1. Purpose

Spartan's Code of Business Conduct sets out the principles of conduct and ethical and professional values that all employees of the company must adhere to. It is a foundation for strengthening trust between employees, management and stakeholders, and ensures the orderly, meritocratic and responsible operation of the company.

2. Basic Principles – The Code is based on:

• The applicable labor, civil and criminal law
• The requirements of the law for compliance with the necessary professional licenses and certifications, depending on the job role.
• The General Data Protection Regulation (GDPR)
• The company's internal policies and procedures
• The principles of ISO standards adopted by Spartan
• The fundamental principles of professional ethics, honesty, dignity and integrity

3. Human Rights - Employees:

• Be treated equally without discrimination
• Enjoy respect, dignity and protection from any form of violence, harassment or intimidation
• Work in an environment that promotes equality, acceptance of diversity and trust, with zero tolerance for any kind of violence wherever it comes from (employees, partners, suppliers, customers)
• Subject to the provisions of labor legislation and collective labor agreements

4. Health, Safety & Guidance- The company:

• Ensures working conditions that protect the physical and mental health of employees
• Has a Safety Technician, with the aim of preventing accidents at work

the continuous improvement of safety conditions in the workplace

• Has an Occupational Doctor, with the aim of monitoring the health of employees and promoting health prevention
• Implements a Health and Safety Management System in accordance with ISO standards
• Provides ongoing training and personal protective equipment
• Ensures cleanliness, risk prevention and compliance with all safety rules in vehicles and building facilities
• Protects employees' personal data, in accordance with the General Data Protection Regulation (GDPR)
• Guides staff through written, digital and verbal safety instructions depending on the criticality of the incidents

5. Professional Behavior - Employees:

• Act with integrity, responsibility and respect towards colleagues and third parties
• Comply with the Internal Labor Regulations that they signed when they were hired, as well as the emergency instructions of the Administration depending on its changing needs, the new certifications it receives and the projects it undertakes.
• Avoid acts that constitute a conflict of interest or harm the company
• Contribute to ensuring the quality of services and a positive corporate profile

6. Obligations & Abilities - In detail, employees must:

• Possess or arrange for the timely issuance of all required certificates or licenses related to their role and position, with a maximum time limit of six (6) months from the date of recruitment.
• Carefully adhere to the company's procedures and regulations.
• Submit suggestions, questions or problems in writing to the supervisor or Quality Assurance Officer.
• Actively contribute to the prevention and reporting of incidents of violence, delinquency or near-accidents.
• Demonstrate professionalism, consistency and efficiency
• Organize their work properly and respect schedules
• Strengthen the spirit of cooperation and teamwork
• Seek their continuous personal and professional development
• Meet the expectations of their roles based on Spartan's values, ethics and vision

7. Confidentiality, Confidentiality & Policies - Employees:

• Carefully safeguard information related to the operation of the company
• Do not disclose personal data, financial data, strategic plans, litigation, clientele, agreements, or contracts to unauthorized persons
• Operate with respect to policies:
• Security Policy
• Privacy Policy
• Business Continuity Policy
• Quality Policy
• Health and Safety Policy
• Environment Policy
• Road Safety Policy
• Anti-Bribery Policy

The policies are posted in detail on the official website of Spartan, are updated, modified or enriched at regular or extraordinary intervals, depending on the operational needs and requirements of the inspections. Employees must monitor them, while the company is obliged to inform them digitally via e-mail of any relevant changes that take place on the respective pages.

8. Information Security & Cybersecurity - Given that the confidentiality and security of customer data are self-evident and non-negotiable, all employees, in addition to confidentiality and confidentiality,

• They must respect the security of computer systems.
• Unauthorized software is not allowed to install/download.
• Sharing copyrighted content is expressly prohibited

unlicensed. (contracts, agreements, articles, content of advertising campaigns, etc.)

• They must safeguard physical and electronic records accurately and completely.
• They must follow the instructions of the IT department for the security of data and information systems,

Improper use of IT systems, excessive use of them for self-benefit, and improper file management are strictly prohibited.

9. Assets & Vehicles - Employees are required to protect the company's assets, including vehicles and technological resources. The following are prohibited:

• Waste, damage, destruction, malicious use or theft of equipment.
• The use of vehicles without complying with the rules of safety and road behavior.

10. Emergency Response - The company has an emergency management policy and 24-hour support to ensure business continuity. Employees are trained accordingly to ensure seamless customer service.

11. Work Ethics and Rights - The company promotes:

• Mutual trust and recognition.
• Constructive cooperation and two-way communication.
• The fundamental principles of the International Labour Organization for the protection of labour rights.

Employees actively participate in events, trainings and meetings for the circulation of ideas and their continuous professional development.

12. Education, Culture and Environmental Responsibility - The company actively invests:

• The intellectual and social development of its people.
• The promotion of education, culture and care for the environment.
• Actions and projects that enhance local development and prosperity.

13. Compliance and Monitoring – Employees:

• They must fully comply with the provisions of the Code
• They must immediately inform the supervisors of any violation
• They are liable in case of concealment or tacit acceptance of violations
• Subject to internal control procedures and, if necessary, disciplinary evaluation
• Participate in compliance training programs
• Supported by the Ethics Committee for questions or clarifications

The company strictly adheres to the principles of legality and professional ethics. Any illegal or unlawful competitive practice by an employee directly leads to the termination of the cooperation.

14. Compliance with Internal Procedures

Compliance with the company's approved internal procedures is an obligation of all employees. These procedures concern, inter alia, the following:

• submission and approval of permit applications;
• declaration of extraordinary absence, illness or delays,
• emergency use of company vehicles,
• participation in trainings (internal or external), business trips, presentations, exhibitions, etc.,
• use of a meeting room;
• purchase of consumables,
• submit complaints, incidents or incidents;
• and any other issue related to the smooth operation of the company.

Employees must be informed about the procedures provided by the Head of the Department. Failure to comply with these procedures may result in administrative consequences, as it affects the orderly, transparent and fair functioning of the organization.

15. Report Violations - Employees:

• They have the obligation to immediately report any incident of violation of the Code or relevant policies to: hr@spartan.gr or directly to their immediate supervisor
• They can submit reports confidentially, with full protection of their identity and without fear of reprisals
• Actively participate in investigation procedures and corrective or improvement action plans, if required

The company ensures that all reports are treated with seriousness, confidentiality, and respect for all parties involved.

16. Approval and Date of Application

• The Code is approved by the Spartan Board of Directors
• Application Date: 01.09.2025
• Version Number: 1.0

The Code comes into force from the above date and is mandatory for all employees and partners of the company who provide services in its name.

Failure to comply with the Code of Conduct, the company's policies and principles, entails penalties that can range from a warning to termination of the partnership. In cases of violation of the law, the company reserves the right to proceed with disciplinary and/or legal actions, informing the competent Authorities, if necessary.