Code of Conduct and Anti-Bribery Policy

Last updated: 13 November 2026.

Who we are. In this document, "Vens", "we", "us" and "our" mean Vens Hydroluft Corporation, Woodbridge, Ontario, Canada, and its affiliated companies, including Vens Hydroluft Private Limited (manufacturing, Chennai, India) and VDT Europa OÜ (Tallinn, Estonia). The Vens company that issues a quotation, order acknowledgement or invoice is the company you contract with.

This code applies to every director, employee, agent, distributor and contractor acting for Vens, everywhere we operate. We expect our suppliers and partners to meet the same standards. Breaches lead to disciplinary action, which may include dismissal or termination of contract, and may be reported to the authorities.

1. Integrity

We deal honestly with customers, suppliers, employees, authorities and competitors. We make no false claims about our products, certifications or capabilities, and we keep accurate books and records.

2. Zero tolerance of bribery and corruption

• We never offer, promise, give, request or accept a bribe, kickback or improper advantage, directly or through anyone else. This applies to public officials and private persons alike.

• We do not make facilitation payments, except where a person's safety is at immediate risk. Any such payment must be reported straight away.

• We comply with Canada's Corruption of Foreign Public Officials Act, India's Prevention of Corruption Act, the EU and Estonian anti-corruption laws, the UK Bribery Act and the US Foreign Corrupt Practices Act, wherever they apply.

• Agents, distributors and consultants are appointed only after due diligence and under written contracts. They are paid fees proportionate to legitimate services, by bank transfer.

3. Gifts and hospitality

Modest gifts and hospitality that are customary, infrequent, transparent and not intended to influence a decision may be given or accepted. Cash and cash equivalents are never allowed. Nothing may be given to officials involved in a tender or decision affecting Vens. Anything beyond nominal value must be approved in advance and recorded.

4. Conflicts of interest

Employees must avoid situations where personal interests conflict with those of Vens, and must declare any possible conflict to management.

5. Fair competition

We compete on the merits of our products and service. We do not fix prices, rig bids, share markets or exchange sensitive information with competitors.

6. Sanctions and export control

We screen customers, destinations and end uses, and we do not supply in breach of the sanctions or export control laws of Canada, the European Union, the United Nations, India or other applicable jurisdictions.

7. Human rights and working conditions

We do not use child, forced, bonded or trafficked labour, and we do not accept it in our supply chain. We pay fair wages in line with the law, respect working-hour limits and freedom of association, and do not tolerate discrimination, harassment or bullying.

8. Health, safety and the environment

Safety comes before output. Everyone has the right and duty to stop unsafe work. We prevent pollution, manage waste responsibly and comply with environmental law, in line with our Quality, Health, Safety and Environment Policy.

9. Confidentiality and data protection

We protect confidential information belonging to Vens, our customers and our suppliers, and we handle personal data as set out in our Privacy Policy.

10. Speaking up

Anyone who suspects a breach of this code, bribery, fraud or unsafe practice should report it to management or by email to sales@skimmer.co.in, marked "Confidential: Ethics". Reports may be made anonymously. They are investigated promptly and handled confidentially. No one will suffer retaliation for a report made in good faith.

Contact. Vens Hydroluft Corporation, 28 Christina Ciccolini Court, Woodbridge, Ontario, Canada. Email sales@skimmer.co.in. Telephone +1 289 622 1032.