Code of Sustainable Supplier Version 1.1 of September, 2025 Public document. Level A. Contents Social and Environmental Policy Version 2.3 of September, 2025 2 Revision History....................................................................................... 2 Purpose.................................................................................................... 3 Scope....................................................................................................... 3 Policy....................................................................................................... 3 Business Ethics and Compliance....................................................... 3 Anticorruption and Conflict of Interest.............................................. 3 Anti-Money Laundering......................................................................... 4 Protection of Intellectual Property.......................................................... 4 Labor and Human Rights........................................................................ 5 Forced and Child Labor..................................................................... 5 Freedom of Association, Fair Treatment, Non-Discrimination, Diversity and Inclusion............................................................................ 6 Health and Safety................................................................................... 7 Occupational Safety and Health...................................................... 7 Emergency Preparedness.................................................................. 7 Sanitation, Food, and Housing.......................................................... 8 Environmental Protection........................................................................ 8 Feedback Form........................................................................................ 9 Revision History Date 06/2023 08/2025 Version Comments 1.0 Initial version 1.1 Annual revision. Minor edits. Approved By Andrey Shklyarov Andrey Shklyarov This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Purpose Scope Policy Social and Environmental Policy Version 2.3 of September, 2025 3 DataArt is committed to creating value for all its stakeholders, including the communities and societies where it operates and the planet as a whole. In order toTo achieve that, we intend to motivate our suppliers to make a positive impact across each and every area of our supply chain. For that purpose, we urge our suppliers to adhere to the DataArt Code of Sustainable Supplier (CSS) as well as to require their subcontractors to acknowledge and implement the principles of SSM in their operations and across their supply chains. The given Code applies to all Suppliers of DataArt. Business Ethics and Compliance DataArt expects from its suppliers to uphold the highest standards of ethics while conducting their business activities in full compliance with all applicable laws and regulations. Anticorruption and Conflict of Interest: -- All suppliers are expected to fully comply with any other an- ti-bribery/corruption legislation enacted by countries in which they operate as well as the United States Foreign Corrupt Practices Act of 1977, as amended (15 U.S.C. ยง78dd-2) ("FCPA") or the United Kingdom Bribery Act of 2010 ("U.K. Bribery Act") for operations outside the national jurisdictions. -- Suppliers are obliged to avoid conflicts of interest in their work with DataArt. They are expected to report any known family or other close personal relationships with DataArt personnel who have an influence over their engagements with DataArt. -- Giving or receiving gifts between suppliers and DataArt staff members is prohibited unless it complies with the local anticorruption legislation and is not made with the intention of influencing to obtain or retain business or a business advantage or to reward the provision or retention of business or a business advantage, or This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 4 in explicit or implicit exchange for favours favors or benefits. In case of any doubts regarding the national anticorruption legislation, it is highly recommended to stay within the limit of 20 USD for the price of gifts given or received from DataArt staff members, -- Suppliers must report signs of any personnel, representative, or partner performing unethically or engaged in bribery or kickbacks (see feedback form below). Anti-Money Laundering -- Suppliers must comply with all applicable Anti-money laundering (AML) laws and regulations, including but not limited to the Bank Secrecy Act, USA PATRIOT Act, and other relevant laws and regulations. -- Suppliers must conduct a risk assessment of their business operations to identify and properly manage any AML risks. They must have appropriate policies and procedures in place to address those risks. -- Suppliers must report any suspicious activity related to money laundering or terrorist financing to the relevant authorities and cooperate with the company in any related investigations. -- Suppliers must provide training and awareness to their employees on AML laws and regulations and must ensure that their employees are aware of the company's AML policies and procedures. -- Suppliers must maintain accurate and complete records of their transactions and customer information and must retain those records in accordance with applicable laws and regulations. -- Suppliers must conduct appropriate due diligence on their own suppliers and subcontractors to ensure that they also comply with AML laws and regulations. -- Any suppliers must guarantee DataArt that it does not use its operations and facilities for any activity that supports money laundering or terrorist activities or violates the UN or similar sanctions regimes. DataArt may conduct periodic compliance reviews of the supplier's AML policies and procedures and may terminate the supplier's This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 5 contract if they are found to be non-compliant with AML laws and regulations. Protection of Intellectual Property -- Suppliers are to respect the intellectual property rights of others and ensure that any materials or products they provide do not infringe on the intellectual property rights of others. -- Suppliers will use only licensed software and ensure that all software used in the production of goods or services is legitimate and not pirated. -- Suppliers are requested to protect any confidential information provided by the company and not disclose it to any third party without prior written consent. -- Suppliers should assign ownership of any intellectual property created during the provision of goods or services to the company. -- Suppliers are required to cooperate with DataArt in the protection of intellectual property and take reasonable measures to prevent any unauthorized use, reproduction, or distribution of the company's intellectual property. Labour and Human Rights DataArt expects its suppliers to fully comply with all applicable labourlabor protection laws and share its commitment to respect all human rights and to provide equal opportunity in the workplace as set forth in the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the UN Global Compact Principles and the International Labour Organization (ILO) Core Labour Standards. As a result, suppliers must manage their business in such a way in order toto achieve the following results: Forced and Child Labour -- Suppliers will not use or permit any form of forced labourlabor. All work must be voluntary, and all workers must be free to terminate their employment at any time. -- Suppliers will not hold workers' identity, immigration or work This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 6 permit documents longer than reasonably necessary for administrative processing. -- Suppliers are expected not to require workers to pay recruitment fees or other fees for their employment, either directly or through third parties, and are expected to repay any worker that has paid such fees. -- Suppliers will not unreasonably restrict workers' freedom to move into, out of or at working facilities. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the worker's terms of employment in a language understood by the worker, and if internationally relocating, the written agreement will be provided before they leave their country of origin. -- Suppliers will pay legally mandated wages and benefits, will comply with the law regarding wage deductions and will provide workers with the basis on which workers are paid via pay stubs or similar documentation. -- Except in emergency situations, for suppliers' will comply with all applicable laws on work hours and overtime, as well as all applicable laws on wages and benefits. Suppliers should follow the International Labour Organization's Standards on Working Time and should provide living wages to employees. Suppliers will prohibit employee-borne recruitment fees and the retention of employee passports or other travel documents and will provide adequate living facilities (where dormitories are provided). -- Suppliers will not use child labourlabor. 'Child' means any person under age 15, under the age for completing compulsory education or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health or Safety, including night shifts and overtime. -- Suppliers may use legitimate, properly managed apprenticeship programmesprograms, such as student internships. Unless otherwise addressed by local law, suppliers are expected to pay student workers, interns, and apprentices at least the same wage rates as other entry-level workers performing equal or similar tasks. This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 7 Freedom of Association, Fair Ttreatment, Non-Discrimination, Diversity and Inclusion -- Suppliers are to respect employees' right to free association, including their lawful right to join, form, or not join a labourlabor union or otherwise engage in collective bargaining. Any form ofretaliation or discrimination against employees who exercise their right to freedom of association should be strictly prohibited. -- Suppliers should provide equal and fair treatment to all employees, including providing fair wages and benefits, reasonable working hours, and opportunities for career development and advancement. -- Suppliers will not permit harassment, abuse, corporal punishment or inhumane treatment. -- Suppliers will not subject workers or potential workers to unlawful medical tests or physical exams. -- Suppliers will not discriminate in screening, hiring, or employment practices based on race, colour, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status or body art or any personal characteristics. Workers' religious practices will be reasonably accommodated. -- Suppliers are expected to demonstrate a commitment to identify, measure and improve a culture of diversity and inclusion through all aspects of workplace management. -- Suppliers must provide employees with effective grievance procedures for raising workplace concerns, including concerns involving harassment and discrimination, to the attention of managementmanagement's attention for appropriate resolution. This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 8 Health and Safety Suppliers are required to develop and maintain health and safety management practices covering the following aspects: Occupational Safety and Health -- Suppliers are requested to establish an occupational health and safety management system by setting policy, roles, responsibilities, accountabilities, and risk and hazard identification procedures, including recordkeeping, investigation, corrective action, and continual improvement. -- Suppliers will comply with all applicable Safety and health laws and regulations and identify, evaluate and control worker exposure to Safety and health hazards, including chemical, biological, physical, and ergonomic stressors, through proper design, engineering controls, maintenance, safe work procedures and ongoing health and safety guidance. -- Suppliers will protect workers with appropriate personal protective equipment and provide them with information about risks to them from these hazards. -- Suppliers will implement procedures to prevent, manage, track, and report occupational injury and illness, including encouraging worker reporting, classifying and recording cases, providing medical treatment, investigating cases, implementing corrective actions and facilitating workers' return to work. Emergency Preparedness -- Suppliers will identify and plan for potential emergencies and will implement emergency plans and provide guidance to workers on emergency response procedures, including emergency reporting, worker notification and evacuation, drills, fire detection and suppression equipment, exit facilities and recovery plans. Sanitation, Food and Housing -- Suppliers will provide workers with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage and eating facilities. If suppliers provide workers with residential This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Social and Environmental Policy Version 2.3 of September, 2025 9 facilities, those facilities will be clean and safe, with adequate personal space, entry and exit privileges, emergency egresses, heat and ventilation, and hot water for bathing and showering. Environmental Protection DataArt takes responsibility for climate, waste, energy, water and other natural resources and expects its suppliers to share these values by creating products and services with the thought of minimizing their negative impacts on the environment and by adhering to the following actions: -- Suppliers will comply with all applicable environmental laws, regulations, and international treaties, including those that regulate hazardous materials, air and water emissions, and wastes. -- Suppliers will obtain and keep current all required environmental permits, approvals and registrations and follow their operational and reporting requirements. -- Suppliers are requested to apply efforts to reduce the consumption of resources, including raw materials, energy and water, by tracking and minimizing energy consumption and greenhouse gas emissions and seeking ways to improve energy efficiency and use cleaner sources of energy. -- Suppliers must disclose complete, consistent, and accurate scope 1, 2 and 3 greenhouse gas (GHG) emissions data and/or components required to calculate GHG emissions data, -- Suppliers will identify any chemicals, waste, or other materials that may be released and which may pose a threat to the environment and manage such chemicals or materials appropriately to ensure their safe handling, movement, storage, use, reuse, recycling, and disposal. -- Suppliers will identify, monitor, control, treat and reduce hazardous air emissions, wastewater and waste generated from their operations. Identify. -- Suppliers should strive for continuous improvement in their environmental performance by setting environmental goals and regularly reviewing and updating their environmental management practices. This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A. Feedback Form Social and Environmental Policy Version 2.3 of September, 2025 10 If you have encountered a violation of the code or have reason to believe that a violation has occurred, we kindly request that you inform us by completing an anonymous feedback form following the link. If you anticipate a response or wish to communicate with a specialist, please include your email address. We deeply value your assistance, and we assure you that all code-related concerns will be addressed and thoroughly examined. This document is the property of DataArt. The document or any part of it may not be used or reproduced without the written permission Public document. Level A.