All staff and management staff members of ecofleet UK Ltd (The Company) will strive to avoid any conflict of interest between the interests of the company on the one hand, and personal, professional, or business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

The purpose of this policy is to protect the integrity of the company’s decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of our staff and management team.

Examples of conflicts of interest include:

• The company or an employee is likely to make a financial gain, or avoid a financial loss, at the expense of the client
• The company or an employee has an interest in the outcome of a service provided to the client or of a transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome
• The company or an employee has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client
• The company or an employee carries on the same business as the client
• The company or an employee receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of monies, goods or services, other than the standard commission or fee for that service

In the course of meetings or activities, staff members will disclose any interests in a transaction or decision where there may be a conflict between the company’s best interests and the staff member’s best interests or a conflict between the best interests of two parties which the staff member has dealings with.

After disclosure, the staff member may be asked to leave the room for the discussion and may not be able to take part in the decision depending on the judgement of the management team or other staff members present at the time.

Any such disclosure and the subsequent actions taken will be noted in the company’s internal conflicts of interest’s register.

This conflicts of interest’s policy is meant to supplement good judgement; staff members and management team members are encouraged to respect the nature and also the wording of the policy going forward.

ecofleet UK  Ltd ‘s  Proprietary Information

Trade secrets, technology, ideas, customer lists, unannounced financial data, marketing and pricing strategies, and business plans are, among others, ecofleet UK Ltd ‘s  most valuable business assets and protecting their confidential and proprietary nature is the ethical duty of every ecofleet UK Ltd employee. This information must not be disclosed to anyone without proper authorisation. By law, our trade secrets are our property and we all have obligations to protect that property. In the course of your employment you may be given or come into contact with information that is commercially sensitive or which is provided for your information so that you may gain a better understanding of the business, for example at staff briefing meetings. This type of information must not be divulged outside the organisation via any route (e.g. verbal, oral, internet chat room or to the media). Breach of this obligation may result in disciplinary proceedings. When in doubt, contact the Company Secretary.

In addition, no employee must ever attempt to obtain or use another company’s proprietary information for ecofleet UK Ltd ’s benefit or otherwise in violation of law or any applicable agreement.

Information Security

Information is vital to ecofleet UK Ltd ‘s continuing success. Inadequate protection or misuse of ecofleet UK Ltd ‘s information assets could give the company’s competition an unfair advantage, diminish the quality of our products and services, increase the risk of litigation, or otherwise harm the company. All ecofleet UK Ltd employees share a responsibility to our customers, shareholders, and each other to protect ecofleet UK Ltd, customer vendor information assets from unauthorised access, use, modification, destruction, theft, or disclosure and must treat such assets in accordance with any information handling policies issued by ecofleet UK Ltd.

Communication with the financial community and/or media

Employees who are contacted by a member of the financial community or media are not authorised to provide information regarding ecofleet UK Ltd’ s or its business without prior approval. Financial calls should be referred to the Managing Director, or the General manager; calls from industry analysts or the media should be referred to Director.

Reviewed Dec 2021