Code of Conduct and Anticorruption

ASDT Corporation S.L.U. is a Spanish technology company specialising in the design, development, manufacture and deployment of anti-drone protection systems for airspace security. The company develops its own hardware and software solutions based on advanced technology, applicable to both civil and institutional environments, and operates in areas that require high standards of reliability, security and responsibility.

ASDT's activity is oriented towards the protection of particularly sensitive sectors, including defence and public security, the protection of critical infrastructures, strategic operations and the security of events, heritage and spaces of special relevance. These environments require rigorous professional behaviour and a reinforced commitment to legality, business ethics and the responsible use of technology.

Due to the nature of its solutions and the potential impact they may have on security, fundamental rights and the public interest, ASDT assumes as an essential principle the development of its activity in accordance with the highest standards of integrity, transparency and regulatory compliance. This commitment extends to all the people who form part of the organisation and to third parties who collaborate with the company or act on its behalf.

This Code of Conduct and Anti-Corruption Code establishes the ethical principles and basic rules of behaviour that should guide the actions of ASDT Corporation S.L.U. and all the people who form part of the organisation.

Its aim is to promote a corporate culture based on integrity, transparency, compliance with the law and respect for people, and to prevent any irregular, fraudulent or corrupt conduct.

This Code applies to all employees, officers and partners of ASDT, regardless of their function or level of responsibility. Suppliers, business partners and third parties acting on behalf of ASDT are also expected to observe equivalent principles in the course of their dealings with the company.

ASDT's activity is based on the following values and principles:

• IntegrityWe act honestly, consistently and responsibly in all our professional decisions and activities.
• TransparencyWe maintain clear and truthful relations with customers, employees, suppliers and public administrations.
• Professional liabilityWe assume the consequences of our actions and work with technical and ethical rigour.
• Respect for peopleWe promote a working environment based on dignity, equal treatment and collaboration.
• Commitment to legalityWe comply with applicable regulations and internal policies as a minimum basis for action.

These principles should guide the daily behaviour of all ASDT members.

ASDT carries out its activities in strict compliance with the applicable legislation in force, including, among others, commercial, labour, tax, data protection and information security regulations.

Legal compliance is a minimum requirement. All employees must act with integrity even in situations that are not expressly regulated, avoiding conduct that may be unlawful, unethical or damaging to the reputation of the company.

No person is authorised to breach the law or this Code in order to obtain a benefit for ASDT.

ASDT maintains a zero tolerance policy towards any form of corruption, bribery or fraudulent behaviour.

It is expressly prohibited to offer, promise, grant, solicit or accept, directly or indirectly, any undue advantage for the purpose of influencing professional, commercial or administrative decisions.

This prohibition applies both in the private sphere and in relations with public administrations, authorities or officials, regardless of the country or context in which the activities take place. ASDT does not allow facilitation payments or similar practices, even if they are common in certain environments or markets.

People working at ASDT must always act in the interests of the company, avoiding situations in which personal, family or economic interests may influence their professional decisions. Any potential conflict of interest must be reported immediately to management for evaluation and appropriate management. In relation to gifts, invitations or other hospitality:

• They may not be offered or accepted where they may influence or appear to influence professional decisions.
• Only occasional attentions of a symbolic value and in accordance with reasonable social usage shall be admitted.
• The giving of gifts or benefits to officials or public officials is expressly prohibited.

If in doubt, prior consultation should take place before accepting or offering any gift.

ASDT's relations with customers, suppliers, partners and collaborators are based on objective, professional and ethical criteria. The company will avoid establishing business relationships with third parties when there are reasonable indications of illegal or corrupt practices or practices contrary to the principles contained in this Code.

In relations with public administrations, ASDT shall act with political neutrality, transparency and full respect for the law, refraining from making donations, contributions or favours that could compromise its independence or integrity.

The information, data and knowledge generated by ASDT are essential assets for the company. All employees must:

• Protect confidential information and use it only for legitimate business purposes.
• To guarantee the confidentiality of personal data in accordance with the applicable regulations.
• Responsible use of the company's systems, tools and technological resources.

The obligation of confidentiality continues even after the termination of the employment or professional relationship with ASDT.

ASDT promotes a safe, professional and respectful working environment, based on equal opportunities, diversity and non-discrimination. The company considers that respect for people and the quality of professional relations are essential elements for the correct development of its activity and for the fulfilment of its business objectives.

Everyone who is a member of ASDT has the right to be treated with dignity, fairness and respect. Any form of harassment, intimidation, verbal abuse, offensive behaviour or conduct that violates personal or professional dignity will not be tolerated, regardless of its origin or motivation. This principle applies to all working relationships, both between colleagues and between different hierarchical levels.

Equal opportunities and non-discrimination are fundamental principles of ASDT's corporate culture. The company guarantees fair processes in the selection, promotion and management of people, based exclusively on merit, professional skills and suitability for the position. ASDT expressly rejects any type of direct or indirect discrimination on the grounds of race, colour, national or ethnic origin, religion or beliefs, sex, gender identity or expression, sexual orientation, marital status, age, disability, medical condition, political opinion, social status or any other personal circumstance protected by applicable legislation.

The company values diversity as an element that enriches the working environment and considers that the plurality of perspectives, experiences and professional profiles contributes positively to innovation, creativity and the sustainable development of the organisation.

Labour relations at ASDT should be based on mutual respect, collaboration, professionalism and compliance with occupational health and safety standards, fostering a climate of trust, cooperation and shared responsibility.

ASDT provides confidential communication mechanisms so that employees and third parties related to its activity can report, in good faith, possible breaches of this Code, of the applicable regulations or irregular conduct linked to the company's activity.

Communications made through these mechanisms will be treated with due confidentiality, diligence and objectivity, respecting at all times the rights of the persons involved. ASDT expresses its commitment to the protection of persons who communicate possible irregularities in good faith, guaranteeing that no reprisals will be taken as a consequence of such communications.

These mechanisms are intended to reinforce the company's culture of integrity, transparency and accountability, as well as to facilitate the early detection of potential risks.

Failure to comply with the provisions of this Code may result in disciplinary action in accordance with applicable labour regulations, without prejudice to any legal responsibilities that may apply.

This Code comes into force upon its approval and will be subject to periodic review to ensure its adequacy to ASDT's activity and to changes in regulations or in the business environment.

All persons subject to this Code are responsible for knowing, complying with and actively contributing to its implementation.

Date and version: 16/12/2025 - Version 1