Ethics & Compliance

Code of Conduct—Our Shared Commitment

At Zad Treffer, our global team is guided by a strong foundation of shared values—safety, quality, integrity, and transparency—that shape everything we do. We believe that ethical conduct and adherence to compliance standards are responsibilities shared by all. Upholding these values means holding ourselves and our colleagues accountable while fostering an inclusive and respectful work environment.

Our leadership actively encourages open dialogue, prompt reporting of concerns, and a culture of transparency. We empower every team member to raise issues confidently and participate in building a culture of integrity.

The Global Compliance team at Zad Treffer ensures that our operations across all regions align with ethical practices and regulatory standards. Our Chief Compliance Officer collaborates with executive leadership, our Board, employees, and external partners to strengthen our culture of compliance and uphold our commitment to ethical excellence company-wide.

Contacting Ethics

At Zad Treffer, we encourage our team members to voice concerns related to safety, quality, ethics, or potential policy violations. We strive to maintain an environment where everyone feels safe to seek guidance, report issues, and suggest improvements.

We recognize that speaking up isn't always easy, so we provide multiple secure and confidential channels to raise concerns—whether through direct managers, dedicated ethics advisors, phone lines, or web portals. Our Site Ethics Coordinators and Ethics Advocates are available for both in-person and virtual support, offering resources and direction as needed.

Retaliation of any kind against individuals who report concerns in good faith is strictly prohibited and may lead to disciplinary action, including termination.

Zad Treffer Ethics Line (1-888-XXX-XXXX) operates 24/7 and is accessible to all employees, contractors, vendors, and partners.

Global Ethics Portal: Our global ethics services are available around the clock, across multiple regions. You can also report concerns via our web portal.

Compliance

Zad Treffer is committed to maintaining full compliance with all relevant global laws, regulations, and our internal standards. To uphold a strong culture of accountability and compliance, we integrate effective risk management strategies into every level of our operations.

We regularly review and strengthen our internal controls—including policies, training, data analytics, and audit processes—to ensure their effectiveness. Leaders and employees alike receive annual training on key risk areas such as data security, anti-corruption, intellectual property protection, and compliance with government regulations.

Through our Compliance Risk Management (CRM) program, Zad Treffer leaders are equipped to identify, assess, and mitigate compliance risks while promoting transparency, leadership accountability, and operational integrity.

At Zad Treffer, our Compliance Risk Management (CRM) program ensures that senior leaders are actively engaged in identifying, evaluating, and managing enterprise-wide compliance responsibilities. The program is jointly led by our Chief Compliance Officer and Financial Controller, and is governed by the Compliance Risk Management Board (CRMB), which includes senior executives from all major business units and functional areas.

The CRMB is tasked with cultivating a forward-looking compliance culture, embedding compliance risk management into every layer of our organization, and driving the implementation of effective, efficient controls to support our strategic goals. The board regularly reviews key compliance risks and their mitigation strategies, identifies emerging issues requiring attention, and, when necessary, escalates critical matters to the CEO and the Audit & Compliance Committee of the Board of Directors.

In partnership with our Internal Audit team, the CRM program also evaluates and validates the performance and resilience of our compliance controls. This collaboration ensures that controls remain strong, relevant, and aligned with the evolving regulatory landscape.

Anti-Corruption Program

Zad Treffer is firmly committed to maintaining the highest standards of integrity, transparency, and ethical conduct in every aspect of our business. Our Anti-Corruption Program reflects a zero-tolerance approach to bribery, fraud, and all forms of corrupt behavior, ensuring compliance with both local and international laws.

We have established clear policies, regular training, and robust internal controls to guide our employees, partners, and third parties in making ethical decisions. From third-party due diligence to proper handling of gifts, hospitality, and conflicts of interest, every measure is taken to prevent misconduct before it happens.

Our leadership actively oversees the program through dedicated compliance governance structures, encouraging a speak-up culture and swift action when issues arise. Through vigilance, accountability, and continuous improvement, we strive to build and maintain trust with our stakeholders and the communities we serve.

At Zad Treffer, our Compliance Risk Management (CRM) program ensures that senior leaders are actively engaged in identifying, evaluating, and managing enterprise-wide compliance responsibilities. The program is jointly led by our Chief Compliance Officer and Financial Controller, and is governed by the Compliance Risk Management Board (CRMB), which includes senior executives from all major business units and functional areas.

Continuous monitoring and periodic audits ensure the program remains effective and evolves with emerging risks. We also maintain secure and anonymous reporting mechanisms to empower individuals to report concerns without fear of retaliation.

At Zad Treffer, ethical business is not just a policy—it's a principle. Our Anti-Corruption Program is a core part of our values, driving long-term sustainability, responsible growth, and a culture that puts integrity first.