Ethics and Compliance Policy

1. Purpose and Scope

This Ethics and Compliance Policy (“Policy”) sets out the principles and standards of conduct that govern all business activities of Norya AyroN. The purpose of this Policy is to ensure that all our operations are conducted with the highest standards of integrity, honesty, and transparency, and in full compliance with all applicable laws and regulations in Morocco and the countries where we operate.

This Policy applies to all employees, officers, directors, and agents of Norya AyroN. We also expect our business partners, suppliers, and third-party affiliates to adhere to similar ethical principles.

2. Core Principles

Our business is built on a foundation of trust. We are committed to upholding the following core principles:

• Integrity and Honesty: We will conduct our business with integrity, avoiding any behavior that could be considered fraudulent, deceptive, or misleading.
• Fairness: We are committed to treating all individuals with fairness, dignity, and respect, without discrimination or harassment.
• Compliance with Law: We will comply with all laws and regulations, including those related to labor, human rights, data protection, and anti-corruption.

3. Specific Compliance Areas

• Anti-Bribery and Corruption:

• Norya AyroN has a zero-tolerance policy for bribery, corruption, and all forms of unethical conduct.
• We will not offer, pay, or accept bribes, kickbacks, or any other improper payments to or from government officials or private parties.
• This includes “facilitation payments,” which are illegal under Moroccan law and our policy.
• Any form of giving or receiving gifts, hospitality, or entertainment must be reasonable, proportionate, and not intended to influence a business decision improperly.

• Fair Labor Practices and Human Rights:

• We are committed to respecting and promoting human rights in our own operations and throughout our supply chain.
• We prohibit all forms of forced labor, modern slavery, and child labor.
• All workers, including those employed by our suppliers, must be treated with dignity and respect, be paid a fair wage, and have the right to a safe and healthy working environment.
• We will ensure that working hours comply with all local labor laws, including the Moroccan Labour Code.
• We will not tolerate any form of discrimination or harassment based on race, gender, religion, national origin, social status, or any other protected characteristic.

• Data Privacy and Security:

• We are committed to protecting the personal information of our customers, employees, and partners.
• We will process personal data in accordance with our Privacy Policy and all applicable data protection laws, including Morocco’s Law No. 09-08 and international regulations such as the GDPR.
• We will maintain appropriate technical and organizational measures to ensure the security and confidentiality of all data we collect.

• Conflicts of Interest:

• Employees must avoid any situation where their personal interests conflict, or appear to conflict, with the interests of Norya AyroN.
• Employees must disclose any potential conflicts of interest to their manager or a designated Compliance Officer.

• Confidentiality:
• Employees are responsible for protecting the confidential information of Norya AyroN and its business partners. This includes, but is not limited to, financial information, trade secrets, business plans, and customer data.
• This obligation continues even after employment with Norya AyroN ends.

4. Reporting Violations and Non-Retaliation

• We encourage and expect our employees and partners to speak up and report any suspected violations of this Policy or the law.
• Reports can be made to a manager or a dedicated reporting channel, which will be maintained to ensure confidentiality.
• Norya AyroN is committed to protecting individuals who report concerns in good faith from any form of retaliation, punishment, or adverse action.
• Please be aware that while Morocco is developing comprehensive whistleblower protection laws, existing legal provisions provide some mechanisms for reporting corruption.