Message from the Management

At Eleven Access, our values and commitment to ethical business conduct form the foundation of how we operate and how we build relationships with our employees, partners, clients, and communities.

Integrity, professionalism, and respect guide our decisions and our daily work. We are committed to conducting our business responsibly and in compliance with applicable laws and regulations in all countries where we operate.

Our company expects the highest standards of ethical behavior from everyone representing Eleven Access, including employees, subcontractors, suppliers, and business partners.

We do not tolerate corruption, fraud, discrimination, harassment, or any form of human rights abuse. We are committed to creating a working environment based on fairness, equal opportunities, and mutual respect.

As a company operating in international projects across Europe, we recognize our responsibility to contribute positively to society while minimizing our environmental impact. We aim to build long-term partnerships based on trust, transparency, and professional excellence.

Everyone working with or on behalf of Eleven Access is expected to follow not only applicable laws but also the principles outlined in this Code of Conduct.

Any concerns regarding potential violations of laws, ethical standards, or company policies should be reported promptly so they can be addressed appropriately.

Ethical behavior is a shared responsibility. By acting with integrity and accountability, we contribute to building a safe, respectful, and sustainable business environment.

Our Purpose, Values and Culture

Our Purpose

At Eleven Access International Services SRL, our purpose is to support the success of our partners and clients by delivering reliable services, responsible workforce solutions, and operational support across Europe.

Through our activities in transportation services, workforce recruitment, and integrated operational support, we contribute to the development of projects that create economic value, strengthen partnerships, and support the sustainable growth of businesses and communities.

Our purpose reflects our commitment to professionalism, reliability, and responsible business conduct. By working collaboratively with our clients and partners, we aim to create long-term value while maintaining high ethical standards and operational excellence.

Our Core Values

Our core values define who we are as an organization and guide how we conduct our business. They shape the decisions we make and the relationships we build with our employees, clients, suppliers, and stakeholders.

Integrity

Integrity is the foundation of our company. We conduct our business with honesty, transparency, and accountability. We expect all employees and business partners to act ethically and comply with applicable laws and regulations.

Professionalism

We are committed to maintaining high professional standards in all aspects of our operations. Our team works with competence, dedication, and responsibility to deliver reliable and high-quality services to our clients and partners.

Commitment

We approach every project with responsibility and dedication. Our commitment to our clients, employees, and partners drives us to deliver consistent results and maintain strong, long-term relationships built on trust.

Quality and Excellence

We continuously strive to improve the quality of our services and operational performance. By maintaining high standards and focusing on reliability and efficiency, we aim to exceed the expectations of our partners and stakeholders.

Respect and Collaboration

We believe that successful partnerships are built on mutual respect, open communication, and collaboration. We value diverse perspectives and promote a culture where employees and partners work together to achieve common goals.

Our Cultural Behaviours

Our cultural behaviours translate our values into everyday actions. They guide how we interact with our colleagues, clients, subcontractors, and stakeholders.

Accountability

We take responsibility for our actions, decisions, and commitments. Employees are encouraged to act proactively, raise concerns when necessary, and contribute to responsible decision-making.

Respect and Inclusion

We treat all individuals with dignity and respect. We value diversity and promote an inclusive working environment where people feel respected, supported, and able to contribute their ideas.

Collaboration and Teamwork

We work together across teams and with our partners to achieve shared objectives. Collaboration and open communication are essential for delivering reliable and effective services.

Continuous Learning and Improvement

We encourage curiosity, professional development, and the continuous improvement of our services and processes. By learning from experience and adapting to change, we strengthen our operational capabilities.

Responsibility Toward Society and Stakeholders

We recognize that our activities have an impact on society, the environment, and the communities in which we operate. We aim to conduct our business responsibly and contribute positively to the markets and industries we serve.

Through our purpose, values, and cultural behaviours, Eleven Access International Services SRL aims to build a business environment based on trust, professionalism, and long-term partnerships.

 Responsibilities under this Code of Conduct

This Code of Conduct applies to all employees, managers, subcontractors, consultants, and business partners acting on behalf of Eleven Access.

All individuals working with or representing the Company are expected to understand and follow the principles and standards outlined in this Code.

Responsibilities of Employees

All employees have a responsibility to:

• act with integrity and professionalism in all business activities;
• comply with applicable laws, regulations, and company policies;
• respect colleagues, clients, and partners in all professional interactions;
• avoid conflicts of interest that could compromise business decisions;
• protect confidential information and company assets;
• report any concerns or suspected violations of this Code.

Employees are encouraged to raise concerns without fear of retaliation. The Company supports a culture of openness and responsible reporting.

Responsibilities of Managers and Supervisors

Managers and supervisors have additional responsibilities to promote ethical conduct and ensure compliance within their teams.

Managers are expected to:

• lead by example and demonstrate ethical leadership;
• communicate the principles of this Code to employees and partners;
• ensure that employees understand their responsibilities;
• create a working environment where employees feel comfortable raising concerns;
• take appropriate action when potential violations are identified.

Responsibilities of Business Partners and Subcontractors

The Company expects its suppliers, subcontractors, and business partners to respect the same ethical standards described in this Code.

Business partners working with Eleven Access must:

• comply with applicable laws and regulatory requirements;
• conduct business ethically and responsibly;
• respect human rights and fair labour practices;
• avoid corruption, fraud, or unethical business practices;
• cooperate with the Company in ensuring compliance with applicable policies.

Where necessary, the Company may request that subcontractors and partners demonstrate compliance with these principles through documentation, contractual commitments, or operational reviews.

Commitment to Ethical Conduct

Maintaining ethical standards is a shared responsibility. By adhering to the principles outlined in this Code of Conduct, employees and partners contribute to protecting the integrity, reputation, and long-term sustainability of Eleven Access.

Compliance with Laws and Ethical Conduct

Eleven Access is committed to conducting its business in full compliance with applicable national and international laws and regulations. Respecting legal requirements and maintaining high ethical standards are fundamental principles that guide the Company’s operations and decision-making processes.

Operating responsibly and ethically helps protect the reputation of the Company, strengthen trust with clients and partners, and ensure the long-term sustainability of our business activities. All employees and individuals acting on behalf of the Company are expected to understand and respect the legal and ethical obligations associated with their professional responsibilities.

Compliance with laws and ethical conduct applies to all aspects of the Company’s activities, including operational services, recruitment activities, business partnerships and contractual relationships.

All employees and representatives of the Company must:

• comply with applicable laws and regulatory requirements in the jurisdictions where the Company operates
  • act ethically, responsibly and with professional integrity in all business activities
  • protect the reputation, credibility and integrity of the Company
  • avoid actions or behaviours that could damage trust with clients, partners, subcontractors or public authorities

Where employees are uncertain about the legality or appropriateness of a particular action or decision, they are encouraged to seek guidance from management or relevant company representatives before proceeding.

By acting responsibly and ethically, employees contribute to maintaining a business environment based on professionalism, transparency and mutual trust.

Anti-Bribery and Anti-Corruption

Eleven Access is committed to conducting its business with integrity, transparency and fairness. The Company recognises that bribery, corruption and other forms of unethical conduct undermine trust, distort fair competition and may expose organisations and individuals to significant legal, financial and reputational risks.

For this reason, Company maintains a strict zero-tolerance approach toward bribery and corruption in all business activities and relationships. This commitment applies to employees, managers, subcontractors, consultants and any individual acting on behalf of the Company.

All employees and representatives of the Company must ensure that their actions reflect the highest standards of ethical conduct and comply with applicable anti-corruption legislation in the jurisdictions where the Company operates.

Employees and representatives of the Company must not:

• offer or accept bribes
  • offer improper financial or non-financial advantages
  • engage in corrupt practices intended to influence business decisions
  • provide or accept gifts, hospitality or benefits that may improperly influence a business outcome

Business decisions must always be based on objective criteria such as quality, reliability, professionalism and legitimate commercial considerations.

Employees must exercise good judgement when interacting with clients, suppliers, subcontractors and public officials, ensuring that all professional interactions remain transparent, lawful and ethically appropriate.

All employees must comply with the Company’s Anti-Bribery and Anti-Corruption Policy, which provides detailed guidance regarding acceptable conduct, reporting obligations and compliance requirements.

Any suspicion of bribery, corruption or unethical conduct must be reported through the Company’s internal reporting channels so that appropriate action can be taken.

Human Rights and Labour Standards

Contributing to Society and Respect for Human Rights

Eleven Access aims to operate as a responsible corporate citizen and to contribute positively to the communities and markets in which it operates.

The Company recognises that responsible business conduct requires engagement with a wide range of stakeholders, including employees, clients, partners, suppliers, public authorities and the wider society. Through transparent and ethical operations, we seek to build long-term relationships based on trust, integrity and mutual respect.

Respect for Human Rights

Eleven Access supports and respects internationally recognised human rights and is committed to conducting its business in a manner that protects the dignity and rights of all individuals affected by its activities.

Our approach is aligned with internationally recognised frameworks, including:

• the Universal Declaration of Human Rights
• the International Labour Organization (ILO) core conventions
• the UN Guiding Principles on Business and Human Rights

The Company is committed to avoiding any involvement in human rights violations and to addressing potential risks that may arise within its operations or supply chain.

Responsible Business Conduct

Eleven Access is committed to ethical business practices and does not tolerate corruption, exploitation, discrimination or any form of unethical behaviour in its operations or business relationships.

Responsible conduct includes:

• maintaining transparent and lawful business practices
• preventing corruption and unethical practices
• ensuring fair and voluntary employment relationships
• respecting labour rights and safe working conditions
• supporting responsible business relationships with partners and suppliers.

Supply Chain Responsibility

The Company recognises that respect for human rights extends beyond its direct operations. Eleven Access expects subcontractors, suppliers and business partners to operate in accordance with applicable labour standards and human rights principles.

Where necessary, the Company may conduct operational reviews or due diligence activities in order to ensure that its partners respect these standards.

Continuous Awareness and Improvement

Eleven Access promotes awareness of ethical conduct, human rights, and responsible business practices across its organisation. The Company is committed to continuously improving its internal policies and operational practices in order to strengthen its role as a responsible and trustworthy business partner.

Further details are outlined in the Company’s Human Rights Policy and Modern Slavery and Human Trafficking Policy.

Equality, Diversity and Non-Discrimination

Eleven Access is committed to creating a working environment based on fairness, dignity, and equal opportunities for all individuals. The Company recognises that diversity strengthens organisations by encouraging different perspectives, ideas, and experiences that contribute to better decision-making and sustainable business development.

Our commitment to equality and diversity means that all individuals are treated with respect and professionalism, regardless of personal characteristics or background. The Company promotes a workplace culture where employees, partners, and stakeholders can interact in an environment free from discrimination, harassment, or intimidation.

Eleven Access strictly prohibits any form of discrimination in employment, recruitment, promotion, training, compensation, or professional development.

Discrimination based on the following characteristics is not tolerated:

• gender
  • race or ethnicity
  • nationality
  • religion or belief
  • age
  • disability
  • sexual orientation
  • marital or family status
  • political opinions
  • social background
  • any other characteristic protected by applicable law

All employees, managers, subcontractors and business partners are expected to support these principles and contribute to a respectful and inclusive professional environment.

Further details regarding definitions, responsibilities, reporting procedures and disciplinary measures are outlined in the Company’s Workplace Anti-Harassment and Anti-Discrimination Policy.

Workplace Conduct and Respect

Eleven Access is committed to maintaining a professional workplace culture built on mutual respect, integrity and responsible behaviour.

A respectful work environment is essential for employee wellbeing, collaboration, and operational effectiveness. All employees are expected to conduct themselves in a professional manner and to treat colleagues, clients, and partners with dignity and courtesy.

The Company operates a zero-tolerance approach toward behaviour that may create an intimidating, hostile, degrading or unsafe working environment.

The following behaviours are strictly prohibited:

• harassment
  • bullying
  • intimidation
  • abusive or offensive conduct
  • workplace violence

All employees share responsibility for maintaining a safe and respectful workplace. Individuals who experience or witness inappropriate behaviour are encouraged to report concerns through the Company’s internal reporting channels.

Any reported incident will be addressed promptly and investigated in accordance with the procedures defined in the Workplace Anti-Harassment and Anti-Discrimination Policy.

Health, Safety and Wellbeing

The health, safety and wellbeing of employees, contractors and business partners represent a fundamental priority for Eleven Access.

The Company recognises that a safe and supportive working environment is essential not only for protecting individuals but also for maintaining operational reliability, service quality and responsible business practices.

Particularly in operational sectors such as transportation services, logistics coordination and workforce deployment, employee wellbeing, fatigue management and occupational safety play a critical role in preventing incidents and ensuring effective service delivery.

Eleven Access is therefore committed to promoting a workplace culture in which health, safety and wellbeing are actively protected and continuously improved.

The Company is committed to:

• providing safe and healthy working conditions across all operational and administrative activities
• identifying, assessing and mitigating occupational health and safety risks
• promoting employee wellbeing and responsible workload management
• monitoring fatigue and working time requirements in safety-critical roles
• encouraging open communication regarding health, safety or wellbeing concerns
• supporting employees experiencing work-related stress or health difficulties
• maintaining responsible operational practices that protect both employees and the wider community

Employees and managers share responsibility for maintaining a safe and healthy workplace. All employees are expected to follow applicable safety procedures, comply with working time and rest requirements, and report any hazards, incidents or safety concerns in a timely manner.

Managers and supervisors are responsible for supporting employees, monitoring operational pressures, and taking appropriate action where health, safety or wellbeing risks are identified.

Further guidance regarding occupational health, stress management, fatigue awareness and employee wellbeing is provided in the Company’s Employee Health, Wellbeing and Work-Related Stress Policy, which outlines detailed procedures, responsibilities and risk management measures.

Drugs and Alcohol in the Workplace

Eleven Access International Services SRL is committed to maintaining a safe, professional and responsible working environment. The Company recognises that the consumption of alcohol or the use of illegal drugs in the workplace may significantly compromise safety, operational performance and the wellbeing of employees and others.

In operational sectors such as transportation services, logistics coordination and workforce deployment, employees may perform duties that require a high level of concentration, judgement and responsibility. For this reason, employees must always be fit for work and able to perform their duties safely and effectively.

The Company maintains a strict policy regarding the use of alcohol and illegal drugs during working time or in any work-related context.

The following behaviours are strictly prohibited:

• reporting to work under the influence of alcohol or illegal drugs
• consumption of alcohol or illegal drugs during working hours
• possession, distribution or sale of illegal drugs in the workplace or during work-related activities

Employees who are taking prescribed medication that may affect their ability to perform their duties safely must inform management where appropriate for health and safety reasons. This ensures that reasonable adjustments can be considered where necessary in order to protect both the employee and others in the workplace.

Maintaining a safe and responsible workplace is a shared responsibility. Employees are expected to exercise sound judgement and to support a professional working environment that prioritises safety and operational integrity.

Further details regarding responsibilities, procedures and disciplinary measures are outlined in the Company’s Drugs and Alcohol Policy.

Responsible Supply Chain and Subcontractor Management

Eleven Access International Services SRL recognises that responsible business conduct extends beyond its direct operations and includes the activities of subcontractors, suppliers and other business partners involved in the delivery of services.

As a company operating in transportation services, workforce deployment and operational support across multiple locations, the Company relies on a network of subcontractors and service partners. For this reason, maintaining high standards of professionalism, legal compliance and ethical conduct throughout the supply chain is essential.

The Company is committed to working with partners who share its values of integrity, reliability and responsible business practices. All subcontractors and suppliers are expected to operate in accordance with applicable laws, contractual obligations and recognised industry standards.

Eleven Access expects its subcontractors and suppliers to:

• comply with all applicable legal and regulatory requirements in the jurisdictions where services are provided
• maintain all licences, permits and authorisations necessary to perform their activities
• deliver services in accordance with agreed operational, safety and quality standards
• respect ethical labour practices and internationally recognised human rights principles
• conduct their business with integrity and avoid corruption, fraud or unethical practices

The Company promotes transparent and responsible partnerships and seeks to build long-term relationships with subcontractors who demonstrate reliability, professionalism and respect for ethical business principles.

In order to ensure service quality and compliance, subcontractor performance may be monitored through:

• operational reviews and performance evaluations
• verification of documentation, licences and certifications
• contractual compliance monitoring
• project-based performance assessments

Where necessary, corrective measures may be implemented in order to maintain service quality and ensure compliance with applicable standards.

Further information regarding the monitoring and evaluation of subcontractors is detailed in the Company’s Subcontractor Performance Monitoring Procedure.

Protection of Company Assets and Confidential Information

Eleven Access International Services SRL recognises that the responsible management of company assets and information is essential for maintaining operational integrity, protecting business relationships and ensuring the long-term sustainability of the organisation.

Company assets include not only physical property such as equipment, vehicles, documents and technological systems, but also intangible assets such as confidential information, intellectual property, business strategies and the reputation of the Company.

Employees, subcontractors and any individuals acting on behalf of the Company are expected to use company assets responsibly and exclusively for legitimate business purposes. Misuse, unauthorised access or inappropriate disclosure of company assets or information may result in operational risks, legal consequences and reputational damage.

Confidential information may include, but is not limited to:

• business strategies and operational plans
• contractual information and commercial agreements
• financial data and internal reports
• client or partner information
• operational procedures and internal documentation

Such information must be protected and handled with appropriate care. Employees must not disclose confidential information to unauthorised persons, whether inside or outside the Company, unless required as part of their professional responsibilities.

All employees are also expected to protect information related to clients, partners and subcontractors, ensuring that data is used responsibly and in accordance with applicable data protection and confidentiality obligations.

Company equipment, systems and resources must be used responsibly and in accordance with established procedures. Employees should take reasonable precautions to safeguard company property and prevent misuse, loss or damage.

Protecting company assets and confidential information is a shared responsibility. By handling company resources responsibly and maintaining confidentiality where required, employees contribute to protecting the integrity, reputation and operational security of Eleven Access.

Reporting Concerns and Ethical Issues

Eleven Access promotes a culture of integrity, transparency and accountability. The Company encourages employees, subcontractors and business partners to raise concerns whenever they believe that unethical conduct or violations of company policies may have occurred.

Open communication is essential for maintaining trust, protecting the reputation of the Company and ensuring that potential issues are addressed promptly and responsibly.

Employees, subcontractors and partners are encouraged to report any concerns regarding:

• unethical behaviour
  • violations of this Code of Conduct
  • corruption, bribery or fraud
  • human rights violations
  • workplace misconduct or inappropriate behaviour

Reports may be submitted through the following channels:

• direct management or immediate supervisor
  • Human Resources representatives
  • Company leadership or designated management contacts

All reports will be treated seriously and handled in a confidential and professional manner. The Company is committed to reviewing concerns promptly and taking appropriate action where necessary.

Eleven Access does not tolerate retaliation against any individual who raises concerns in good faith or participates in an internal review or investigation process. Protecting individuals who report concerns is an important part of maintaining a responsible and ethical working environment.

Compliance and Disciplinary Measures

Compliance with this Code of Conduct is essential for maintaining the integrity, reputation and professional standards of Eleven Access.

All employees, subcontractors and individuals acting on behalf of the Company are expected to understand and comply with the principles outlined in this Code. Failure to follow these standards may expose the Company and its partners to legal, financial and reputational risks.

Where violations of this Code of Conduct occur, the Company will take appropriate action to address the situation and ensure that similar issues are prevented in the future.

Failure to comply with this Code of Conduct may result in disciplinary action.

Depending on the severity and nature of the violation, measures may include:

• formal warning
  • mandatory training or corrective guidance
  • suspension from duties
  • termination of employment
  • termination of contractual or business relationships with partners

In cases where required by law, the Company may also report violations to the appropriate authorities.

Disciplinary actions will be applied fairly, proportionately and in accordance with applicable employment legislation and company procedures.

Continuous Improvement and Review

Eleven Access is committed to maintaining high standards of ethical conduct, responsible governance and continuous organisational improvement.

The Company recognises that ethical business practices and compliance frameworks must evolve in response to changes in legislation, industry standards, operational practices and stakeholder expectations. For this reason, the Company promotes a culture of continuous learning, responsible leadership and ongoing evaluation of its internal policies and procedures.

This Code of Conduct represents an important component of the Company’s governance framework and serves as a guide for ethical decision-making across all areas of the organisation.

In order to ensure its continued relevance and effectiveness, the Code of Conduct will be reviewed periodically by Company management. Reviews may consider developments in applicable legislation, regulatory requirements, operational experience and recognised industry best practices.

Where necessary, the Company may update or revise this Code of Conduct and related policies in order to strengthen its ethical standards, improve governance practices and support responsible business conduct.

Through continuous improvement and responsible leadership, Eleven Access aims to maintain a business environment based on integrity, professionalism and trust.