Code of Ethics/ Ethical Business Code Turbo Link International

At Turbo-Link, we believe that long-term business relationships are built on trust, transparency, integrity and professional conduct. As an international supplier and sourcing partner for turbochargers, we are committed to conducting business responsibly and fairly with customers, suppliers and partners worldwide.

This Ethical Business Code sets out the key principles that guide the way Turbo-Link conducts its business.

1. Integrity and Honesty

Turbo-Link conducts its business with integrity and honesty. We aim to provide customers and business partners with clear, accurate and transparent information regarding our products, availability, pricing and delivery.

We do not knowingly provide false or misleading information regarding products, brands, specifications, origin or condition.

2. Product Authenticity

Product authenticity is important to Turbo-Link.

When a product is offered as Original Equipment (OE), we aim to ensure that it originates from the stated manufacturer or from an appropriate and verifiable supply chain.

Where applicable, we clearly distinguish between:

• Original Equipment (OE)

• New products

• Remanufactured products

• Other product conditions or specifications

Turbo-Link does not knowingly sell counterfeit products or parts.

3. Responsible Sourcing

Turbo-Link works with an international network of suppliers and business partners.

We aim to source products from professional and reliable parties and expect our suppliers to conduct their business lawfully and responsibly.

When selecting and evaluating suppliers, we may consider factors including product authenticity, quality, reliability, traceability, commercial conduct and compliance with applicable laws and regulations.

4. Fair and Transparent Business Practices

We believe in fair competition and transparent business relationships.

Quotations, invoices and agreements should communicate the relevant commercial terms as clearly as possible.

Turbo-Link does not knowingly participate in deceptive sales practices, bribery, corruption or improper influence.

Commercial decisions are made on the basis of legitimate business considerations.

5. Compliance with Laws and Regulations

Turbo-Link aims to comply with applicable laws and regulations in the countries and markets in which we operate.

Where applicable, this includes regulations relating to:

• International trade

• Import and export

• Customs

• Sanctions and trade restrictions

• Taxation

• Product regulations

• Competition law

• Privacy and data protection

Where an international transaction is subject to trade restrictions or additional compliance requirements, Turbo-Link reserves the right to request additional information or decline a transaction.

6. Fair and Transparent Export Practices

International trade and export are an important part of Turbo-Link’s activities. We are committed to honesty, transparency and accurate information throughout the entire export process.

This applies not only to our communication with customers and suppliers, but also to our cooperation with carriers, freight forwarders, customs brokers and customs authorities.

Turbo-Link aims to ensure that export documentation and customs information are completed truthfully, accurately and as fully as reasonably possible. This includes, where applicable:

• Description of the goods

• Quantity and weight

• Invoice and transaction value

• Country of origin

• Commodity and customs classification codes

• Destination and consignee

• Required export and transport documentation

We prefer to work with carriers and logistics partners that operate in a transparent, reliable and legally compliant manner.

Turbo-Link does not knowingly participate in the false declaration of goods, artificial undervaluation of shipments, incorrect statements regarding the origin of goods, or attempts to circumvent applicable customs duties, taxes, sanctions or trade restrictions.

These principles apply to our dealings with Dutch Customs, as well as customs authorities, carriers, freight forwarders and logistics partners in destination and transit countries.

We aim to handle international shipments correctly and transparently and expect the same professional standards from our customers, suppliers, carriers and other parties involved in the supply chain.

7. Our Customers

We treat our customers professionally and respectfully, regardless of company size, location or market.

Our objective is to provide accurate product information and assist customers in identifying the correct turbocharger for their application.

If a product is unavailable or certain information cannot be established with sufficient certainty, we prefer to communicate this openly rather than make commitments that we cannot reasonably fulfil.

8. Suppliers and Business Partners

We value long-term relationships with suppliers and business partners based on mutual trust and professional conduct.

Turbo-Link expects its business partners to respect applicable laws, contractual agreements, intellectual property rights and generally accepted standards of ethical business conduct.

We do not knowingly cooperate with parties involved in fraud, corruption, counterfeit trade or other unlawful business practices.

9. Anti-Bribery and Anti-Corruption

Turbo-Link does not tolerate bribery or corruption.

Individuals and business partners acting on behalf of Turbo-Link must not offer, request, give or accept improper payments, benefits or other incentives intended to unlawfully influence a business decision.

Reasonable and legitimate business hospitality must never be used to improperly influence commercial decisions.

10. International Trade and Sanctions

As an internationally oriented company, Turbo-Link recognises the importance of responsible international trade.

We aim to comply with applicable export controls, sanctions and trade restrictions.

Turbo-Link may refuse or cancel a transaction where there are reasonable concerns regarding the destination, end user, payment, intended application of the product or compliance with applicable trade regulations.

11. Confidentiality and Data Protection

Information received from customers, suppliers and business partners is handled with appropriate care.

We respect confidential business information and aim to process personal data responsibly and in accordance with applicable privacy and data protection laws.

Confidential information is used only for legitimate business purposes.

12. Conflicts of Interest

Business decisions should be made in the interests of Turbo-Link and its legitimate business relationships.

Any personal, financial or other interests that could improperly influence a business decision should be disclosed and managed appropriately.

13. Respect and Equal Treatment

Turbo-Link believes that professional relationships should be based on mutual respect.

We do not tolerate discrimination, harassment, intimidation, threats or other inappropriate behaviour within our business relationships or working environment.

We aim to treat customers, suppliers, employees and business partners fairly, equally and professionally.

14. Environmental Responsibility

We recognise that international trade, transportation and industrial activities have an impact on the environment.

Where practical and commercially feasible, Turbo-Link aims to make responsible choices regarding transportation, packaging, sourcing and operational efficiency.

We also encourage our suppliers and business partners to consider sustainability and environmental responsibility within their own operations.

15. Reporting Concerns or Misconduct

Customers, suppliers and business partners are encouraged to contact Turbo-Link if they have concerns regarding potential unethical behaviour, product authenticity, compliance or other conduct related to our business.

Reports will be taken seriously and, where appropriate, investigated.

Turbo-Link does not tolerate retaliation against individuals who raise legitimate concerns or report potential misconduct in good faith.

16. Continuous Improvement

Ethical and responsible business conduct is an ongoing process.

Turbo-Link reviews its business practices and procedures where appropriate and aims to continuously improve them as our company, international regulations and markets develop.

Our objective is not only to supply and source turbochargers, but also to build reliable and long-term international business relationships based on integrity, transparency, product knowledge and trust.