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Code of Conduct

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Code
of Conduct

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Integrity, transparency, and fairness play a
central role at inDrive Group and shape how we
perceive ourselves. This Code of Conduct sets
out inDrive Group’s values and the guiding
principles of its ethics and business conduct. The
Code of Conduct is adopted and approved by the
Chief Executive Officer and the Board of
Directors.
The Code of Conduct outlines the Company’s
expectations regarding the behavior of all
employees towards their colleagues, Managers,
and inDrive Group as a whole and any other third
parties with whom they interact.
The Company expects all employees to follow our
Code of Conduct. All employees must avoid
offending others, participating in serious
disputes, and disrupting the workplace.
The Company expects them to foster a wellorganized, respectful, and collaborative
environment.
The words ''Company'' or ''inDrive Group'' as used
in this Code include each and every company
or legal entity that belongs to INDRIVER Holdings
Inc. a Delaware company and its subsidiaries
worldwide.
This Code of Conduct applies to all employees of inDrive Group. Failure to comply with the Code of
Conduct can seriously impact our business and reputation, leading to significant fines.
The Company also expects its third parties to know and comply with this Code of Conduct.
This Code of Conduct sets out the minimum requirements of behavior and cannot anticipate every
situation in which an employee has to make a decision. The Company also takes responsibility in
situations for which there are no clear rules or in which they can be interpreted in different ways.

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This Code of Conduct sets out inDrive Group’s values and guiding principles of its
ethics and business conduct.

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COMPLIANCE, INTEGRITY AND ANTI-CORRUPTION
line. Reporting violations" for more details.
. Please see Section
"Integrity
. Please see Section "Integrity line. Reporting violations" for more details.

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The Company expects employees to avoid any personal, financial, or other interests that may hinder their
capability or willingness to perform their job duties. It is important to avoid conflicts between private and
business interests, or even the appearance of such a conflict.
All employees must always act in the best interests of the Company and must inform the Compliance &
Risk Department of any business or financial interest that could be seen as conflicting or possibly
conflicting with the performance of their duties.
More information can be found in the “Conflict of Interest Policy”. If an employee is unsure whether a
particular situation creates a conflict, the employee needs to contact the Compliance & Risk Department.
Please see Section "Integrity line. Reporting violations" for more details.
. Please
see Section "Integrity line. Reporting
violations" for more details.

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SUSTAINABILITY AND SOCIAL RESPONSIBILITY
. Please see Section
"Integrity line. Reporting violations" for more details.

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Human & Labor Rights
The Company conducts its business activities based on respecting the following human and labor
rights:
1. Workplace Non-Harassment
2. Equal Opportunity, Diversity and Inclusion

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3. Non-Discrimination
The Company does not tolerate any form of discrimination and embraces diversity, actively encourages
inclusion and creates an environment that fosters each employee’s individuality in the interests of the
Company.
Protected characteristics include: race, color, religion, national or ethnic origin, ancestry, sex (including
pregnancy and related conditions), gender (including gender identity and expression), sexual orientation,
marital status, genetic information, age, disability or any other characteristics protected by applicable
laws
4. Fair Labor Practices
5. No Forced or Child Labor
6. Training and Communication
SANCTIONS AND EXPORT CONTROL REGULATIONS
Sanctions and export control regulations determine where and with whom the Company can do
business. The Company complies with applicable sanctions and export laws and regulations.
Failure to comply with these laws can seriously impact our business and reputation, leading to
significant fines.

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Each employee must:
• obtain and process only the information that is necessary and directly related to
fulfillment of one’s work responsibilities;
• retain said information in such a way that outside parties are prevented from
becoming aware of it or accessing it; and
• respect and comply with the confidential information of the Company's third parties.

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Integrity line. Reporting violations
The Company promotes the reporting of potential violations of the Code of Conduct. The Company
has adopted a “Whistleblower Policy” that encourages all employees to come forward if they have
any information on illegal practices or potential violations of the Company’s adopted policies.
The Company’s policies protect the whistleblower from retaliation and has implemented a process
for reporting potential violations. More information can be found in the “Whistleblower Policy”.
HOW TO MAKE A REPORT?
NO RETALIATION
The Company offers several channels
for raising concerns, use the channel
that is most comfortable for you.
Your Manager and the People & Culture
Department will be in the best position to
resolve a compliance concern quickly.
However, the Manager and the People &
Culture Department are not your only option.
Other channels include:
Anyone found to have engaged in retaliation
will be subject to disciplinary action, up to and
including termination.
If an employee feels that they have been
subject to retaliation or suspects that another
person has been subject to retaliation, they
should report this through one of the channels
referenced in this section
via e-mail [email protected]
In situations where you urgently require
confidential advice or if you have concerns
that cannot be addressed through your
Manager or People & Culture Department,
please contact the Head of Compliance &
Risk Department in accordance with the
“Whistleblower Policy”.
via anonymous channel Integrity line
https://indrive.integrityline.com
in person
Head of Compliance & Risk
Department
https://teammate.indrive.io
AFTER A REPORT IS
RECEIVED
All reports of potential violations will be
appropriately investigated and treated
confidentially to the extent possible
considering the Company’s need to conduct
an investigation and follow up on any
concerns.
Any concern raised will be taken seriously,
investigated, and responded to appropriately.
The Company may take legal action in cases
of corruption, theft, embezzlement, or other
unlawful behavior.
The Company may have to take disciplinary
action, including termination of employment,
against employees who repeatedly or
intentionally fail to follow the Code of Conduct.

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Key questions for self-assessment
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