti-money laundering laws and regulations and have controls to prevent such illegal activities. Suppliers are expected to inform Inovivo Group if they become aware of any actual or suspected violations of applicable anti-money laundering laws.

3.4. Confidentiality

Inovivo Group is committed to protecting the confidentiality of information across its operations and expects all Suppliers to maintain the same standards of discretion and security. Suppliers must protect all proprietary and sensitive information (hereinafter: “Confidential information”) entrusted to them by Inovivo Group, its clients, and its business partners. Suppliers are required to handle all Confidential information, including but not limited to business plans, financial data, product specifications, customer details, trade secrets, and intellectual property, with the utmost care. Such information must be used solely for its intended purpose and disclosed only to authorized personnel. Suppliers are expected to implement appropriate security measures, including physical, administrative, and technological safeguards, to prevent unauthorized access to, loss or misuse of Confidential information. Suppliers must take prompt action to address any data breaches or security incidents and notify Inovivo immediately if such an incident occurs. Suppliers must not disclose Confidential information obtained through their relationship with Inovivo to third parties without prior written authorization from Inovivo Group. This obligation extends beyond the term of the business relationship and continues indefinitely.

3.5. Conflicts of interest

Inovivo Group expects its Suppliers to maintain impartiality in their business dealings and to avoid any situations that could create, or appear to create, a conflict between personal interests and professional responsibilities.

• Avoidance of conflicts: Suppliers must avoid any activities, relationships, or financial interests that could interfere or be perceived to interfere with their ability to act in Inovivo Group’s best interests. This includes avoiding personal or business relationships that could influence decision-making.
• Disclosure obligations: Suppliers are required to promptly disclose any actual, potential, or perceived conflicts of interest to Inovivo. Transparency in reporting these situations allows for appropriate management and resolution.

3.6. Fair competition

Inovivo Group is committed to maintaining fair and open competition in all markets in which it operates and expects its Suppliers to comply with these principles by conducting business ethically and in full compliance with all applicable competition laws. This includes any unethical practices that unlawfully restrict competition. All business dealings should be conducted with integrity and respect for fair competition. Suppliers must not enter into agreements or exchange information with competitors that could lead to conflicts of interest or restrict competition. This includes avoiding any arrangements or discussions related to pricing, market sharing, or limiting production.

3.7. Compliance with international trade restrictions

Inovivo Group requires its Suppliers to comply fully with all applicable trade restrictions, export controls, and economic sanctions laws in the regions where they operate. Suppliers must ensure that they do not engage in or support any transactions, business activities, or shipments that are restricted or prohibited by international, national, or local sanctions, trade regulations or import/export embargos. This includes refraining from doing business with any sanctioned countries, entities, or individuals, as specified by the relevant authorities, or governments. Suppliers are expected to implement measures to monitor compliance with these regulations and to conduct due diligence on their supply chains to identify and avoid prohibited transactions. Suppliers must promptly report to Inovivo Group any potential violations of trade restrictions or sanctions that may impact their business relationship with Inovivo Group.

3.8. Prevention of tax evasion and accurate reporting

Inovivo Group is committed to lawful and transparent tax practices and expects its Suppliers to uphold the same standards. Suppliers must comply with all applicable tax laws and regulations and must not engage in or facilitate any form of tax evasion, either directly or indirectly. Suppliers should ensure that all transactions and financial reporting are accurate and complete, reflecting true business activities and Suppliers shall act in accordance with the legal bookkeeping practices. Inovivo Group reserves the right to request evidence of compliance with tax obligations from Suppliers.

4. Intellectual property rights and trademarks

Inovivo Group values and rigorously protects intellectual property (IP) rights as a cornerstone of innovation and ethical business practice. Our suppliers must respect intellectual property by securing these rights and complying with all applicable laws and regulations related to the protection of intellectual property. Suppliers must ensure that they respect the intellectual property of Inovivo Group, other business partners, and third parties by not engaging in or supporting any unauthorized use, reproduction, distribution, or alteration of copyrighted materials, patents, trademarks, trade secrets, or other proprietary information. Any intellectual property created or developed as part of a business relationship with Inovivo Group should be disclosed, and the rights associated with such intellectual property should be managed in accordance with applicable agreements between the parties and regulations concerning to IP laws. Suppliers must protect Inovivo Group’s intellectual property, trademarks, and other proprietary information. Suppliers are only authorized to use Inovivo Group’s intellectual property as necessary for approved business purposes and must not share, misuse, or misrepresent these assets. Any use of Inovivo Group’s trademarks must align with company guidelines and be pre-approved in writing.

5. Human rights and fair labour practices

5.1. Humane treatment and anti-harassment

The Inovivo Group supports and respects the protection of internationally proclaimed human rights. Suppliers must treat all employees with respect and dignity, protecting them from any form of harsh or inhumane treatment, including violence, mental or physical coercion, bullying, public shaming, or verbal abuse. There must be no threat of such treatment. Disciplinary policies and procedures supporting these standards should be clearly defined and communicated to all employees. Suppliers shall not engage in behavior that could be characterized as offensive, intimidating, humiliating, degrading, malicious or insulting. Suppliers shall be committed to ensuring the human rights of workers and to treating them with dignity and respect.

5.2. Avoidance of discrimination

At the Inovivo Group nobody can benefit from or be disadvantaged by their gender, age, origin, race, nationality, religion, political affiliation, family relationships, physical disabilities, sexual orientation, membership in any interest representation organization, or any activities related thereto. Exceptions shall include positive discrimination regulated by law. Inovivo Group expects its suppliers to uphold equal opportunity and fair treatment in employment and occupation, free from discrimination based on race, color, sex, religion, political opinion, national or social origin, or any other grounds recognized by the laws of the country or countries in which the contract is performed.

5.3. Working hours, wages and benefits

Working hours at Suppliers must not exceed the maximum limits established by local law. Suppliers must comply with all applicable wage and benefit laws, including those covering minimum wage, overtime rates, equal pay, and legally mandated benefits.

5.4. Health and safety conditions

Suppliers must guarantee health and safety in their workplaces, prioritizing the well-being of their employees and any individuals who may be affected by their operations. Suppliers shall provide a safe and healthy working environment and support the well-being of workers.

5.5. Prohibition of children or forced labor

Suppliers must strictly prohibit all forms of forced labor, including bonded labor, debt bondage, indentured servitude, slavery, and human trafficking. The Inovivo Group condemns child labor, as well as other forms of exploiting children and minorities; it shall not allow the performance of child labor and will not accept any such activities from its partners, either. All Suppliers of the Inovivo Group are required to be aware of these principles and apply them in their operations.

5.6. Privacy

Suppliers shall respect people’s privacy and comply with personal data protection laws; obtain personal information that is necessary and provide appropriate information to data subjects in accordance with the law. Inovivo Group business partners shall adopt appropriate security measures to ensure the confidentiality, integrity and availability of information. Suppliers must comply with all applicable laws and regulations concerning data protection and privacy. This includes compliance with any industry-specific confidentiality requirements, as well as national and international privacy laws governing the handling, storage, and transmission of sensitive information.

6. Environmental protection and sustainability

Inovivo Group is dedicated to promoting sustainable practices that support environmental protection and conservation. We expect our Suppliers to share this commitment by implementing responsible practices that prioritize the well-being of the planet and contribute to a more sustainable future. Suppliers are encouraged to actively engage in these areas. Environmental protection shall comply with all applicable local, national and international environmental laws and regulations in the regions in which they are carried out. All necessary environmental permits, licenses, information registrations and restrictions shall be obtained, and their operational and reporting requirements must be complied with. Suppliers shall integrate environmental sustainability into their business strategies and consider the long-term impacts of their operations. This includes taking proactive steps to reduce the environmental footprint of their processes, products, and services, while actively seeking opportunities to improve environmental performance. Suppliers shall operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment and must comply with all applicable environmental laws and regulations, as well as adhere to industry best practices to prevent environmental degradation. Suppliers are expected to conserve natural resources, preserve biodiversity, reduce their greenhouse gas emissions, conserve water, and manage waste responsibly. This includes setting targets to lower emissions, reducing water consumption, and implementing waste reduction-, recycling- and disposal measures. Suppliers should adopt practices that minimize their impact on air-, water- and soil quality, with a goal of achieving continuous improvement in their environmental performance.