The Royal Wagenborg Code of Conduct is intended to make management and employees more aware of the importance of acting with integrity. We aim to achieve this by clearly defining what is considered desirable and undesirable behaviour within Royal Wagenborg, both inside and outside the workplace. As a family business, Royal Wagenborg gives full attention to sustainability, welfare, and health. Being of value to people and the environment is at least as important as financial value. Good employment practices, long-term relationships with employees, suppliers, and clients, and decisions with a long-term perspective are our top priorities. We are solution-driven and, when necessary, go the extra mile to achieve excellent results. We are people of our word, who do what we promise and take pride in our work. We believe in the power of cooperation and human interaction. This makes us a pillar of strength for our customers, colleagues, and the environment.

Everyone is responsible for fostering and maintaining a pleasant and safe corporate culture. Our Code of Conduct sets out the standards and values by which we operate at Royal Wagenborg. It applies to directors, employees, temporary staff, and anyone providing services to, acting on behalf of, or under the instruction of Royal Wagenborg. All employees are expected to act in accordance with this Code of Conduct. No one is exempt.

Scope

This Code of Conduct applies to all management and employees of Royal Wagenborg, including those hired via employment agencies. Management is responsible for ensuring that all employees receive the Code of Conduct. The Royal Wagenborg management may amend the Code at any time. Substantive amendments require the approval of the Central Works Council. If applicable, management will clearly communicate any changes.

Supervisor

Royal Wagenborg management appoints a supervisor to oversee compliance with the Code of Conduct. The supervisor also acts as an advisor within the organisation and ensures consistent application of the Code across all operating companies. The supervisor's responsibilities and authority will be established and communicated upon appointment. See also Appendix 1: "Notes to the Royal Wagenborg Code of Conduct."

Acting Ethically

All management and employees are required to act in accordance with the rules and guidelines set out in this Code of Conduct. This means behaving carefully, ethically, and in a socially responsible manner.

Acting Unlawfully

Employees must always comply with applicable national and international legislation. In particular, employees must refrain from conduct that violates European, Dutch, or locally applicable competition laws, as well as from engaging in criminal activities related to principals and competitors. Working abroad may require compliance with local legislation, customs, and cultural norms. Employees are expected to be aware of this and act accordingly.

Inappropriate Conduct

Wagenborg does not tolerate inappropriate conduct such as bullying, discrimination, smoking in prohibited areas, or (sexual) harassment. This includes any form of verbal, non-verbal, or physical behaviour that is or should be known to be offensive to a colleague or any other person. Employees must treat each other and others with respect. No distinctions may be made based on skin colour, nationality, culture, origin, religion, language, political beliefs, gender, disability, personal beliefs, or sexual orientation. Applicable complaints procedures regarding health and safety are available within the various Royal Wagenborg operating companies.

Confidentiality

Employees must maintain strict confidentiality regarding all sensitive company matters unless required by law to disclose them. This obligation continues even after the termination of employment, as stated in employment contracts. Disclosing confidential information via the internet, social media, or any other means is considered a breach of confidentiality unless written exemption is granted by management.

Safety

Employees must actively contribute to safe working conditions and remain vigilant about their own and others' safety. All employees must comply with the Royal Wagenborg HSEQ Policy Statement and know what is expected of them regarding safety in their specific roles.

Internet and Social Media

The widespread use of the internet and social media has blurred the line between work and private life. While Royal Wagenborg fully respects freedom of expression, employees must remember they represent the company. Use common sense and integrity when posting content related to your work. Be aware that sharing texts or images can negatively affect Wagenborg’s reputation and interests. Detailed guidelines can be found in the "Royal Wagenborg Guidelines on Using Social Media."

Media Contact

The CEO of each Royal Wagenborg operating company is the designated media contact. If approached by the media, employees must not answer questions but should refer the journalist to the respective CEO, regardless of whether the attention is positive or the questions seem harmless. Relevant emergency procedures also apply.

Intellectual Property

All work created during employment at Royal Wagenborg—including drawings, photographs, texts, manuals, and models—remains the intellectual property of Royal Wagenborg. Employees cannot claim copyright on such materials.

Recording Data

All business transactions must be accurately recorded in accordance with the relevant administrative procedures, which must be clear and verifiable.

ICT and Security

Royal Wagenborg has drawn up guidelines to ensure safe and reliable use of its ICT systems:

• Preferably use ICT equipment provided by Royal Wagenborg.

• Do not share your passwords or allow others access to Wagenborg ICT equipment.

• Personal use of the internet and email is permitted provided it does not interfere with work and complies with Royal Wagenborg's Internet and Email Code.

In certain cases, Wagenborg may be legally required to perform inspections or report system misuse to authorities.

Alcohol, Drugs, and Other Substances

Strict regulations apply in many countries regarding the use, possession, or influence of alcohol, drugs, and other narcotics. Misuse endangers not only yourself but also your family and colleagues. Please refer to the alcohol and drugs policies of the Royal Wagenborg operating companies.

Child Labour and Modern Slavery

Royal Wagenborg has a zero-tolerance policy regarding child labour and modern slavery, including slavery, servitude, human trafficking, and forced labour. When procuring goods and/or services, any suppliers or subcontractors found to be involved in these practices will be excluded. Employees are expected to strictly monitor compliance in this area.

Unforeseen Circumstances

If a situation arises that is not specifically addressed in this Code but may conflict with its spirit, the supervisor will assess whether the Code applies and will advise on potential sanctions.

If you witness conduct that violates the Code of Conduct, you must first raise the issue with the person involved. If this does not resolve the matter, you may escalate it to your manager, the HR Manager of your operating company, or the supervisor. Attempts to provoke violations must also be reported. All reports will be treated confidentially, and privacy will be protected.

If you have any questions, uncertainties, or suggestions regarding this Code, please contact the HR Manager of Royal Wagenborg.