ETN / ETNPARTS

CODE OF CONDUCT, ANTI-BRIBERY, ANTI-FRAUD AND ANTI-CORRUPTION POLICY

1. Our Commitment

ETN / ETNPARTS is committed to conducting its business ethically, honestly, transparently, and in compliance with all applicable laws and regulations.

This Code establishes the Company's standards of conduct and its policies for preventing and combating bribery, fraud, and corruption.

These policies are communicated and made available to our employees, representatives, suppliers, contractors, business partners, and other third parties that maintain business relationships with ETN / ETNPARTS.

2. Ethical Conduct

All ETN / ETNPARTS employees and representatives are expected to act with honesty, integrity, responsibility, and professionalism.

Business decisions must be based on legitimate considerations such as quality, price, service, experience, and compliance with contractual obligations.

Fraudulent, corrupt, deceptive, or unlawful business practices will not be tolerated.

3. Anti-Bribery and Anti-Corruption

ETN / ETNPARTS maintains a zero-tolerance policy toward bribery and corruption.

It is strictly prohibited, directly or indirectly, to:

• Offer, promise, give, request, or accept bribes.

• Make improper payments to obtain or retain business.

• Provide money, gifts, favors, or other benefits for the purpose of improperly influencing a business decision.

• Pay or receive illegal commissions, kickbacks, or secret payments.

• Use suppliers, agents, intermediaries, or other third parties to make improper payments.

These rules apply to both private commercial relationships and interactions with government officials or public entities.

4. Fraud Prevention

ETN / ETNPARTS prohibits fraud in any form.

Fraudulent conduct includes, but is not limited to:

• Providing false information, invoices, or documents.

• Altering or concealing financial or commercial information.

• Misappropriating Company funds or assets.

• Making false representations to obtain a commercial or financial advantage.

• Intentionally concealing relevant information related to a transaction.

All business and financial transactions must be accurately and transparently recorded.

5. Gifts and Benefits

No employee, representative, or third party acting on behalf of ETN / ETNPARTS may offer or accept gifts, payments, favors, invitations, or other benefits when they are intended to improperly influence a business decision.

Reasonable business courtesies must have a legitimate business purpose and comply with applicable laws and policies.

6. Conflicts of Interest

Employees and representatives must avoid situations in which their personal interests interfere, or appear to interfere, with the interests of ETN / ETNPARTS.

Any actual or potential conflict of interest must be disclosed to management for appropriate review.

7. Employees and Third Parties

ETN / ETNPARTS expects its employees, suppliers, contractors, representatives, and other business partners to maintain standards of conduct consistent with the principles established in this Code.

No third party may be used to perform any activity that would be prohibited if performed directly by ETN / ETNPARTS.

8. Reporting Misconduct

Any employee or third party who becomes aware of or suspects possible bribery, fraud, corruption, or any other violation of this Code is encouraged to report the matter to ETN / ETNPARTS for appropriate review.

ETN / ETNPARTS prohibits retaliation against any person who, in good faith, reports a suspected violation or raises an ethical concern.

9. Compliance

Failure to comply with this Code may result in appropriate corrective action and, where applicable, termination of the employment or business relationship.

ETN / ETNPARTS may periodically review and update this Code to ensure that its compliance principles and policies remain appropriate for the Company's operations and applicable legal requirements.

ETN / ETNPARTS

Committed to integrity, transparency, and ethical business practices.