1.1 This Code of Ethics Policy establishes the fundamental principles and standards of conduct that all employees, officers, directors, contractors, and agents of the Organization are expected to uphold in the performance of their professional duties and in their interactions with colleagues, clients, partners, regulators, and the public. The policy is designed to foster a culture of integrity, accountability, and transparency that reflects the Organization's core values and supports its long-term reputation. Compliance with this code is a condition of employment and engagement, and violations may result in disciplinary action up to and including termination.

1.2 This policy applies to all individuals who represent the Organization in any capacity, including full-time and part-time employees, temporary staff, interns, consultants, contractors, board members, and any third parties acting on behalf of the Organization. The policy governs conduct both within and outside the workplace where such conduct may reasonably affect the Organization's interests, reputation, or relationships with stakeholders. All personnel are expected to familiarise themselves with this code upon joining the Organization and to seek guidance from their manager or the Ethics and Compliance department whenever they are uncertain about the application of any provision.

1.3 The Organization shall designate a Chief Ethics Officer, or a senior leader with equivalent authority, who shall be responsible for the administration, interpretation, enforcement, and periodic review of this Code of Ethics across all business units, subsidiaries, and geographic locations. The Chief Ethics Officer shall report directly to the Board of Directors or its designated committee on matters of ethics and compliance, and shall have the authority to investigate potential violations, recommend disciplinary action, and implement corrective measures. The Chief Ethics Officer shall also ensure that adequate training, communication, and reporting mechanisms are in place to support the effective operation of this code.

2.1 All personnel shall conduct themselves with honesty, integrity, and fairness in every business transaction, communication, and professional interaction. This includes providing accurate and truthful information in all reports, records, and communications; honouring commitments made to clients, partners, and colleagues; and avoiding any action, statement, or omission that could mislead stakeholders, undermine trust, or bring the Organization into disrepute. Personnel shall not engage in deceptive, manipulative, or fraudulent conduct under any circumstances, regardless of perceived business justification or competitive pressure.

2.2 Personnel shall respect the dignity, rights, and diversity of all individuals encountered in the course of their professional duties, including colleagues, clients, vendors, candidates, and members of the public. The Organization expressly prohibits discrimination, harassment, bullying, intimidation, and any form of conduct that creates a hostile, intimidating, or offensive working environment based on race, color, ethnicity, gender, sexual orientation, gender identity, religion, age, disability, national origin, or any other protected characteristic. All personnel are expected to promote an inclusive culture that values diverse perspectives and treats every individual with courtesy and professionalism.

2.3 Personnel shall protect the Organization's confidential information, trade secrets, intellectual property, and proprietary data from unauthorised access, use, or disclosure. Confidential information includes, but is not limited to, financial data, business strategies, client lists, employee records, product designs, and any information designated as confidential by the Organization. Personnel shall not use confidential information for personal gain, share it with unauthorised parties, or retain it after the conclusion of their employment or engagement. Obligations of confidentiality survive the termination of the employment or contractual relationship and remain in force for the period specified in the applicable confidentiality agreement.

2.4 Personnel shall comply with all applicable laws, regulations, and industry standards in every jurisdiction where the Organization operates, including but not limited to anti-corruption statutes, securities regulations, data protection laws, competition laws, and employment legislation. Ignorance of the law shall not constitute a defence for non-compliance. Personnel shall promptly report any known or suspected legal violations to their manager, the Legal department, or the Ethics and Compliance department. The Organization shall provide guidance and training to help personnel understand the regulatory requirements applicable to their roles and shall maintain a register of key compliance obligations reviewed at least annually.

3.1 Personnel shall avoid any situation in which their personal, financial, or familial interests conflict, or could reasonably appear to conflict, with the interests of the Organization. A conflict of interest arises when a personal interest interferes, or has the potential to interfere, with an individual's ability to act in the best interests of the Organization. Common examples include outside employment with a competitor or vendor, financial interests in companies that do business with the Organization, and personal relationships with subordinates or individuals involved in hiring or procurement decisions. All actual or potential conflicts of interest must be disclosed promptly in writing to the individual's manager and the Ethics and Compliance department using the Organization's conflict of interest declaration form.

3.2 The Organization strictly prohibits bribery, corruption, and the offering, giving, soliciting, or acceptance of gifts, entertainment, hospitality, or other inducements that could improperly influence, or could reasonably be perceived as intended to influence, business decisions, government actions, or the exercise of professional judgment. Personnel shall not offer or accept gifts or entertainment that exceed the thresholds established in the Organization's gifts and hospitality policy without prior written approval from their manager and the Ethics and Compliance department. All gifts received or offered above a nominal value shall be recorded in the Organization's gifts register. The Organization shall comply with all applicable anti-bribery and anti-corruption legislation, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and equivalent local laws.

3.3 Personnel shall use the Organization's assets, resources, and information systems responsibly and exclusively for legitimate business purposes unless otherwise permitted by specific Organization policies. This includes physical assets such as equipment, facilities, and inventory, as well as intangible assets such as proprietary information, software licences, and brand identity. Personnel shall safeguard Organization assets against misuse, waste, theft, damage, and unauthorised access, and shall report any suspected loss, theft, or misappropriation to their manager and the relevant department immediately upon discovery. Limited personal use of Organization resources may be permitted in accordance with the Organization's acceptable use policy, provided it does not interfere with job performance, incur material cost, or violate any law or policy.

4.1 The Organization shall maintain multiple confidential reporting channels through which personnel can report suspected ethical violations, misconduct, illegal activity, or concerns about non-compliance with this code or any Organization policy. Reporting channels shall include, at a minimum, direct reporting to the individual's manager or the Ethics and Compliance department, a dedicated ethics hotline operated by an independent third party, and a secure online reporting portal that permits anonymous submissions where allowed by law. The Organization shall publicise these channels through regular communications, training sessions, and prominently displayed notices in all workplace locations. All reports shall be acknowledged within 5 business days and investigated promptly, thoroughly, and impartially.

4.2 The Organization strictly prohibits any form of retaliation, including but not limited to termination, demotion, suspension, harassment, intimidation, threats, or any adverse change in the terms or conditions of employment or engagement, against any individual who in good faith reports a suspected ethical violation, participates in an investigation, or refuses to engage in conduct that the individual reasonably believes to be unethical or illegal. Retaliatory conduct shall be treated as a separate and serious violation of this code, subject to disciplinary action up to and including termination, regardless of the outcome of the underlying reported matter. The Ethics and Compliance department shall monitor for potential retaliation following all reported matters and shall take immediate corrective action where retaliation is identified.

4.3 All investigations into reported concerns shall be conducted by qualified personnel from the Ethics and Compliance department, the Legal department, or an external investigator appointed by the Organization, as appropriate to the nature and severity of the matter. Investigations shall be conducted in a fair, timely, and confidential manner, with due regard for the rights of all parties involved, including the reporter, the subject of the investigation, and any witnesses. Investigations shall be completed within 30 calendar days of the initial report, unless the complexity of the matter requires an extension approved by the Chief Ethics Officer. Findings shall be documented in a confidential investigation report and communicated to the appropriate governance body, which shall determine corrective and disciplinary actions in accordance with this code and applicable law.

5.1 Violations of this Code of Ethics, whether by act, omission, or failure to report known violations by others, shall result in disciplinary action proportionate to the nature, severity, and frequency of the breach. Disciplinary measures may include formal written warning, mandatory ethics retraining, suspension from duties, demotion, forfeiture of incentive compensation, termination of employment or contract, and referral to appropriate law enforcement or regulatory authorities where the conduct constitutes a criminal offence. The Organization shall consider mitigating factors such as voluntary disclosure, cooperation with the investigation, and the individual's overall conduct history when determining the appropriate disciplinary response. All disciplinary actions taken under this code shall be documented and reported to the Chief Ethics Officer.

5.2 All personnel shall complete mandatory ethics training within 30 calendar days of joining the Organization and on an annual basis thereafter. Training shall cover the key provisions of this code, the Organization's core values and ethical expectations, conflict of interest recognition and disclosure, anti-bribery and anti-corruption obligations, confidential reporting mechanisms, and real-world case studies relevant to the Organization's industry. The Ethics and Compliance department shall track training completion rates by department and report aggregate compliance metrics to the Board of Directors or its designated committee on a quarterly basis. Personnel who fail to complete mandatory training within the prescribed timeframe shall be restricted from performing certain duties until training is completed.

5.3 This Code of Ethics shall be reviewed comprehensively at least once every 12 months by the Chief Ethics Officer, in consultation with Legal Counsel, senior leadership, and the Board of Directors or its designated ethics committee. Interim reviews shall be triggered by material changes in applicable legislation, significant organizational changes, audit findings, or incidents that reveal gaps in the existing code. Proposed amendments shall be reviewed by Legal Counsel for legal sufficiency, approved by the Board, and communicated in writing to all affected personnel at least 14 calendar days before the effective date. All personnel shall be required to acknowledge receipt and understanding of material amendments. A complete version history shall be maintained as an appendix to this code.