Anti-Bribery and Corruption Policy

Primex ehf. (“the Company”) rejects all forms of corruption and bribery. The Company and its employees strive to comply with applicable laws, regulations, and recognized standards of business ethics and corporate governance at all times, to avoid conflicts of interest, and to maintain confidentiality. Reasonable and appropriate gifts and entertainment are permitted within with antibribery/ anticorruption laws set out by market segment and geography.

Primex is committed to always complying with applicable laws and regulations governing its operations, as well as with recognized business ethics standards, corporate governance guidelines, and its own internal rules.

Employees must avoid making decisions that create conflicts of interest and must uphold the principle that the interests of both employees and the Company are aligned.

Employees are bound by confidentiality and must maintain strict secrecy regarding all information acquired in their work that relates to customers or Company operations. This duty of confidentiality continues after employment ends. Employees may not use confidential information for personal gain or for the benefit of others.

The Company permits the giving and receiving of reasonable and appropriate gifts and entertainment in connection with legitimate business relationships. It is prohibited to give or accept cash. All gifts must be given in the name of Primex and may never be given secretly. Business decisions must not be influenced by gifts or create conflicts of interest.

Primex respects the fundamental right to personal data protection and will adhere to accepted standards in this area. The Company maintains a separate Data Protection Policy that governs the processing of personal data within the organization.

Primex expects its suppliers and subcontractors to follow the same principles as the Company.

All business, product, and customer invoices and related records must be prepared with accuracy and integrity. Off-the-book accounts or concealed payments are prohibited.

Money laundering is the process of concealing or disguising the existence of illegal proceeds so that they appear legitimate. Primex shall not permit any entity or individual to use the Company for money laundering and shall not accept any proceeds from illegal activities. Employees must report to their immediate supervisor if they become aware of circumstances suggesting that a transaction may involve payment or receipt of unlawful proceeds.

It is the personal responsibility of all employees to act in accordance with the legal standards and limitations applicable to their job duties and relevant laws and regulations.

If employees wish to report a suspected breach of these ethical rules or believe that laws and regulations are not being followed, they must discuss the matter with their immediate supervisor. The Company will not tolerate retaliation against anyone who, in good faith, reports an actual or suspected violation.