1. FOREWORD

Dear colleagues,

Van Eck’s success is based on our core values and our management system supported by our main principles, in particular our commitment to Eckcellence. We are the transport solution provider with a strong commitment to deliver innovation and quality together. Our goal is to provide the best possible solution to our customers’ specific transport challenges with the best total cost of ownership. With sustainability in mind, our passion for high-quality and innovation will guide us constantly to reinvent modern road transport.

We act in accordance with our corporate culture, core values and follow all legal and compliance standards. Together with our core values and our leadership principles, this Code of Conduct forms the guideline by which we operate.

This document contains the most important principles which we all must live up to – the management as well as all managers and employees. The Code of Conduct supports us in our everyday business by prescribing binding rules and describing how we can deal with challenging situations.

We urge you to read the contents of this document carefully and discuss the examples with your colleagues. By applying this Code of Conduct, together with our employees, Van Eck will thrive staying the strong and Eckcellent company as it is of today.

Should you have any questions or doubts, please do not hesitate to contact us or your department managers.

Sincerely,

The Management

Aygün Bilgihan      Derun Ünlüer      Ayşenur Nuhoğlu

2. OUR CORE VALUES

Our company, Van Eck Trailers B.V. (“Company” or ”Van Eck“) act in accordance with the special laws related to the sector and the relevant local and international legal regulations. If there is no clarity in industry rules or relevant regulations, our ethical principles compiled within this Code of Conduct (”Code“) will show us the right way.

With sustainability in mind, our passion for high-quality and innovation will guide us constantly to reinvent modern road transport. Our ethical values are integrity, fairness, and compliance with the law and our corporate values are, innovation, reliability, customer-orientation and Eckcellence.

• Innovation; We are on a continuous quest for new opportunities and extraordinary solutions. Our innovative power is based on research, development, extensive technical expertise, and a thorough knowledge of our customers’ operations supported by our active roles in advanced research networks.

• Reliability; Our customer’s future road transportation is in right hands. We value teamwork. We communicate our success as well as failures openly to learn from them and to deliver reliable and consistent products and services each time.

• Customer-Orientation; We make sure that our customers are absolutely satisfied with each Van Eck product. We devote to long-term relationships with our customers. We listen and understand their unique challenges and always provide them the best possible solution.

• Eckcellence; We strive to meet and exceed the expectations of both our customers and Company. We melt the longstanding experience and the best quality in the same pot and deliver it to our customers in every single Van Eck product.

As all Van Eck employees and management, we exhibit attitudes and behaviors that will ensure cultural integrity within the framework of our values and the guidance provided by the Code.

3. OUR ETHICAL PRINCIPLES

an Eck Code is compiled for the purpose of guiding the Company’s employees, managers, and shareholders, as well as all stakeholders such as customers, suppliers, consultants, contractors, subcontractors, institutions, and organizations with which the Company acts on behalf, in other words, to all kinds of real and legal persons who contribute to the Company’s vision and mission. All Van Eck employees must comply with the legal regulations of the countries in which the Company operates or has a business relationship, as well as the Van Eck Code.

Compliance with the Van Eck Code is the duty of all our employees, but the Company’s senior management is expected to show leadership in this regard.

Our Code is based on the following three operational principles:

• Prevention : We aim to set an example and guide honest, fair, and law-based work at all levels in all countries where we operate.

• Detection : We encourage and protect our employees from reporting nonconformities and to support and guide all stakeholders.

• Response : We report violations, investigate them in a proper and fair manner, apply relevant sanctions, if necessary, work to continuously improve our business processes and minimize risks and improve the processes of audits and controls.

When in doubt of a case that is not expressly included in the Van Eck Code or any of our policies, we consult our Chief Supervisors or The Management.

4. OUR PRINCIPLES AND POLICIES

4.1 Respect for Human Rights

Van Eck values teamwork and strives to meet and exceed the expectations of its customers, employees, stand its stakeholders.

• In this context, Van Eck has adopted the United Nations Declaration of Human Rights and compiled the Code in accordance with the United Nations Declaration of Human Rights Declaration.

• We show utmost care to treat all our employees equally and fair, and we expect the same attitude from all our stakeholders.

• It is our Company’s responsibility to ensure that our employees work in a peaceful and comfortable environment. Each individual has the freedom of self-expression.

• We believe that diversity enriches the Company’s culture, and we stand against all forms of discrimination. We do not allow and tolerate any form of violence or harassment in our working environment.

• In all processes starting from the recruitment to the termination of the employment contract, we treat the employee candidate and our employees equally, support them to improve themselves and always treat each of our employees fairly.

• In the employment process, what we seek is the eligibility for the job position regardless of language, religion, race, age, nationality, disability, gender, and sexual orientation.

• We do not tolerate child labor, slavery, human trafficking or forced labor.

• We value open communication and feedback processes within the Company, act with the awareness of the importance of these processes for the development of our employees at all levels and expect all our employees to act accordingly in their internal Company relations.

• We advance our relationships based on trust by exhibiting honest, respectful, equal, fair and ethical behaviors in our customer relationships. We protect and preserve the personal data and trade secrets of our customers in accordance with the relevant local and international legislation.

• We prioritize honesty in our relations with stakeholders and expect them to act in accordance with the Van Eck Code.

• We act fairly, transparently, and objectively in the process of identifying our business partners, and we expect their business capabilities as well as their ethical values to be compatible with the Company. We closely know our business partners and avoid business relationships that may pose a risk to the Company in the future. In case a situation contrary to the Van Eck Code is encountered during our work; we immediately terminate our business relationship in accordance with this Code.

4.2 Compliance with the Law

With sustainability in mind, Van Eck, according to its mission to deliver innovation and quality together, takes responsibility for its actions by providing transparency and reliability.

In every country where we do business, we act in accordance with the law. If the legislation is not clear, we follow our Code and, where necessary, in consultation with the competent authorities.

As Van Eck, we consider intellectual and industrial property rights as an important tool to achieve sustainable competitive advantage and best business results. We protect the intellectual and industrial property rights of our works and respect the intellectual and industrial property rights of third parties.

We act in accordance with the legal regulations in the processing of personal data and take the necessary measures accordingly. In this context, our Company acts in accordance with the local and international legislation we are subject to and follows the rules to process the personal data under all circumstances.

We keep all our business activities and records in a complete and transparent manner in accordance with the applicable legislation and ensure that agreements with third parties are made in compliance with the legislation, our Code, and policies.

4.3 Preventing Conflicts of Interest

As Van Eck employees, we do not take any part in decision making practices that may prevent us from being objective, may benefit ourselves or our relatives, or may create the impression that our decisions are influenced by our roles and responsibilities.

If we are in a situation that may be considered a conflict of interest, we will share the matter with our Chief Supervisor and the Management to eliminate the risk to violate our Code of Conduct. To avoid potential conflicts of interest:

• We do not use the title, reputation, resources, recognition, corporate identity, and power of our Company for our personal gain or anyone else. In addition, we do not provide personal benefits from any natural and/or legal entity with which we have a business relationship.

• If we have a kinship or other affinity with the people in the primary decision-making position in the commercial activities of Van Eck business partners, we inform our Chief Supervisor or the Management.

4.4 Fighting Bribery and Corruption

Van Eck is against all forms of bribery, and similar acts of corruption and will investigate with the utmost care and diligence any allegations made within this framework.

In align with our commitment to fight against bribery and corruption and in compliance with all related local and international regulations, receiving and offering bribes by our employees, as well as persons, and organizations which are authorized to act on behalf of Van Eck are strictly prohibited.

Bribery involves providing, offering, promising, or accepting anything of value to or from any third party, domestic or foreign public officials and other third parties directly or indirectly related to the Company’s business activities, to influence the decision-making process and to gain an illegal benefit.

It is extremely important that all business processes and financial records are clear and transparent in accordance with local and international regulations on fighting bribery and corruption, and that they are recorded and archived together with supporting documents without causing any doubt when evaluated by a third party.

All our employees are obliged to comply with local and relevant international legislation and related policies on fighting with bribery and corruption, and we expect all our business partners to comply with the relevant regulations accordingly.

4.5 Corporate Hospitality

Van Eck’s corporate hospitality practices, such as giving gifts to its customers and potential business partners or hosting them in a Company event, have an important place in our business relations and these practices are subject to certain Company rules.

Corporate hospitality practices should always be kept within reasonable limits and in accordance with the legislation. It should always be noted that hosting is a gesture, and gifts should not bear financially high values or constitute advantages in direct cash or similar ways within the limits specified in Company policies and procedures.

Furthermore, the gifts received should not influence our Company decision making process, and the gifts given should not be intended to affect the decisions of the other party but should be able to be considered as cultural customs, courtesy and/or marketing. The gifts we receive and give must be clearly and transparently kept in the Company’s records.

For detailed information, please review the Company Policy on Corporate Hospitality.

4.6 Political Activities

Van Eck is equally distant from all political opinions as per Company policy and does not donate or support any political party and/or political active person.

While we support that our employees are free to personally support the party or political opinion they want and participate in their activities, they should not be involved in these activities during working hours and by using Company resources (tools, computers, e-mails, etc.).

4.7 Compliance with International Sanctions

As an internationally operating Company, Van Eck pays utmost attention and takes necessary measures within the scope of economic sanctions and export controls. Van Eck is committed to internationally implemented high standards in the fight against money laundering.

Money laundering is the process of integrating illegally obtained revenues into the financial system to make it look as if it was earned legitimately. All Van Eck employees and third parties associated with the Company are obliged to comply with the standards set forth to prevent the use of Van Eck products and services for the purpose of laundering criminal revenues or financing of terrorism.

It is the duty of all employees to comply with local and international regulations. In this context, we only work with parties that generate income from legitimate business activities, have reputation in the market, and value transparency in its business activities.

We do not initiate business relations with the third parties that we do not have sufficient information about, that we have obtained negative intelligence or that we consider there is a risk of money laundering.

In addition to money laundering, within the scope of economic sanction regulations and export bans, some countries and international organizations may limit the transfer or supply of certain goods and services, certain technical information, certain materials, and technology to a country, and a real or legal entity. Within this context, we conduct periodic checks based on the published sanction lists to make sure that the countries in which we operate, real and legal persons do not have relations with the countries, real and legal persons on the sanction lists. We conduct these periodic checks not only before the contract, but also throughout the relationship with the Company.

During these checks, if we encounter with a risky situation, we always follow the procedure, as defined in the Company’s Policy on Sanctions and Export Controls when we encounter a situation that is considered risky.

For detailed information, please review the Company Policy on Sanctions and Export Controls and Company Policy on Prevention of Money Laundering.

Protection of Privacy and Commercial Information

Van Eck ensures the necessary level of security for the protection of commercial and personal data and takes all kinds of technical and administrative measures to prevent the unlawful processing of commercial and personal data of its employees, customers, and business partners and to blocks the access of unauthorized persons to such data.

We are aware that it is forbidden to use or share personal, commercial, financial, technical, legal and/or similar confidential information of our company, employees, customers and business partners for our own benefit or the benefit of third parties, and we take the necessary measures to protect the confidential information we hold in accordance with our roles and responsibilities. We use the information we obtain only for the work we are obliged to perform in accordance with our terms of reference. We act in accordance with the relevant legislation and in accordance with our obligations arising from the confidentiality and non-disclosure clauses concerning trade secrets in the contracts we are part of.

We protect the confidential information we obtain even if we leave the Company and do not share it with third parties.

For detailed information on the use of personal data, please review the Company Privacy Statement.

4.9 Donations and Sponsorship

Van Eck values social responsibility projects.

We can provide financial and/or in-kind assistance to social responsibility projects within the framework of our annual budget planning. We evaluate the requests through a transparent process to ensure the requests do not conflict with our business ethics rules.

We are always cautious in our relationships with public officials in order not to create a perception of commission, bribery or corruption. We comply with the local and international legislation in our donation and sponsorship activities.

4.10 Compliance with Competition Law

Van Eck avoids any kind of actions against the competition law and legislation while achieving its targets.

By executing our strategy in align with our company vision and mission, we follow and comply with the applicable anti-trust and competition legislation at the local and international level. In this context, we avoid providing misinformation to interested parties or obtaining the confidential information of our competitors by unethical means.

Furthermore, we avoid conduct that could be considered as a misappropriation of our respectable position in the sector. We do not use our market position to initiate or take part in anti-competitive agreements against the competitors.

We never enter into agreements and engage in behaviors with the competitors or other persons or organizations that directly or indirectly have the intention of preventing, distorting, or restricting competition or that may result in violation of anti-trust and competition law. We do not conduct negotiations to determine market conditions, and we refrain from participating in all meetings, interviews and organizations that may be perceived as events contrary to competition rules.

We avoid all kinds of meetings and communications that may result in the above-mentioned situations or that may be described as such in other private or professional meetings and other meetings that bring together competitors such as associations, councils, chambers, professional associations and conferences and fairs that are participated on behalf of the Company.

In order to protect our Company, we treat issues that may constitute a violation of the competition law with the same care and diligence. In the case, the Company receives confidential information about our competitors, which does not exist in public sources, we will immediately notify the Chief Supervisor and get his/her opinion to ensure that we do not act contrary to the applicable regulations.

In addition, in the case there is a competition clause in any contract to which the Company is a party, we seek for legal counsel before signing the contract.

4.11 Environmental Awareness, Creating a Healthy and Safe Business Environment

Van Eck is committed to complying with legal and regulatory obligations related to the environment, occupational health, and safety in all its activities, and is committed to creating one of the most respected corporate cultures for Environment, Occupational Health, and Safety (OHS) practices in the semi-trailer manufacturing sector in Europe.

As Van Eck, we pledge to:

• channel all our resources to leave a livable environment to future generations;

• contribute to the protection of biological diversity and ecosystem;

• work to reduce our waste and prevent pollution at its source;

• prevent injuries and occupational diseases;

• utilize latest technology and corresponding process improvements, while generating solutions to the problems related to environment and OHS during the production of semi-trailers;

• evaluate the environment and OHS as a factor in the selection of new investments;

• inform our employees, customers, and external suppliers to generate awareness on environmental protection and OHS measures;

• eliminate hazards and reducing OHS risks;

• provide consultation and participation of employees and employee representatives;

• create the most respected corporate culture in the field of environment and OHS in the semi-trailer manufacturing sector in Europe.

In this context, we know that all Van Eck employees will work in line with Company policies. We state that Van Eck employees shall be obliged to fully comply with the relevant legal obligations and internal processes and to report any violation or suspicion about the environment, occupational health, and safety to the managers.

4.12 Acting Honestly and Fairly in Relations with Stakeholders

All parties affected by the Company’s activities and whose activities affect the Company are our stakeholders, and as Van Eck, we always act honestly and fairly in our relations with stakeholders.

Our basic principles in our relations with our stakeholders are as the following:

• We decide on objective criteria in our supplier, dealer, authorized dealer, and authorized service selections. We engage in business relations with parties that care about human rights, comply with the principles of anti-bribery and anti-corruption, and fulfill their legal obligations.

• We keep our communication channels open with our stakeholders and always consider their complaints and suggestions.

• We always comply with confidentiality rules during our visits and inspections to our stakeholders.

• We expect all our stakeholders to always comply with the relevant laws and regulations.

• We refrain from giving personal opinions to the public, and when the public needs to be informed, we only make statements on behalf of the Company by authorized employees, as defined in the Company’s procedures.

• If we are authorized to make a statement on behalf of the Company, we always provide honest and reliable information to the public and media.

• If we are authorized to make a statement on behalf of the Company, we do not use statements that contradict the Company’s Code.

5. VIOLATION OF ETHICAL PRINCIPLES AND THE EXPRESSION OF CONCERNS

This Code is prepared by compiling our principles of integrity, fairness, and adherence to the law, which are already in practice while performing our activities and which we do not compromise while fulfilling Van Eck’s vision and mission.

The Code highlights our ethical principles under the responsibility of all employees of our Company and the Compliance Manager should be contacted via emailing [email protected] for the cases, which are not covered in the Code or for various reasons needs further clarification.

It is very important for us that our stakeholders we work with know our Code and act in line with our principles. If our ethical principles outlined in this Code have been violated by our employees or stakeholders, these real persons and/or legal entities may face sanctions to the extent applicable, depending on the level of the violation in accordance with the relevant legal regulations in force and our Company policies.

It is very important that any person witnessing any irregularities and/or inappropriate behavior and suspecting such situations shares their concerns with the Company. All kinds of stakeholders, especially our employees, are expected to report any situation they have witnessed or raised suspicions to the Company via https://www.faceup.com/c/vanecktrailers .

The issues that can be reported include, but are not limited to:

• Crimes such as theft and fraud,

• Discrimination of religion, language, gender, race, sexual orientation, and nationality,

• Taking bribes and bribing,

• Mobbing,

• Loss on Company assets,

• Violation of ethical principles and laws and other legal regulations,

• Laundering of proceeds of crime and financing of terrorism,

• Abuse,

• Fraud in accounting records,

• Use of Company facilities for personal gain,

• Undue sharing of confidential personal data or commercial information,

• Unlawful benefits to public servants,

• Improper use of Company materials, or

• Revealing the Company’s trade secret.

If Company employees witness a transaction that they suspect constitutes a violation of the Company Policy on Sanctions and Export Controls and Company Policy on Prevention of Money Laundering, they must directly notify the Risk Manager andCompliance Manager, or alternatively the Company via https://www.faceup.com/c/vanecktrailers in writing.

As Van Eck, it is the responsibility of our Company to take care of the interests of our employees who notify violations (whistleblowers). The Company will carefully evaluate each notice of violation by conducting the investigation with meticulous impartiality. Furthermore, our Company will not tolerate retaliation against such persons due to whistleblowing.

For detailed information on this subject, please review the Company Policy on Whistleblower Protection Policy.