Last updated: September 14, 2026

This Code of Ethics applies to SANIVAC USA, LLC and all of its subsidiaries, affiliates, and controlled entities (collectively, the “Company”), including all business operations, divisions, and functions, including but not limited to oil and gas operations, temporary structure installation, sales, marketing, operations, human resources, and all support functions. Operating with the highest ethical standards, including competing fairly for contracts, avoiding any practice which might be construed to be a violation of the letter or spirit of antitrust laws, or violating any law governing the competitive process is paramount. You must only operate in geographies and provide services where you have obtained all technical competence, experience, certifications, registrations, licenses, and permits required by applicable federal, state, and local law for oil and gas operations and temporary structure installation in those jurisdictions, including but not limited to compliance with Texas Occupations Code requirements and Railroad Commission of Texas regulations. You are required to ensure the safety of your employees, representatives, agents and the general public in your endeavors in compliance with all applicable Occupational Safety and Health Administration (OSHA) requirements, Texas labor laws, and industry-specific safety standards for oil and gas operations. We expect you and your agents to use the highest degree of professional courtesy when dealing with potential customers, existing customers, and competitors. Fair and open treatment for the customer is a top priority. To that end, the Company will monitor and provide compliance guidance according to the Company’s contractor and supplier program and will take appropriate disciplinary action for any contractor, supplier, or agent who fails to treat clients in a

Prohibition on Monopolistic Conduct: You must not engage in any conduct intended to monopolize or attempt to monopolize any market or line of commerce. This includes, but is not limited to: (a) predatory or below-cost pricing designed to eliminate competitors or foreclose competition; (b) exclusive dealing arrangements, tying arrangements, or bundling practices that unreasonably restrain competition or foreclose competitors’ access to customers or distribution channels; (c) abuse of market dominance or monopoly power; or (d) any other conduct designed to substantially lessen competition or create barriers to entry. All pricing strategies, distribution arrangements, and competitive practices must be evaluated for antitrust compliance and must not be designed to harm or eliminate competition.

OUR CORE VALUES:

The Company believes that core values are important drivers of behavior, decision-making, and culture. Below are the core values we have at the Company. Each value is defined as follows: We expect every supplier, contractor, and business partner to embrace these values and to consistently demonstrate them:

Quality: We are committed to delivering the highest standards of workmanship, materials, and service in all temporary structure installations and oil and gas operations, meeting or exceeding all applicable industry standards and regulatory requirements.

Honesty: We conduct all business dealings with truthfulness, integrity, and transparency, providing accurate information to clients, regulators, and business partners at all times.

Competitiveness: We compete vigorously but fairly in the marketplace, seeking to win business through superior service, quality, and value while strictly adhering to all applicable antitrust and competition laws.

Transparency: We maintain open, honest communication with all stakeholders, providing clear information about our services, capabilities, limitations, and business practices.

Teamwork: We collaborate effectively with colleagues, contractors, suppliers, and clients to achieve shared goals and deliver exceptional results in all projects.

Customer Oriented: We prioritize our clients’ needs, safety, and satisfaction in all aspects of our operations, striving to exceed expectations and build long-term relationships based on trust and superior service delivery.

Social Responsibility: We are committed to conducting business in a manner that respects human rights, protects the environment, supports the communities in which we operate, and contributes positively to society while maintaining the highest ethical standards.

BUSINESS INTEGRITY & ETHICS:

This Code of Ethics applies globally to all operations and business activities of SANIVAC USA, LLC (“Company”), wherever conducted. The Company and its network of suppliers, distributors, agents, representatives, employees, contractors, independent contractors, consultants, temporary workers, board members, directors, and executive officers share the goal of ethical and compliant practices coupled with high-quality products and services, which will enable all customers to enjoy the experience of a safer, transparent, and compliant business partner, and contribute to positive industry growth and reputation. All our employees and business partners (including board members, directors, and executive officers at all levels), business partners, suppliers, distributors, agents, representatives, contractors, independent contractors, consultants, and temporary workers are expected to comply with their agreement with the Company (“Applicable Agreement”) and with all applicable laws, rules, and regulations governing all of their activities, including international anti-bribery laws (such as the U.S. Foreign Corrupt Practices Act), export control regulations, international sanctions, and anti-corruption laws applicable to international oil and gas operations, as well as applicable Texas laws including the Texas Deceptive Trade Practices-Consumer Protection Act (Tex. Bus. & Com. Code Ch. 17). In addition to said laws (and other items covered in the Applicable Agreement, but not covered here), this Code of Ethics (or “Code”) is designed to help you understand the way the Company conducts (and expects you to conduct) business, and is meant to be a resource to help ensure that your actions align

Government Relations and Foreign Official Interactions:\n\nYou must comply with all applicable laws and regulations governing interactions with government officials, including foreign government officials and public international organizations. Specifically, you must:\n\n- Refrain from offering, promising, giving, or authorizing any valuable gifts, payments, or benefits (whether direct or indirect) to foreign government officials, employees of public international organizations, or any person acting in an official capacity to obtain any business advantage, in compliance with the U.S. Foreign Corrupt Practices Act and similar anti-bribery laws in other jurisdictions;\n\n- Ensure that any legitimate business courtesies, meals, or entertainment provided to foreign government officials comply with applicable law and the recipient’s ethics rules;\n\n- Maintain accurate records of all interactions and transactions with foreign government officials and international organizations;\n\n- Immediately report any requests for improper payments or benefits to foreign government officials or international organization officials to the Company’s compliance department.

Key ethics and compliance issues with which you must comply are as follows:

Bribery, Corruption and Conflicts of Interests:

• Not giving or accepting illegal payments or engaging in corruption, and limiting. For purposes of this Code, bribery is defined as offering, promising, giving, or accepting anything of value, directly or indirectly, to or from any person with the intent to improperly influence any business decision or action. Kickbacks are defined as payments, rewards, or benefits provided in return for favorable treatment, preferential consideration, or improper influence in business transactions. Facilitation payments, sometimes referred to as ‘grease payments,’ which are payments made to expedite or secure the performance of routine governmental or administrative actions, are strictly prohibited regardless of local custom or practice. Prohibited payments include any transfer of money, goods, services, or other items of value that are intended to influence business decisions or obtain improper advantage. The Company prohibits all forms of bribery and kickbacks without exception. Additionally, the Company limits gifts, entertainment, and benefits by not offering or accepting gifts, meals, entertainment, travel, or other benefits of more than nominal value to or from any party doing business with or seeking business from the Company, except where such gifts or benefits are: (i) reasonable in value; (ii) infrequent; (iii) customary in the industry; (iv) not given with the intent to improperly influence business decisions; and (v) compliant with all applicable laws and the recipient’s organizational policies. Cash or cash equivalents must never be given or accepted;
• Complying with antitrust and competition laws;
• You must not engage in price fixing agreements or discussions with competitors regarding pricing, discounts, terms of sale, or any other competitively sensitive pricing information. Any coordination with competitors on pricing matters is strictly prohibited and may constitute a serious violation of antitrust laws. This prohibition extends to indirect sharing of competitively sensitive information through third parties, consultants, intermediaries, or agents. You must not use or assist others in using any intermediary or indirect means to communicate, share, or coordinate competitively sensitive information with competitors.
• All joint ventures, strategic alliances, partnerships, or collaborations involving competitors must be reviewed and approved by the Company’s Legal and Compliance Operations prior to execution. Any proposed collaboration that may implicate antitrust concerns, including but not limited to joint bidding, information sharing with competitors, or coordinated market activities, requires antitrust compliance review and written legal approval before proceeding.
• Competing fairly and ethically for all business opportunities; and when in doubt regarding whether a particular competitive practice, competitor interaction, pricing strategy, or business arrangement complies with antitrust and competition laws, you must consult with the Company’s Legal and Compliance Operations before proceeding.
• Avoiding conflicts of interest, which are defined as situations where personal, financial, or other interests have the potential to compromise or appear to compromise professional judgment, objectivity, or ability to act in the best interests of the Company, including but not limited to: (i) personal financial interests in entities doing business with or competing with the Company; (ii) outside employment or business activities that interfere with Company duties; (iii) personal relationships that affect business decisions; (iv) use of Company position for personal gain; or (v) any circumstance where personal interests could reasonably be perceived to influence business judgment; and . Any actual, potential, or perceived conflicts of interest must be promptly disclosed in writing to the Company’s designated compliance officer or legal department immediately upon awareness. The duty to disclose conflicts is ongoing, and individuals must update their prior disclosures in writing whenever circumstances change, existing conflicts intensify, or new conflicts emerge. Failure to disclose or update conflict of interest information is itself a violation of this Code. Upon receipt of a conflict of interest disclosure, the Company’s compliance officer or legal department shall evaluate the disclosed conflict and within thirty (30) days provide a written determination regarding whether: (i) the conflict is approved to proceed with appropriate safeguards; (ii) a waiver of the conflict is granted; (iii) a management plan is implemented to mitigate the conflict; or (iv) the conflicting activity must be discontinued. All approval, waiver, and management plan determinations shall be documented in writing and maintained in the individual’s personnel or business file.
• Operating with financial integrity.
• Gifts, Entertainment, and Hospitality: No gifts, entertainment, or hospitality may be offered, provided, or accepted if doing so could create the appearance of improper influence or violate applicable anti-bribery laws. All gifts, entertainment, and hospitality must be:
  • Reasonable in value and frequency;
  • Directly related to legitimate business purposes;
  • Provided openly and transparently with proper documentation;
  • In compliance with all applicable laws and regulations; and
  • Never offered or provided to government officials without prior written approval from the Company’s Legal and Compliance Operations.

Employees, contractors, and business partners must obtain written pre-approval from the Company’s Legal and Compliance Operations for:

• Any single gift, entertainment, or hospitality item valued at $100 or more;
• Any gifts, entertainment, or hospitality provided to or received from the same party that exceeds $250 in aggregate value within any 12-month period;
• All gifts, entertainment, or hospitality involving government officials or employees of state-owned enterprises, regardless of value; and
• Any gift of cash or cash equivalents, which are strictly prohibited.

All approved gifts, entertainment, and hospitality must be accurately recorded in business records with appropriate documentation and justification.

• Political Contributions: The Company strictly regulates political contributions made on its behalf to comply with applicable laws and maintain ethical standards. Employees, contractors, and business partners are prohibited from making any political contributions, donations, or expenditures to political parties, candidates, or political action committees using Company funds or resources without prior written approval from the Company’s Legal and Compliance Operations. All requests for political contributions must include:
  • Identification of the recipient political organization or candidate;
  • The business purpose and justification for the contribution;
  • The proposed amount and timing;
  • Documentation of compliance with all applicable federal, state, and local campaign finance laws; and
  • Certification that the contribution does not violate the recipient’s organizational policies.

No political contributions may be made to government officials in any jurisdiction. All approved political contributions must be accurately recorded in business records and disclosed in accordance with applicable law.

• Employees must obtain prior written approval from the Company’s legal or compliance department before engaging in any lobbying activities or substantive interactions with government officials, including elected representatives, appointed officials, or their staff members, to ensure compliance with applicable laws and Company policy.

Business Records and Confidential Information Obligations:

• Protecting the Company’s intellectual property and confidential information;
• Prohibiting the use of Company or customer confidential information for personal gain, benefit, or advantage, or for the benefit of any third party outside the scope of authorized business purposes.
• Protecting customers’ confidential information in accordance with applicable data protection laws, including maintaining appropriate safeguards and obtaining necessary consents for data processing;
• Protecting customers’ confidential information in accordance with applicable data protection laws, including maintaining appropriate safeguards and obtaining necessary consents for data processing;
• Refraining from making any public statements, disclosures, press releases, social media posts, or communications to third parties regarding the Company’s confidential business matters, operations, clients, financial information, trade secrets, or proprietary information without express prior written authorization from the Company;
• Only accessing your own information available in any Company-administered system, software, web portal or the like and not the information of another contractor, supplier, or the Company’s confidential information at any time. You are strictly prohibited from disclosing, sharing, or communicating any confidential information to external parties, competitors, unauthorized contractors, suppliers, or any unauthorized internal personnel without express written authorization from the Company;
• Refusing to seek additional log-in information for suspended or terminated personnel;
• Audit Cooperation and Record Access: All employees, contractors, business partners, and representatives must fully cooperate with internal and external audits, investigations, and compliance reviews. This includes: (i) promptly providing access to all financial records, books of account, and supporting documentation; (ii) making personnel available for interviews and questioning; (iii) responding timely to audit requests and inquiries; (iv) providing truthful and complete information to auditors; and (v) not destroying, altering, or concealing any documents or information relevant to audits or investigations.

Competition and Sales Practices Obligations:

• Respecting known client relationships with other Company contractors by not soliciting or bidding on Company projects for clients that you have actual knowledge have an existing, active Company contract with another Company contractor, provided that this restriction shall not apply to publicly advertised competitive bidding opportunities or requests for proposals;
• Not actively inducing breach of an existing Company contract with another contractor through improper means;
• Refraining from improper solicitation of employees or agents from another Company contractor through misappropriation of confidential information or other unlawful means; provided, however, that general recruitment efforts, job postings, responses to unsolicited applications, and hiring of employees who voluntarily apply shall be permitted;
• You must not collude with competitors on bids or engage in bid rigging, bid rotation, complementary bidding schemes, or any other form of bid manipulation. All bids must be prepared independently without consultation or coordination with competitors. Behaving ethically in contracting with clients and in all project bidding processes is required at all times.
• Implementing robust processes to prevent sales misconduct and restore integrity immediately if and when any misconduct is discovered;
• Requiring agents to comply with this Code and disciplining agents for any misconduct as applicable; and
• Identifying as an agent or representative of the contractor (not an agent of the Company) and accurately describing the contractor’s relationship to the Company.

MARKETING & SALES PRACTICES:

Project Bidding and Client Engagement Compliance

• You are expected to understand the client’s requirements for temporary structures in remote oil and gas locations, including but not limited to site conditions, environmental factors, safety requirements, regulatory compliance for the jurisdiction, worker capacity needs, utilities infrastructure, and logistical constraints for remote deployment.
• No one in the contractor’s organization will harass, threaten, or engage in unethical conduct toward clients, or use deceptive or unfair business practices in project bidding or contract negotiations.
• You will not enter into contracts with clients who do not meet the Company’s qualification criteria or who lack the legal authority to enter into binding agreements. All contracts must be executed by authorized representatives with full legal capacity to bind their organizations.
• No misleading representations about structure specifications, safety features, regulatory compliance, performance capabilities, or cost estimates; no false implications of certifications, government approvals, or affiliations with regulatory bodies; and no misrepresentation of experience or qualifications in oil and gas operations. You must comply with the Company’s policies and compliance guidance materials, including any client communications and project proposal

Key Client Contract Terms

Authorized representatives must review and emphasize key terms of the contract to clients, including but not limited to:

• Contract pricing, payment terms, and any financing arrangements (if applicable),
• The scope of work, deliverables, specifications, and any additional services or change orders,
• Termination provisions and any applicable notice periods as set forth in the contract,
• The fact that the Company provides temporary structures and related services for oil and gas operations and does not guarantee specific operational outcomes beyond the specifications and performance standards set forth in the contract,
• The terms and conditions related to relocation of temporary structures, transfer of services to different sites, and any applicable warranty provisions, including geographic limitations and transferability restrictions.

Branding

The Company’s image is supported by the correct and consistent use of the Company brand. Repetition of brand standards creates familiarity and is the most immediate representation of our Company and our brand. Our brand is a valuable asset that must be used consistently in the proper, approved forms. You must comply with the following branding requirements:

• Have permission to use the Company’s brand and logo in writing, signed by an authorized marketing representative of the Company,
• Submit any Company-branded and/or co-branded materials to the Company for approval prior to printing and/or dissemination,
• Adhere to the Company’s co-branding guidelines in all materials, and
• NEVER use branding or logos from any utility, municipality, government agency or quasi governmental entity on any materials without the express written consent of said organization and the Company.

The Company can provide access to marketing materials, co-branding asset opportunities, and legally-approved collateral materials. Using pre-approved materials ensures You stay within our guidelines. You are required to train your employees, management and any third-party organization with whom you work on applicable laws, including the foregoing marketing, sales and branding practices policies and guidelines.

HUMAN RIGHTS & LABOR:

You will demonstrate a work environment free from discrimination, abuse and harassment, force or coercion, illegal employment, or inhumane treatment. You are explicitly prohibited from engaging in human trafficking in any form, including the recruitment, transportation, transfer, harboring, or receipt of persons by means of threat, force, coercion, abduction, fraud, or deception for the purpose of exploitation. You are explicitly prohibited from discriminating against any individual based on protected characteristics including, but not limited to, race, color, religion, sex, national origin, age, disability, genetic information, veteran status, or any other characteristic protected by applicable federal, state, or local law. You are explicitly prohibited from using forced labor, involuntary servitude, or any form of compulsory labor in your operations and supply chain. You are explicitly prohibited from employing child labor and must comply with minimum age requirements consistent with ILO Convention 138 or applicable local law, whichever is more stringent. All work must be voluntary, and workers must be free to leave employment after reasonable notice. You must comply with all applicable federal and state employment laws, including but not limited to the Fair Labor Standards Act (FLSA), Texas Payday Law (Texas Labor Code Chapter 61), workers’ compensation requirements, and all applicable benefits, leave, wage and hour, and anti-discrimination laws. You will pay agents and subcontractors in a timely manner. Additionally, You will provide human resources for their employees and agents through an accessible, trusted and fair grievance process. The requirements set forth herein shall only apply to the extent consistent with applicable law, and no part of this Code constitutes legal advice.

HEALTH, SAFETY, & ENVIRONMENTAL:

We expect our You to maintain safe working conditions and a healthy work environment for their workers, including with communication of hazards, preventing occupational injuries by providing appropriate personal protective equipment, establishing processes and programs that drive health and safety, and establishing safe work procedures. You are required to anticipate and be prepared for emergency situations and reasonably mitigate risk. We rely on our You to conduct themselves in a safe manner and provide safety support to all employees, agents, and representatives who are working with them. You assume all risk and liability associated with these actions. Additionally, You show a commitment to bettering the environment and will strive to reduce the impact of their operations by preventing pollution and waste, conserving natural resources, reducing their environmental footprint, and identifying methods to minimize packaging and shipping materials.

OPERATIONAL COMPLIANCE:

You are expected to comply with each state and territory regulations governing licensing and permitting required to perform sales. Dealer’s advertising or other customer-facing materials must comply with each jurisdiction’s requirements, including (where applicable) stating the Dealer’s license number as required (business cards, vehicles, flyers, billboards, etc.) along with other required information and in the format required by law. You must consult with their legal counsel to ensure they and their sales personnel or vendors have the appropriate license(s) and registration(s), and display credentials properly in every state or territory in which they operate. You must promptly notify the Company upon any change in license numbers, name, status, or qualifying agent.

GENERAL COMPLIANCE:

You will designate one or more of its management staff to be responsible for assessing and monitoring its compliance with this Code of Ethics and the Applicable Agreement. You are required to establish internal procedures that support compliance with this Code and review those procedures with its employees that perform any activities in relation to the Company’s products. From time to time, the Company will ask You to execute certifications of their compliance with the principles in this Code. Failure to promptly return executed certifications is a violation of the Code and may lead to termination of the business relationship with the Company. The Company or one of our third-party auditors may conduct announced visits to assess compliance with the Code or to confirm that necessary corrective action has been taken. Refusing to grant auditors access to facilities or workers is a violation of the Code. You will develop and maintain internal training, policies and/or codes to ensure that their workers and business partners assisting with Company business understand how to comply with this Code. The Company may periodically require business you and their workers to attend compliance forums. Failure to participate in such training upon request is a violation of this Code.

REPORTING VIOLATIONS:

We expect You to always follow the law and the information in this Code. We also expect You to promptly and responsibly report any actual or suspected violations, including violations by any team member or individual acting on behalf of you or anyone else you are aware of. To report a violation or suspected violation there are several options:

• Contact your Company account relationship manager
• Contact the Company’s customer service line
• Send an email to
• Write to: SANIVAC USA, LLC Attn: Legal and Compliance Operations

You may choose to remain anonymous if you call the Company customer service line. All reported violations that include specific information will be investigated and appropriate action will be taken.

ACKNOWLEDGEMENT:

Compliance with this Code of Ethics is a material condition of your employment, engagement, or business relationship with the Company. We have received this Code of Ethics and, in addition to our other contractual obligations to the Company, hereby agree to comply with it, and to ensure that our subcontractors and vendors engaged in any work related to the Company, comply with the principles in this Code. Failure to comply with this Code may result in disciplinary action, up to and including termination of the business relationship. However, to the extent that any term contained herein is inconsistent with the terms of the Applicable Agreement or would create or extend any right or obligation beyond the scope of the Applicable Agreement, it shall be non-binding.

By AR Portable Services.