This Elso Energy by @mycs Europe bv's Code of Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide all employees and owners of the Company and its subsidiaries. All Elso Energy by @mycs Europe bv employees and owners must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. The code should also be provided to and followed by our agents and representatives. In addition, company policies apply to various company operations and you need to know and follow those olicies that apply to your work.

If a law conflicts with a policy in this code, you must comply with the law. Alternatively, if a local custom or policy conflicts with this code, you must comply with the code as far as this will not bring you or the company in legal danger. Every person in the company is responsible for understanding the legal and policy requirements that apply to their jobs and reporting any suspected violations of law, this code, or Elso Energy by @mycs Europe bv's policy.

Violations of this code may also be violations of the law and may result in civil or criminal penalties for you or the company. If you are in a situation which you believe may violate or lead to a violation of this code, this should be discussed with the directors/owners immediately. The basic principles discussed in this code are subject to any company policies covering the same issues and apply to all Elso Energy by @mycs Europe bv affiliated companies.

1. Compliance with laws, rules and 

Obeying the law, both in letter and in spirit, is the foundation on which this company’s ethical standards are built. All employees and officers must respect and obey the laws, rules, and regulations of the cities, states, and countries in which we operate. Although employees and company owners are not expected to know the details of each of these laws, rules and regulations, it is important to know enough to determine when to seek advice from supervisors, managers or other appropriate personnel.

2. Conflict of interest

A “conflict of interest” exists when a person’s private interest interferes in any way, or even appears to interfere, with the interests of the Company. A conflict situation can arise when an employee or owner takes actions or has interests that may make it difficult to perform his or her company work objectively and effectively. Conflicts of interest may also arise when an employee or owner (or a member of his or her family) receives improper personal benefits as a result of his or her position in the company. Loans to, or guarantees of obligations to, employees and officers and their family members by the company may create conflicts of interest and in certain instances are prohibited by law.

It is a conflict of interest for a company employee or owner to work for a competitor, customer or supplier. You should avoid any direct or indirect business connection with our customers, suppliers or competitors; except as required on our behalf.

Conflicts of interest are prohibited as a matter of company policy, except as approved by the board of directors. Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with the director(s) or follow the procedures set out in Section 19. Any employee or owner who becomes aware of a conflict or potential conflict should bring it to the attention.

3. Insider Trading

All non-public information about the Company should be considered confidential information. Employees and owners who have access to confidential information about the company or any other entity are not permitted to use or share that information for trading purposes, the other entity’s securities, or for any other purpose except for the conduct of the company’s business. To use non-public information for personal financial benefit or to “tip” others who might make an investment decision on the basis of this information is not only unethical, but also illegal.

4. Corporate opportunities

Employees and owners are prohibited from taking opportunities that are discovered through the use of corporate property, information or position for themselves without the consent of the board of directors. No one in the company may use corporate property, information or position for personal gain and no one in the company may compete with the company directly or indirectly. Everyone owes a duty to the company to advance the company’s interests when the opportunity to do so arises.

5. Competiotion and fair dealing

We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance never through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies is prohibited. Each person in the company should endeavor to respect the rights of and deal fairly with the company’s customers, suppliers, competitors and employees. No employee, owner or representative should take unfair advantage of anyone hrough manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other illegal trade practice.

The purpose of business entertainment and gifts in a commercial setting is to create goodwill and sound working relationships, not to gain unfair advantage with customers. No gift or entertainment should ever be offered, given, provided or accepted by any company employee, owner or representative unless it: (1) is not a cash gift, (2) is consistent with customary business practices, (3) is reasonable in value, (4) cannot be construed as a bribe or payoff and (5) does not violate any laws, regulations or applicable policies of the other party’s organization.

6. Political contributions

Except as approved in advance by the chief executive officer or chief financial officer, the Company prohibits political contributions (directly or through trade associations) by the Company or its business units. This includes: (a) any contributions of Company funds or other assets for political purposes; (b) encouraging individual employees to make any such contribution; or (c) reimbursing an employee for any contribution. Individual employees are free to make personal political contributions as they see fit.

7. Discrimination and harassment 

The diversity of the Company’s employees is a tremendous asset. We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment based on race, color, religion, sex, national origin or any other protected class. For further information, consult the appropriate Company policy.

8. Health and safety

The Company strives to provide each employee with safe and healthy work environment. Each employee, owner or representative has the responsibility for maintaining a safe and healthy workplace for all by ollowing environmental, safety, and health rules and practices and by reporting accidents, injuries and unsafe equipment, practices or conditions. Violence and threatening behavior are not permitted.

9. Environmental

The Company expects its employees and officers to follow all applicable environmental laws and regulations and report or discuss if any company working for Elso Energy by @mycs Europe bv is not working according environmental laws and regulations.

10. Record-keeping, financial controls and disclosures

The Company requires honest, accurate and timely recording and reporting of information in order to make responsible business decisions. All business expense accounts must be documented and recorded curately in a timely manner. If you are not sure whether a certain expense is legitimate, ask your controller.

All of the company’s books, records, accounts and financial statements must be maintained in reasonable detail; must appropriately reflect the company’s transactions; must be promptly disclosed in accordance with any applicable laws or regulations; and must conform both to applicable legal requirements and to the Company’s system of internal controls.

Business records and communications often become public and we should avoid exaggeration, derogatory remarks, guesswork or inappropriate characterizations of people and companies that may be misunderstood. This applies equally to email, internal memos and formal reports.

11. Confifidentiality

All must maintain the confidentiality of proprietary information entrusted to them by the company or its customers or suppliers, except when disclosure is authorized in writing by the company owners/directors or required by laws or regulations. Proprietary information includes all non-public information that might be of use to competitors or harmful to the company or its customers or suppliers if disclosed. It includes nformation that suppliers and customers have entrusted to us. The obligation to preserve proprietary information continues even after employment ends.

12. Protection and proper use of company assets

All should protect the company’s assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on the company’s profitability. All company assets are to be used for legitimate company purposes. The obligation to protect the company’s assets includes the company’s proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, rademarks and opyrights, as well as business, marketing and service plans, engineering and manufacturing ideas, designs, databases, records, salary information, and any unpublished financial data and reports. Unauthorized use or distribution of this information is a violation of Company policy. It could also be illegal and result in civil or criminal penalties.

13. Payments to government personnel

The promise, offer or delivery to an official or employee of government and local governments, as well as foreign governments of a gift, favor or other gratuity would not only violate company policy but will also commit a civil or criminal offense.

14. Wavers of the code of business and ethics

Any waiver of this code for employees, directors or representatives may be made only by the board of directors and will be promptly disclosed as required by law or regulation.

15. Reporting any illegal or unethical behavior

Employees are encouraged to talk openly to Elso Energy by @mycs Europe bv owners/directors about observed behavior that they believe may be illegal or a violation of this Elso Energy by @mycs Europe bv Code of Conduct or company policy or when in doubt about the best course of action in a particular situation. It is the policy of the company not to allow retaliation for reports made in good faith by employees of misconduct by others.

16. Improper influence on of auditiors

It is prohibited to directly or indirectly take any action to coerce, manipulate, mislead or fraudulently influence the company’s independent auditors for the purpose of rendering the financial statements of the company materially misleading. Prohibited actions include, but are not limited to, those actions taken to coerce, manipulate, mislead or fraudulently influence an auditor: (1) to issue or reissue a report on the company’s financial statements that is not warranted in the circumstances (due to material violations of generally accepted accounting principles, generally accepted auditing standards, or other rofessional or regulatory standards); (2) not to perform an audit, review or other procedures required by generally accepted auditing standards or other professional standards; (3) not to withdraw an issued report; or (4) not to communicate matters to the company’s audit committee.