1.1 This Code of Conduct establishes the ethical standards, behavioral expectations, and professional obligations that apply to every individual employed by or acting on behalf of the Organization, including full-time, part-time, temporary, and contract personnel at all levels and across all locations. The Code serves as the foundation for cultivating a respectful, productive, and legally compliant workplace environment in which employees understand their rights and responsibilities. It is designed to protect the Organization's reputation, safeguard the interests of employees, clients, and stakeholders, and ensure compliance with applicable laws, regulations, and industry standards. All employees are expected to familiarise themselves with the Code upon joining the Organization and to conduct themselves in accordance with its provisions throughout the duration of their employment.

1.2 This Code applies to all work-related activities and interactions, whether conducted on Organization premises, at client or third-party sites, during business travel, at company-sponsored events and functions, or in any digital, virtual, or online environment where the employee may be perceived as representing the Organization. The Code extends to communications on professional networking platforms, social media channels, and electronic messaging systems where the employee's association with the Organization is apparent or can be reasonably inferred. Conduct outside of working hours that materially damages the Organization's reputation, breaches confidentiality obligations, or constitutes a criminal offence may also fall within the scope of this Code. Employees who are uncertain whether a particular situation or activity falls within the Code's scope should seek guidance from their manager or the Human Resources department before proceeding.

1.3 The Head of Human Resources, or such senior leader as may be designated by the Chief Executive Officer, shall serve as the custodian of this Code and shall bear primary responsibility for its dissemination, interpretation, enforcement, and periodic review. The custodian shall ensure that all employees receive a copy of the Code during onboarding, that annual acknowledgement is obtained from every active employee, and that adequate training and awareness programs are conducted to support consistent understanding and application. The custodian shall consult with Legal Counsel, the Compliance function, and the senior leadership team when interpreting ambiguous provisions or when circumstances arise that are not expressly addressed by the Code. The Code shall be made available on the Organization's intranet and included in the employee handbook.

2.1 Employees shall conduct themselves with integrity, professionalism, courtesy, and mutual respect in all workplace interactions with colleagues, managers, subordinates, clients, vendors, and members of the public. The Organization strictly prohibits harassment, bullying, discrimination, intimidation, threats, and any conduct that creates a hostile, offensive, or degrading work environment. This prohibition extends to verbal, physical, visual, and electronic forms of misconduct, including but not limited to unwelcome remarks, slurs, jokes, gestures, images, and messages directed at or referencing any individual's protected characteristics. Employees are expected to resolve interpersonal disagreements through constructive dialogue and established conflict resolution channels. Retaliation against any individual who reports a concern in good faith is strictly prohibited and shall itself constitute a violation of this Code.

2.2 Employees are expected to maintain punctuality, adhere to their approved work schedules, and fulfil their contractual working hours consistently. Any unplanned absence or anticipated delay must be communicated to the employee's direct manager as early as possible and no later than 30 minutes after the scheduled start of the work period, using the Organization's approved notification method. Employees must comply with the Organization's leave policy when requesting planned absences and must provide appropriate documentation, such as medical certificates, when required. Chronic or patterned absenteeism, tardiness, or failure to follow absence notification procedures shall be addressed through the Organization's progressive discipline process, which may include verbal counselling, written warnings, and ultimately termination of employment for persistent non-compliance.

2.3 The Organization maintains a zero-tolerance policy towards the possession, use, distribution, manufacture, or sale of illegal or controlled substances on Organization premises, in Organization vehicles, or during any work-related activity or function. Employees must not report to work or perform any work duty while under the influence of alcohol, illegal drugs, or any substance, including prescription medication, that impairs their cognitive or physical ability to perform their duties safely and effectively. Where prescription medication may affect an employee's ability to perform safety-sensitive duties, the employee must disclose this to their manager or the Occupational Health team so that appropriate accommodations or reassignments can be considered. The Organization reserves the right to conduct reasonable-suspicion and post-incident substance testing in accordance with applicable laws. Violations of this provision shall result in immediate disciplinary action, up to and including summary dismissal.

2.4 Employees shall dress and present themselves in a manner that is professional, neat, and appropriate to their role, work environment, client-facing responsibilities, and any applicable health and safety requirements. Where the Organization has established a business-casual or formal dress code, employees are expected to comply with the published guidelines. Department-specific or role-specific dress code standards, including requirements for uniforms, personal protective equipment, or industry-specific attire, shall be communicated by the relevant department head and shall take precedence over general guidelines. The Organization shall make reasonable accommodations for religious dress, cultural attire, and disability-related needs upon request. Employees who are uncertain about appropriate workplace attire should consult their manager or the HR department for guidance.

3.1 Employees must avoid situations where their personal, financial, familial, or romantic interests conflict, or could reasonably appear to conflict, with the legitimate business interests of the Organization. A conflict of interest arises when an employee's private interests or external commitments could impair, or could be perceived to impair, their objectivity, judgment, or ability to act in the Organization's best interests. All actual, potential, or perceived conflicts of interest must be disclosed promptly and in writing to the employee's direct manager and the Human Resources department using the Organization's designated disclosure form. The HR department, in consultation with Legal Counsel and the Compliance function, shall assess each disclosure on a case-by-case basis and determine whether the conflict can be managed through mitigation measures, such as recusal from specific decisions, or whether the conflicting activity or interest must be divested or terminated. Failure to disclose a conflict of interest shall be treated as a serious violation of this Code.

3.2 Employees shall not solicit, accept, or offer gifts, gratuities, hospitality, entertainment, or any other item of value from or to any vendor, client, supplier, competitor, or third party where such exchange could reasonably be perceived as influencing, or intended to influence, the employee's professional judgment, business decisions, or the outcome of any commercial transaction. Modest courtesies of nominal value, such as branded promotional items or refreshments at a business meeting, are generally permissible. Any gift, hospitality, or entertainment with an estimated value exceeding $50, or any pattern of smaller gifts from the same source, must be reported to the Compliance team within 5 business days of receipt using the Organization's gift and hospitality register. The Compliance team shall determine whether the gift may be retained, must be returned, or should be donated to a charitable cause. Employees who are offered cash or cash equivalents must decline immediately and report the offer.

3.3 Employees who wish to engage in outside employment, freelance or consulting work, board memberships, advisory roles, or any business activity — whether paid or unpaid — that may compete with the Organization's business interests, create a conflict of interest, or materially interfere with the employee's ability to fulfil their obligations to the Organization must obtain prior written approval from their direct manager and the HR department. Requests for outside activity approval shall be submitted using the Organization's designated form and shall include the nature and scope of the activity, the time commitment, the identity of the external entity, and an assessment of any potential conflict. Approval may be granted subject to conditions, such as time limitations or restrictions on the scope of the external activity. Employees must not use Organization resources, proprietary information, or work time for outside activities. Approved outside activities shall be reviewed annually and may be revoked if circumstances change.

4.1 Employees shall maintain strict confidentiality with respect to all proprietary information, trade secrets, intellectual property, client data, financial information, strategic plans, personnel records, and any other sensitive business information obtained during or as a result of their employment with the Organization. Confidential information shall not be disclosed, copied, transmitted, or made available to any unauthorised individual, whether inside or outside the Organization, except as expressly required for the performance of the employee's job duties or as authorised in writing by the employee's manager and the Legal department. Confidentiality obligations apply during and after the term of employment, and employees may be required to execute a separate non-disclosure agreement reinforcing these obligations. Upon termination of employment for any reason, employees must return all Organization property, documents, and data in their possession and certify that they have not retained any copies.

4.2 Employees must comply with all provisions of the Organization's information security policy, data protection policy, and acceptable use policy, including but not limited to requirements for strong password management and multi-factor authentication, proper data classification and handling according to the Organization's data classification framework, adherence to access control principles of least privilege and need-to-know, secure storage and transmission of sensitive data using Organization-approved encryption tools, and prohibition on the use of personal devices, unapproved cloud services, or public networks for processing or storing Organization data unless expressly permitted under the bring-your-own-device policy. Employees must report any suspected or actual security incident, data breach, or loss of Organization data to the Information Security team within 1 hour of discovery. Failure to comply with information security requirements may result in disciplinary action and, where applicable, personal liability under data protection legislation.

4.3 Employees shall use the Organization's IT systems, email accounts, internet access, telecommunications, and digital collaboration tools responsibly, professionally, and in accordance with the Organization's Acceptable Use Policy. Limited personal use of Organization systems is permitted provided it does not interfere with work duties, consume excessive resources, or violate any provision of this Code or the Acceptable Use Policy. Employees shall not use Organization systems to access, download, store, or distribute material that is illegal, obscene, offensive, defamatory, or discriminatory. The Organization reserves the right to monitor, log, and audit employee usage of its IT systems, including email content, internet activity, and file access, for security, compliance, and operational purposes. Employees should have no expectation of personal privacy when using Organization-owned systems. Monitoring shall be conducted in accordance with applicable privacy laws and the Organization's employee monitoring disclosure.

5.1 Employees must comply with all applicable local, state, national, and international laws, regulations, and industry standards in the performance of their duties, including but not limited to anti-corruption and anti-bribery statutes, competition and antitrust laws, securities regulations, tax and financial reporting obligations, health and safety legislation, environmental regulations, and data protection and privacy laws. The Organization shall provide training and guidance on key regulatory requirements relevant to each employee's role and function. Ignorance of the law shall not be accepted as a defence for non-compliance, and employees who are uncertain about the legality of a proposed course of action must seek guidance from their manager, the Legal department, or the Compliance function before proceeding. Employees who become aware of any actual or suspected violation of law by the Organization, its employees, or its agents must report the matter promptly through the channels described in this Code.

5.2 The Organization provides a confidential whistleblower mechanism, accessible through a dedicated hotline, secure web portal, and direct email to the Compliance Officer, through which employees may report suspected fraud, corruption, financial irregularities, unethical conduct, safety hazards, or violations of this Code or any Organization policy. Reports may be made anonymously where permitted by law. The Organization is committed to protecting whistleblowers from any form of retaliation, including adverse employment actions, harassment, or exclusion, and any individual found to have retaliated against a good-faith reporter shall be subject to disciplinary action up to and including termination. All reports shall be acknowledged within 3 business days and investigated promptly by the Compliance function or an independent investigator, as appropriate. The Organization shall maintain a register of all reports received, investigations conducted, and outcomes determined, which shall be reviewed by the Audit Committee on a quarterly basis.

5.3 Employees holding positions of financial authority, fiduciary responsibility, or access to material non-public information must adhere to heightened standards of conduct as defined by the Organization's finance and compliance policies. These employees shall be required to make annual disclosures of personal financial interests, outside directorships, and related-party transactions that may present a conflict of interest. Employees with access to material non-public information about the Organization, its clients, or its business partners are strictly prohibited from trading in securities or tipping others to trade on the basis of such information, in compliance with applicable insider trading laws. The Compliance function shall maintain a restricted list of securities and shall enforce blackout periods during which designated insiders are prohibited from trading. Violations of insider trading restrictions may result in criminal prosecution and civil penalties in addition to disciplinary action by the Organization.

6.1 Any reported or suspected violation of this Code shall be investigated promptly and thoroughly by the Human Resources department, the Compliance function, or an independent investigator, as appropriate to the nature and severity of the allegation. Investigations shall be conducted with due regard for confidentiality, procedural fairness, and the rights of all parties involved. Where a violation is substantiated, disciplinary action shall be imposed that is proportionate to the severity, intent, and recurrence of the violation, the employee's role and level of responsibility, the impact on the Organization, its employees, or its stakeholders, and the employee's prior disciplinary record. Disciplinary measures may include formal counselling, written warnings, mandatory retraining, suspension with or without pay, demotion, or termination of employment. In cases involving criminal conduct, the Organization may refer the matter to law enforcement authorities.

6.2 All employees shall be required to acknowledge receipt and understanding of this Code of Conduct upon commencement of employment and annually thereafter during the Organization's compliance acknowledgement cycle. Acknowledgement shall be documented through a signed hard-copy declaration or a digitally confirmed acknowledgement via the Organization's HR information system, and the record shall be stored in the employee's personnel file. Failure to submit an acknowledgement within 30 calendar days of the due date shall be escalated to the employee's manager and the HR department for follow-up, and persistent non-compliance may be treated as a violation of this Code. The Organization shall communicate material amendments to the Code to all employees within 14 calendar days of the effective date and shall require re-acknowledgement of the amended provisions.

6.3 This Code of Conduct shall be reviewed comprehensively at least once every 12 months by the Head of Human Resources, in consultation with Legal Counsel, the Compliance function, and the senior leadership team, to ensure that it remains current, effective, and aligned with the Organization's values, business practices, and regulatory obligations. An interim review shall be triggered by any material change in applicable law, a significant organizational event such as a merger or restructuring, or any incident that reveals a gap in the Code's coverage. Proposed amendments shall be reviewed by Legal Counsel for legal sufficiency, approved by the Chief Executive Officer, and communicated to all employees in writing at least 14 calendar days before the effective date. A complete version history, including the date, author, and summary of each amendment, shall be maintained as an appendix to this Code.