HUEN CODE OF CONDUCT

VERSION 1.0 · EFFECTIVE 1 MARCH 2023 REPORTING: INFO@PROFIXEPSZER.HU

How we work, and what we expect of one another

We work on industrial sites where several companies' crews move at once, often in several languages. In that environment a written rule is the only shared language. This code sets out what we expect of ourselves, and of everyone who works in our name.

01 · Compliance with the law

We comply with Hungarian law and applicable EU regulation, together with the authority and client requirements in force on each site. Where the law and our own rules differ, we apply the stricter one. We do not break the law for commercial advantage, and we ask that of no employee — for no deadline and no order.

02 · Health and safety

Safety is not tradeable against schedule or cost. Any of our employees, any subcontractor, or any client representative may stop a work operation they consider unsafe, and will never suffer for it. Stopping work is not conflict — it is the expected behaviour.

• Personal protective equipment is mandatory across the whole site, without exception, for visitors and managers too.
• Entering site under the influence of alcohol or drugs is prohibited and results in immediate removal.
• Every incident is reported and investigated, including near misses that caused no injury. The purpose is to remove the cause, not to find someone to blame.
• Nobody starts work without valid safety training, medical fitness and completion of the site's access procedure.
• Work at height, lifting operations, plant and electrical work, excavation, confined spaces, chemicals and hot works require separate planning, supervision and a written permit.

Safety also covers workload and fatigue. Predictable rosters, respected rest periods and the freedom to flag overload are as much a safety matter as a guard rail.

03 · Fair employment

The same standard applies on every site and at every tier of subcontracting. The working conditions of the person at the bottom of the chain are our responsibility too, even where we are not the direct employer.

• Declared employment, a written contract, contributions paid, and accurate records of hours worked.
• Wages paid on time, without deduction or withholding. Overtime is accounted for as the law requires.
• Forced labour and child labour are prohibited. Young workers are engaged only within the applicable restrictions.
• We never retain documents, passports, wages or personal papers. Employment may be ended freely, in line with the contract.
• No recruitment fee, deposit or PPE cost is charged to the worker: these are the employer's expense.
• Workers arriving from abroad receive their contract and working conditions in a language they understand, before starting. Where accommodation is provided it is clean, heated, lockable and free to leave.

04 · Equal treatment and a harassment-free site

Our crews come from several countries and we work in several languages. We treat that as a strength. Hiring, pay and promotion decisions are made on professional performance and suitability alone.

• We do not tolerate discrimination on the basis of nationality, origin, language, religion, sex, age, health, family situation or trade-union membership.
• Harassment, intimidation and degrading treatment are unacceptable — including when "that's how it's done here", and including from a position of authority.
• Pregnancy and parenthood are never grounds for disadvantage.
• A language gap must never be the reason a safety instruction is misunderstood: safety briefings are delivered in a language each person understands.

We respect the right to organise and to be represented. We do not obstruct lawful worker representation, and nobody is disadvantaged for taking part in it.

05 · Environment and resources

Construction is material- and energy-intensive. We do not claim it can be done without environmental impact — we do claim that the impact can be measured and reduced.

• We comply with environmental law, permits and the client requirements applying to each site.
• Waste is segregated on site and handled in the order prevent, reuse, recycle. Hazardous waste handling is documented.
• Chemicals and hazardous substances are stored, handled and disposed of as prescribed; preventing soil and water contamination is a baseline requirement.
• We reduce energy and fuel use, plant running time and idling wherever technically and commercially justifiable.
• Noise, dust and vibration are planned for and limited, with regard to neighbouring properties and to the plant operating on site.

06 · Business integrity

We win work on capability and price, not on favours. Neither directly nor through an intermediary do we give or accept any advantage intended to influence a decision.

• Bribery and kickbacks: zero tolerance. This includes facilitation payments made to speed up an official or client decision.
• Gifts and hospitality: only at customary business scale, openly, and never close to a decision. If you would be uncomfortable reporting it, it cannot be accepted.
• Conflicts of interest: personal or family interests must be declared to management before a decision is made. The problem is not that they exist, but that they go unmentioned.
• Fair competition: we do not align prices, share out markets, or contact competitors to influence the outcome of a tender.
• We take no part in money laundering or its facilitation; unusual payment requests are investigated before we contract.

07 · Documents, materials, certificates

In construction the paperwork is part of the works. A falsified test record or an untrue declaration of performance becomes a structural risk years later, so we treat this section as seriously as we treat safety.

• We neither produce nor accept false or back-dated timesheets, invoices, test records, handover documents or training registers.
• Materials are installed only with a genuine, verifiable declaration of performance and traceable origin. Counterfeit or unapproved material is never built in.
• Design and material changes are agreed and documented in writing. Concealed work is evidenced with photographs and a record before it is covered.
• We report defects rather than cover them. Fixing something always costs less than the consequence of hiding it.

08 · Data, confidentiality, IT security

We treat our clients' drawings, technical solutions and commercial data as confidential, for the period agreed and after the work ends. Personal data of employees and applicants is processed under the GDPR, only for the necessary purpose and period. Photographs and video on industrial sites are taken only with the client's permission, and used as references only with written consent. Access rights are personal, and suspicious events are reported immediately.

09 · Subcontractors and suppliers

A significant part of our capacity is delivered with partners, so this code extends to them. By contracting, a subcontractor or supplier undertakes to

• comply with this code and impose it on its own subcontractors;
• evidence lawful employment, wage payment and safety training on request;
• permit site inspection and the review of documents;
• report breaches without delay and remedy identified shortcomings by the agreed date.

We select partners transparently, on capability, price and compliance. Serious or repeated breach ends the contract.

11 · Operation and review

A code is worth something only if it is not left in a drawer. Therefore:

• site and HSE managers are responsible for communicating and enforcing the code in their area;
• the code forms part of site induction and is an annex to every contract;
• compliance is checked through site walks and document reviews;
• the code is reviewed annually, and after any change in law or serious incident.

This document is public and available in Hungarian, English and Chinese on request. The Hungarian version governs; the English edition is provided for information.