I. Introduction

This CODE OF ETHICS AND BUSINESS CONDUCT by ABRAMTRUST establishes our ethical commitment and provides guidance on proper business conduct for all stakeholders. At ABRAMTRUST, we pledge to conduct our business legally, ethically, and transparently. This document applies to all ABRAMTRUST staff, including officers, directors, managers, team leaders, employees, temporary, agency, interim, subcontractor, or consultant staff. It also extends to other organizations engaging in business with us. ABRAMTRUST expects its staff to be impartial and honest in all job-related matters. All staff members share the responsibility to act in good faith and preserve the trust essential for employment. The success of our business hinges on the trust we build with employees, customers, and shareholders. We enhance credibility by upholding our commitment to fairness and achieving our goals through ethical conduct. Staff members are required to adhere to this Code in both their professional and personal conduct, treating everyone with respect, honesty, and fairness. ABRAMTRUST encourages questions at any time and prohibits punishment or retaliation against anyone reporting misconduct in good faith.

Managers and leaders have a higher responsibility to demonstrate the importance of this Code through their actions. They must promptly address any raised ethical questions or concerns, with employees expected to cooperate in investigations of potential or alleged misconduct.

Non-compliance with this Code is considered misconduct and may result in disciplinary action, including termination of employment or other contracts in deserving cases.

We are committed to applying our values and norms throughout the entire value chain, including suppliers, subcontractors, service providers, and business partners.

II. Ethical Principles

Our core values at ABRAMTRUST are:

●Trustworthiness

● Responsibility

● Accountability

● Reliability

● Obedience to the law

III. Ethical Decision-making

Ethical conduct is driven by values in decision-making. Key questions help identify situations that may be unethical, inappropriate, or illegal. Ask yourself: Is what I am doing legal? Does it reflect our company values and ethics? Does it comply with the Code and company rules/policies?

IV. Compliance with laws and regulations

Our commitment to integrity begins with complying with laws, rules, regulations, and contractual agreement. We understand and comply with the legal requirements and commercial practices of lawful business.

V. Sustainability

We commit to meeting current requirements without compromising the needs of future generations. We consider economic, environmental, and social factors in our operations and business decisions.

VI. Human rights

We commit to respecting the dignity and rights of each individual and community we interact with during work.

VII. Fair labor practices and working conditions

We commit to promoting equality in employment practices and fair employment and remuneration policies in compliance with applicable laws. We oppose employing or contracting child or slave labor or any form of forced or compulsory or bonded labor. We condemn all forms of illegal, unfair, unethical labor practice that exploits workforce, destroys social security or serves as tax evasion, including but not limited to undeclared and “grey” work or holding back wages.

VIII. Discrimination and harassment

We ensure equal employment opportunities and strictly prohibit any form of discrimination, harassment, or abuse.

IX. Health, Safety and Environment

We provide clean, safe and healthy work conditions and we are dedicated to maintaining a healthy environment.

X. Fair competition and business conduct

Our connections with business partners are founded on trust and mutual advantages, in accordance with competition law. We are committed to upholding ethical and fair competition, selling products and services based on their quality, functionality, and competitive pricing.

Our personnel is entrusted with ensuring equitable business practices in their roles, adhering to all competition, consumer protection, and fair marketing regulations. Customers and business partners will receive fair and equal treatment, and products and services will be presented in a manner that is just, accurate, and transparent, following fair marketing and advertising standards, with all pertinent information disclosed.

XI. Anti-corruption

We firmly condemn all forms of corruption. It is prohibited directly or indirectly offering, promising, giving, asking, soliciting or accepting any unfair advantage or benefit, in order to obtain, retain or facilitate in any way the business.

XII. Gifts and Hospitality

We shall avoid any actions that create a perception that favorable treatment was sought, received or given in exchange for personal benefits.

XIII. Security, protection and proper use of company assets

We are responsible for the security, protection and for the economic use of company resources. Our resources, including time, material, equipment and information are provided for legitimate business use only. Occasional personal use is permissible as long as it is lawful, does not affect job performance or disrupts workplace morale.

All staff is obliged to follow appropriate security measures and they should treat company property, whether material or intangible, with respect and shouldn’t misuse company assets or use it carelessly.

XIV. Confidentiality, information security, proprietary information and intellectual property

We are committed to business information confidentiality, integrity and accessibility, we implement proper technical security measures this and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorized parties. All staff must handle any such information as secret.

XV. Bookkeeping, true reporting and financial integrity
We must uphold detailed and accurate records, accounts, and financial statements that faithfully reflect our transactions. We condemn all types of money laundering and are dedicated to engaging in business with partners involved in legitimate activities using funds derived from lawful sources.

XVI. Anti-Fraud
Fraud, encompassing actions or intentions to cheat, steal, deceive, or lie, is not only unethical but, in most instances, constitutes a criminal offense. All forms of fraud, such as submitting false expense reports, forging or altering financial documents or certifications, misappropriating assets, misusing company property, and making untrue entries on records or statements, are strictly prohibited.

XVII. Conflict of Interests

Our decisions shall be based on objective and fair assessments avoiding the possibility of any improper influence. A “conflict of interest” exists when an employee’s personal interest (that can be linked to e.g. friends, family, or customer, competitor, supplier, contractor entity, as well) interferes or potentially interferes with the best interests of ABRAMTRUST.

XVIII. Privacy, personal data protection

We respect people’s privacy and we acknowledge customers, employees and other natural persons’ need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to comply with all personal data protection laws. We only acquire and keep personal information that is necessary and we give proper information on these activities to data owners. We implement proper security measures to assure confidentiality, integrity and availability of personal information.