Embed an ethics culture withing the organization – Providing internal review of company policies to ensure corporate consistency and integration with ATNS’s ethics philosophies. Formulating and implementing appropriate Ethics Management policies and practices to guide processes within the function. Identifying and undertaking Ethics Management related projects to enable achievement of the ATNS business strategy and related initiatives. Establishing a well-defined code of ethics outlining expected behaviors and responsibilities. Developing clear and practical policies covering key ethical areas (e.g., conflicts of interest, anti-bribery). Conducting interactive training on ethical decision making, compliance, and the code of ethics. Establishing a confidential and protected mechanism such as the Whistleblower program for employees to report misconduct. Providing accessible platforms for employees to ask questions and raise concerns.Creating a safe space for employees to raise concerns without fear of retaliation. Regularly gathering feedback to understand employee perceptions of the ethical culture.

Ethical Standards, Policies, Regulations and Advisory - Developing and disseminating corporate ethics statements, policies and supporting forms/acknowledgements. Providing an internal review of other corporate policies to ensure corporate consistency and integration with the company's ethics philosophies. Integrates the corporate ethics message throughout the corporate culture. Developing and maintaining confidential procedures for the handling and processing of complaints and allegations. Providing processes for the confidential hearing of employee issues related to ethics or conflicts. Developing and managing ATNS’ Ethics Program and report to the Social and Ethics Committee on ethics related matters. Identifying ethics risks and opportunities to establish and maintain ATNS’ ethical culture. Assisting in conducting risk assessment, reviewing policies, and establishing ethics systems or processes. Advise the company secretary on the company’s approach to Corporate Governance and Ethics across the business and particularly in relation to the Board of Directors. Development of the company code of ethics and other relevant governance policies approved by the Board. Advising and working with various departments in the organization to identify and develop appropriate and effective governance structures for effective decision making within ATNS.

Audits and Investigations – Promptly conducting investigations pursuant to complaints and allegations of ethical wrongdoing or conflicts of interest. Maintaining records and ensuring appropriate action is taken to address and resolve issues. Preparing written investigative reports as necessary. Recommend corrective actions and monitor their implementation. In conjunction with internal audit, conducting annual corporate governance audits to determine the state of the corporation and presenting findings to Chief Governance Risk and Compliance.

Governance, Risks and Reporting – Ensuring adherence and compliance by Ethics Management with the ATNS regulatory framework. Developing and executing on the training of all relevant employees on the Ethics Management requirements, policies, and processes. Maintaining an up-to-date knowledge and understanding of corporate governance requirements, compliance and reporting responsibilities, and related legal benchmarks from federal and state law. Managing timely compilation and submission of all the required reports (internal and external) to all statutory bodies to ensure compliance. Implementation of corporate ethics and conflict-of-interest training. Conducting ethical decision-making, conflict of interest avoidance training, anti-corruption, anti-bribery workshops/ training for senior management on ethics issues and avoiding conflicts of interest. Educating the business units in corporate governance and ethics related issues and raising awareness across the organisation. Assessing the levels of awareness and perceived effectiveness of ethics management interventions within ATNS and make recommendations. Preparing reports on ethics-related activities, including compliance monitoring, investigations, and training initiatives. Maintaining accurate records and documentation related to the ethics program.

Stakeholders Management - Developing, implementing and managing an effective stakeholder management strategy and processes for Ethics Management. Develop, manage and nurture relationships with all key stakeholders. Establishing, managing and participating in all key forums to ensure effective representation.

Finance and Costs Management - Ensuring efficient utilization of the approved budget. Providing the required supporting documents to enable effective auditing process.