MONT TECH Armenia Corporate Ethics Policy

1. Purpose

The Corporate Code of Ethics (hereinafter – the Code) is an internal organizational and disciplinary document that regulates the ethical, legal, and behavioral principles governing the Company’s Internal and External activities.

The purpose of the Code is to enhance the Company’s reputation and corporate culture, ensure transparency and ethical conduct, prevent conflicts of interest, reduce corruption risks, and provide a healthy and safe working environment.

The main objectives of the Code are:

• to implement the Company’s strategic goals;
• to establish moral and ethical principles in the conduct and activities of the Company’s employees;
• to define the framework of relationships among the Company’s employees;
• o foster a culture in which employees take personal responsibility for the performance of their duties.

The Code has been developed based on universally recognized principles and norms of international law, the legislation of the Republic of Armenia, the Company’s internal legal acts, and the Company’s strategic objectives.

By adopting this Code, the Company confirms its commitment to maintaining a high corporate culture by complying with the provisions of the Code and applying them in daily operations.

This Code applies to all employees of the Company, including those working on civil law contracts, as well as to business Partners.

Company employees are required to be guided by the Code in the course of their daily activities.

Each employee of the Company, from the moment they become acquainted with the Code, undertakes the obligation to comply with it.

2. The Scope of the Policy

This Code covers all activities, including:

• regulating the relationship between employees and the Company,
• defining and maintaining proper conduct within the work team,
• cooperation with investors and Partners,
• cooperation with government authorities and media representatives,
• giving and receiving gifts, providing and receiving services,
• conflicts of interest,
• confidentiality,
• dispute resolution,
• whistleblowing system,
• compliance with the Code and accountability for violations.

Կանոնների պահպանում և խախտման համար պատասխանատվություն։

3. Definitions

• “Company” — ''MONT'' LLC;
• “Code” — Corporate code of ethics;
• “External Relationship” — relationships established between the Company and third parties based on contracts, agreements, memoranda, or other transactions;
• “Internal Relationship” — relationships established or to be established between the Company and its employees, as well as among the employees themselves;
• “Partner” — any natural or legal person, including a partner, supplier, seller, buyer, contractor, bank, government authority, or organization, as well as any other person with whom there is an existing Business Relationship or one that is intended to be established.

4. Application of the Code in Internal Relationships

4.1 Every employee of the Company is primarily considered an investor, actively creating and contributing their human capital.

4.2 Employees of the Company should strive to develop and express their diverse qualities to ensure both their own effectiveness and the high performance of the Company.

4.3 The Company provides each employee with the opportunity to participate in determining the terms of their cooperation.

4.4 The key attributes of every Company employee are professionalism, responsibility, decisiveness, initiative, a desire for development, honesty, fairness, and a readiness to uphold a high corporate culture.

4.5 Work at the Company implies high employee productivity, which contributes to maintaining the Company’s competitiveness and sustainable growth.

4.6 Relationships with the Company’s employees are based on long-term cooperation and the proper fulfillment of mutual obligations.

4.7 The Company considers human capital as a source of successful performance. Employees’ personal interests are taken into account, attention is given to developing their potential, ensuring social guarantees, and maintaining value priorities.

4.8 Enhancing the Company’s competitiveness in business activities is achieved through organizing team and collective work. Teamwork is one of the Company’s core values; however, it does not exclude or diminish employees’ individual responsibility for violations of their obligations as established by law and the Company’s internal regulations.

4.9 Relationships among all Company employees are based on principles of mutual respect and equality. In resolving issues arising in the work process, employees are guided by the Company’s interests, the Code, and the principles of fairness and honesty.

4.10 In all situations arising in business and work environments, employees are primarily obliged to act in the best interests of the Company, preserve its authority and reputation, including in their interactions with Partners and every member of the team.

4.11 An employee of the Company is obliged, in any situation, to prevent and not allow the humiliation of Partners’ personal dignity or professional reputation.

4.12 Employee cohesion and cooperation enable the effective and prompt resolution of work-related issues, which enhances the Company’s competitiveness and attractiveness in the business environment.

4.13 When communicating on work matters, it is unacceptable to make decisions influenced by personal interests, external pressures, or approaches that do not comply with ethical standards.

4.14 The foundation of the Company’s establishment, development, and effective performance is a stable and efficient information environment, where employees can freely exchange any work-related information. This ensures the staff’s effective performance, the integrity of processes, and access to necessary information for every employee.

4.15 Active participation and communication of employees on the Company’s information platforms, the organization of personal meetings and discussions, and the exchange of professional opinions are encouraged. Such communication contributes to strengthening the corporate culture and enhancing the Company’s operational effectiveness.

4.16 Employees are allowed to address work-related issues in an informal manner (without mandatory written procedures) if such an approach facilitates faster, more efficient, and higher-quality performance.

4.17 The Company encourages all forms of collaboration among employees, including implementing joint projects, discussing and resolving work-related issues, developing new approaches to growth, as well as cultural and sports initiatives. These formats help strengthen team spirit and support the effective functioning of the organization.

4.18 Employees are required to act with reasonable care, ensuring that their actions do not harm others and fully comply with the requirements of the law and the standards established by this Code.

5. Application of the Code in External Relationships

5.1 The main principles of the Company’s External relationships

5.1.1 The Company builds its External relationships based on respect, trust, and effective cooperation, while excluding any conflict of interest, abuse of position, and/or any form of corrupt activity, as well as any actions prohibited under the legislation of the Republic of Armenia.

5.1.2 A primary duty of the Company’s employees is to establish and maintain the trust of the Company’s Partners and clients by ensuring a high level of professionalism and reliable cooperation. Each employee serves as a worthy representative of the Company and is obliged to protect its reputation.

5.1.3 Employees are required to focus on effective teamwork, demonstrating respectful behavior toward Partners, clients, and even competitors, in line with high standards of business ethics.

5.1.4 The Company is committed to ensuring the disclosure of accurate, complete, and reliable information regarding its activities, including in relations related to the securities market.

5.2 Relationships with investors, Partners, and competitors

5.2.1 The Company’s External relationships are based on the principles of mutual respect, transparency, and responsibility.

5.2.2 The Company strives to establish and maintain stable, trustworthy, and mutually beneficial relationships with its Partners by meeting their requirements for high-quality services and exceeding their expectations.

5.2.3 The Company is committed to creating and developing partnerships with investors, Partners, and competitors, where each party responsibly and consistently fulfills its obligations.

5.2.4 The Company’s activities are focused on long-term, effective, and mutually beneficial cooperation with Partners, clients, and investors.

5.2.5 The Company highly values its reputation and is strictly committed to preserving it. In all areas of its operations, the Company aims to ensure fair, free, and open competition while complying with all requirements of business ethics and the law.

5.2.6 The Company establishes business relationships by fully aligning its activities with the legislation of the Republic of Armenia, the Company’s internal regulations, and this Code.

5.3 Relationships with Government Authorities and Media Representatives

5.3.1 The Company builds and maintains respectful, constructive, and transparent relationships with representatives of government authorities, avoiding any conflict of interest and complying with the legislation of the Republic of Armenia.

5.3.2 The Company does not undertake unjustified or improper attempts to influence the decision-making of government authorities or public officials.

5.3.3 The Company is a law-abiding taxpayer, fully and timely fulfilling its tax obligations, maintaining proper accounting records, and providing necessary information regarding its activities.

5.3.4 The Company strives to maintain high standards of communication with the media, allowing communication with media representatives only through its authorized representatives.

5.3.5 Employees are strictly prohibited from disclosing or sharing information, facts, or data beyond their official duties with any person, including media representatives, and from abusing their official position in any way.

5.4 Gifts and Services

5.4.1 The Company, valuing an environment of fairness, honesty, trust, and mutual respect, strictly condemns corruption in all its forms and does not tolerate it in the work of its employees or Partners.

5.4.2 Company employees are prohibited from accepting, offering, requesting, or receiving any type of bribe.

5.4.3 Employees are advised not to receive gifts or services from third parties, nor to give gifts or provide services to third parties as a form of gratitude. The acceptance of any gift of monetary value is strictly prohibited, regardless of its amount.

5.4.4 Gifts and services provided by the Company to its clients and Partners are considered given or provided solely on behalf of the Company. Gifts should preferably be souvenirs bearing the Company’s symbols.

5.4.5 Gifts and services must not compromise the honor, reputation, or business standing of the Company or its employees.

6. Conflicts of Interest

6.1 All employees of the Company are obliged to avoid and eliminate situations that cause or may cause a conflict of interest in their personal and professional relationships.

6.2 A conflict of interest arises when:

• personal or family interests may affect the ability to make a reasonable and impartial decision on behalf of the Company and/or hinder the fulfillment of obligations toward Partners, investors, or clients;
• the interests of two or more Partners, clients, or investors conflict, significantly jeopardizing one or all of them;
• the interests of the Company and its Partners, clients, or investors conflict.

6.3 In the event of a conflict of interest, an employee is obliged to report it and obtain permission to continue the business relationship.

6.4 Employees of the Company have the right to conduct their own entrepreneurial activities, provided that such activities do not contradict the Company’s internal regulations and do not create a conflict of interest.

6.5 Employees must notify and obtain prior approval from the Company before engaging in entrepreneurial activities or holding positions in other organizations. Such approval is granted provided that the additional work does not interfere with the employee’s duties at the Company, does not create a conflict of interest, and complies with the requirements of the Labor Legislation of the Republic of Armenia. As a rule, employees are permitted to engage concurrently in scientific or educational activities, provided these do not contradict this Code.

6.6 Employees involved in political life must ensure that it does not affect the performance of their work duties and does not create a potential conflict of interest. It is prohibited to directly or indirectly use the Company’s name or resources to support any political party, candidate, or campaign.

6.7 All employees of the Company are obliged to comply with other internal legal acts of the Company regarding conflicts of interest and with this Code.

7. Confidentiality

7.1 All employees of the Company are obliged to strictly maintain confidentiality and not disclose or misuse any information they become aware of during the performance of their work duties or accidentally, including information related to the Company, Partners, clients, investors, and other individuals.

7.2 The obligation of confidentiality continues indefinitely even after the termination of the employee’s employment relationship with the Company.

8. Dispute Resolution

8.1 All employees of the Company are obliged to avoid conflict behavior and disagreements among themselves or with the Company, while respecting the interests and priorities of Partners, clients, and other stakeholders, adhering to professionalism, gender equality principles, and cultural respect.

8.2 Potential conflict situations must be identified, assessed, and minimized in a timely manner, ensuring continuous monitoring.

8.3 Effective Company operations require that each employee clearly understands the scope of their duties and responsibilities and prevents or eliminates situations that may lead to disputes.

8.4 Dispute resolution should be carried out in a way that minimizes potential harm to the Company’s operations and ensures that the resolution process is as fast and efficient as possible.

8.5 Conflict situations are resolved by the heads of the relevant departments and, if necessary, with the participation of the Company’s Director.

8.6 The Company encourages resolving disputes through constructive negotiations, active listening, and preventive measures.

8.7 The dispute resolution process must uphold the principles of professionalism, fairness, and honesty.

8.8 In the case of disputes in external relationships, employees are required to act solely in the best interests of the Company and immediately inform the Director.

9. Whistleblowing System

9.1 Committed to the highest standards of transparency and accountability, the Company encourages the free flow of information within the Company and ensures mechanisms for detecting and preventing unethical behavior or violations.

9.2 The Company encourages all employees to report any suspected violations or well-founded concerns arising in the workplace.

9.3 The Company adheres to all requirements established regarding whistleblowing, identifying violations, and applying disciplinary measures. All reports are investigated confidentially and appropriately, ensuring that no discrimination, abuse, or any form of retaliation is taken against the person submitting the report.

9.4 Cases that must be reported include (but are not limited to):

• illegal acts defined under the legislation of the Republic of Armenia, as well as violations of the requirements of this Code and other internal regulations of the Company,
• cases of fraud, deception, corruption, acceptance of gifts or other improper benefits,
• any situation posing a threat to a person’s health or safety.

9.5 Any employee who has a reasonable suspicion that any of the above situations has occurred may report it to the Company.

10. Compliance with the Code and Liability for Violations

10.1 Adherence to this Code by all Company employees is a fundamental obligation and a key factor in ensuring a comprehensive and objective assessment of their personal, professional, and business qualities.

10.2 Any employee who is subject to remarks or criticism from the management or Partners concerning alleged breaches of professional conduct or ethics is entitled to request an objective and impartial review, conducted in accordance with applicable legislation and the provisions of this Code.

10.3 Upon the employee’s request, or at the initiative of the immediate supervisor, such review may be carried out on a confidential basis, ensuring the protection of the employee’s personal data and maintaining impartiality throughout the entire process.

10.4 If an employee commits an act that is deemed incompatible with the Company’s reputation or the trust placed in them, the director may initiate a procedure to assess the employee’s potential incompatibility with their position.

10.5 When assessing potential incompatibility with the position, the Company shall take into account the employee’s performance evaluation results, professional qualification documents, and any other relevant materials necessary for reviewing their suitability and professional fitness for the role.

10.6 Corporate culture and adherence to ethical standards are core values for every employee of the Company. Any violation of corporate culture or ethical standards is considered conduct incompatible with the employee’s position.

10.7 Failure to comply with the provisions of this Code may result in reputational damage to the Company and its employees, as well as the imposition of penalties provided by the legislation of the Republic of Armenia and/or the Company’s internal regulations.

10.8 Violation of this Code constitutes a breach of the Company’s internal regulations, and disciplinary measures established by the relevant internal regulations of the Company may be applied to the employee responsible for the violation.