1. Purpose

The Spartan Supplier/Partner Code of Conduct sets out the basic requirements that we expect all individuals or entities working with us to meet. It is the guide of ethics and responsibility towards stakeholders, human resources, business partners, customers and the environment.

2. Basic Principles The Code is based on:

• At the Beginnings of the United Nations Global Compact
• Anti-corruption and bribery legislation and regulations
• The General Data Protection Regulation (GDPR)

3. Legal Compliance – Legal Procedures Suppliers/Partners:

• Comply with applicable laws and regulations
• Maintain confidentiality for data, correspondence and personal information
• Protect assets and intellectual property of Spartan and its clients
• Avoid illegal practices and improper use of resources
• Manage pending litigation and investigations responsibly and transparently
• They participate in any administrative or judicial proceedings, if required by the competent authorities, in the context of their cooperation with Spartan or in accordance with the applicable legal framework
• They ensure that they hold and maintain in force all the licences, approvals or certifications required under the applicable national and EU legislation to carry out their activity (e.g. operating licence, professional licence, licence from competent regulatory authorities, where required)

4. Respect for Human Rights Suppliers/Partners:

• Enhance equal opportunities without discrimination
• They respect the dignity and rights of every individual
• They do not accept harassment or abuse
• Ensure fair pay and working conditions
• They recognize the freedom to work and the right to trade unionism

5. Child Labor

• Child labor below the age limits set by law is explicitly prohibited

6. Health and Safety Suppliers/Partners:

• Ensure the health and safety of their employees
• Control risks and implement preventive measures
• Provide ongoing health and safety education

7. Environmental Protection Suppliers/Partners:

• Comply with environmental legislation and have the necessary permits where required
• Reduce environmental impact and implement improvement practices

8. Supply Chain Suppliers/Partners:

• They must ensure that their supply chain partners (such as subcontractors, suppliers, transport or service providers) also comply with the principles and requirements of this Code of Conduct.
• They actively encourage and promote the adoption of appropriate ethical, legal and environmental standards by the third parties with whom they cooperate.
• They are responsible for the conduct of their partners, to the extent that it affects or relates to the services or products provided to Spartan.

9. Anti-Corruption & Bribery - Transparency Suppliers/Partners:

• Committed against bribery and facilitation payments
• Act with integrity in all transactions
• They do not offer or accept benefits for an unfair advantage
• Abide by all laws and principles of transparency

10. Conflicts of Interest & Competition Suppliers/Partners:

• They state any relationships that may affect objectivity
• They avoid practices that violate fair competition

11. Consent & Controls Suppliers/Partners:

• Accept professional ethics audits by Spartan or third - party competent bodies in cases of complaint or other need
• Provide documentation and cooperate during audits

12. Reporting Violations Suppliers/Partners:

• They are required to report incidents within 24 hours to: info@spartan.gr
• Participate in improvement plans in cases of non-compliance

13. Information and Communication

Suppliers/Partners must ensure that the content of this Code of Conduct is promptly and clearly communicated to all their employees, as well as to any third party directly or indirectly involved in transactions with Spartan. Keeping up to date and ensuring an understanding of the requirements of the Code is the sole responsibility of the Suppliers/Partners.

14. Approval and Date of Implementation

• Policy approved by SPARTAN Management
• Date of Application: 01.09.2025
• Version Number: 1.0

The policy is effective from the above date and is mandatory for all suppliers, partners and third-party employees who do business with Spartan.