At Susdev Group Holdings Limited, integrity forms the foundation of our corporate culture and long term strategy. We are committed to conducting all business activities in a lawful, ethical, and responsible manner across every jurisdiction in which we operate. Our Business Ethics Statement reflects our dedication to transparency, accountability, and professional conduct in our relationships with shareholders, employees, clients, partners, suppliers, and regulators.

Integrity and Compliance

Susdev Group operates in strict compliance with applicable laws, regulations, and internal governance policies. We expect all directors, officers, employees, and business partners to uphold the highest standards of honesty and professional conduct. Ethical considerations are integrated into decision making processes to ensure that commercial objectives are pursued responsibly and in alignment with legal and regulatory requirements.

We maintain internal controls and governance mechanisms designed to prevent misconduct, promote accountability, and safeguard corporate assets and information.

Anti Corruption and Anti Bribery

The Group adopts a zero tolerance approach to bribery, corruption, and any form of improper advantage. We strictly prohibit offering, soliciting, or accepting bribes or facilitation payments in any form, whether direct or indirect.

Employees and representatives are required to avoid conflicts of interest and to disclose any situation that may compromise impartiality or professional judgment. We promote a culture of transparency and fairness in all commercial dealings and procurement activities.

Fair Competition and Responsible Conduct

Susdev Group supports fair competition and ethical market practices. We do not engage in anti competitive behavior, collusion, or unfair trade practices. Business decisions are made based on merit, quality, and long term value rather than improper influence.

We are committed to maintaining accurate books and records, ensuring that financial reporting and corporate disclosures reflect a true and fair view of the Group’s operations and performance.

Respect and Workplace Ethics

We foster a professional environment built on mutual respect, diversity, and inclusion. Discrimination, harassment, intimidation, or retaliation of any kind is not tolerated within the Group.

Employees are encouraged to raise concerns regarding unethical behavior or potential violations of policy without fear of retaliation. The Group supports responsible reporting mechanisms to address concerns in a confidential and appropriate manner.

Confidentiality and Data Protection

Susdev Group recognizes the importance of protecting confidential information and respecting privacy rights. We implement appropriate safeguards to secure sensitive business data and personal information entrusted to us.

All employees and business partners are expected to handle information responsibly and in accordance with applicable data protection requirements.

Continuous Improvement

The Business Ethics Statement is subject to periodic review to ensure alignment with evolving regulatory requirements and international best practices. The Group remains committed to strengthening its ethical standards and reinforcing a culture of integrity across all levels of the organization.

Through responsible leadership and principled conduct, Susdev Group seeks to build sustainable trust and long term value for all stakeholders.