Code of Conduct

Our Commitment

Adept Technologies Limited ("Adept") is a women-founded technology and business process outsourcing company headquartered in Nairobi, Kenya, serving clients across East Africa and Europe. We are committed to conducting our business with integrity, honesty and respect, in compliance with the law and in line with the Ten Principles of the UN Global Compact.

This statement summarises the standards set out in our internal Code of Conduct, which applies to everyone who works for or represents Adept.

Who This Statement Applies To

Our Code of Conduct applies to all Adept employees, whatever their role or level, and to contractors, consultants, temporary staff, interns and anyone who represents Adept. We expect our suppliers, service providers and business partners to act consistently with these principles.

Integrity and Professional Conduct

We act honestly and in good faith, take responsibility for our decisions and actions, and comply with applicable laws and regulations. We keep accurate and complete business records, and we do not tolerate fraud, theft, misappropriation or the falsification of records.

Respect, Inclusion and Human Rights

We treat everyone with dignity and respect. We do not tolerate discrimination, harassment, sexual harassment, bullying, intimidation or abusive conduct, whether in person or online. We are committed to fair and responsible employment, equal opportunity and an inclusive workplace, and we respect the human rights of our employees, the customers we serve on behalf of our clients, and workers in our supply chain, as set out in our Human Rights Policy.

Anti-Bribery and Anti-Corruption

We have zero tolerance for bribery and corruption, in line with the Bribery Act, 2016 and Principle 10 of the UN Global Compact. We do not offer, give, request or accept bribes, kickbacks or other improper payments, directly or through third parties, and we do not make facilitation payments.

Gifts and hospitality must be modest and occasional, and must never influence, or appear to influence, a business decision. We do not give or accept cash or cash equivalents, and we take particular care in dealings with public officials.

Conflicts of Interest

Our people avoid situations in which personal, family or financial interests could conflict with their duties to Adept, and disclose any potential conflict so that it can be managed transparently.

Confidentiality and Responsible Information Handling

We protect the confidential information entrusted to us by our clients, their customers, our employees and our business partners. We process personal data lawfully, fairly and securely in accordance with the Data Protection Act, 2019 and our Data Protection Policy, and we use technology, including artificial intelligence tools, responsibly and in line with our information security requirements and client commitments.

Responsible Business Relationships

We select and work with suppliers and partners fairly and transparently. We expect them to comply with applicable laws, to reject bribery and corruption, to respect human rights and labour standards, and to protect confidential information and personal data. Where these expectations are not met, we work with the partner to address the issue and may review or end the relationship.

Health, Safety and Wellbeing

We are committed to a safe and healthy workplace in line with the Occupational Safety and Health Act, 2007. Everyone who works for Adept is expected to follow health, safety and security requirements and to report hazards promptly.

Environmental and Social Responsibility

We seek to use resources responsibly and to reduce the environmental impact of our operations. We aim to contribute positively to the communities in which we operate, including through our social impact initiatives.

Accountability

Our Chief Executive Officer holds overall accountability for the Code of Conduct, supported by our leadership team and HR Department. Employees receive training on the Code and acknowledge that they have read and understood it. Breaches of the Code are taken seriously and addressed fairly and in accordance with the law.

Speaking Up and Non-Retaliation

We encourage employees, business partners and other stakeholders to raise concerns about suspected misconduct, fraud, bribery or corruption, harassment, discrimination, human rights concerns or any other breach of the law or our Code. Concerns can be raised confidentially through our internal channels or by contacting hr@adept-techno.com.

All concerns are handled confidentially and investigated fairly. We do not tolerate retaliation against anyone who raises concern in good faith. Nothing in our Code prevents anyone from reporting a concern to the relevant public authorities.

Governance and Review

Our Code of Conduct is approved by our Chief Executive Officer and reviewed annually to reflect changes in the law, our operations and stakeholder expectations. It is supported by our Human Rights Policy, Data Protection Policy, Business & Ethics Code, Whistle Blowing Policy and other internal policies.

Approved by the Chief Executive Officer, Adept Technologies Limited. Version V(02), September 2026.