Business Ethics Guidelines

1.1 Legal compliance and regulatory obligations

SCANDIC FINANCE GROUP LIMITED is committed to strict compliance with all applicable laws, financial market regulations, compliance requirements (including AML/KYC), industry standards and internal guidelines. Every manager and employee is personally responsible for knowing, understanding and complying with these regulations.

In particular, this includes:

• –Consumer protection and competition law
• –Data protection laws (DSG, GDPR, PDPO Hong Kong)
• –Financial market rules and banking regulations
• –Tax laws, reporting and disclosure requirements
• –Sanctions, embargoes and international trade restrictions
• –Money laundering regulations and terrorist financing guidelines

1.5 Combating corruption

Corruption is not tolerated in any form. This includes within the Group:

• –Bribery and granting of advantages
• –Extortion, bribery or kickbacks
• –Acceptance of inappropriate gifts or invitations

Non-transparent commission payments: Gifts may only be accepted if they are of low value, documented and appropriate.

1.6 Dealing with conflicts of interest

Conflicts of interest must be identified, disclosed and avoided at an early stage. This applies in particular to:

• –Secondary employment
• –family ties
• –Personal business relationships
• –own financial interests in customer relationships

2.1 Equality and diversity

Objective: SCANDIC Finance is committed to a balanced and diverse management team.

Target: By 2030, at least 40% of relevant management positions should be held by women.

Responsibility: Human Resources (HR) in consultation with senior management.

Monitoring: Annual reporting and progress analysis.

2.2 Ethics and compliance training

Objective: All employees must participate in mandatory ethics, compliance and AML/KYC training courses each year.

Target rate: 100% training coverage per calendar year.

Responsibility: HR – Monitoring – Compliance department – Management systems management

Monitoring: Annual internal evaluation – Documentation in the training system – Report to management

2.3 Data protection & information security

SCANDIC Finance respects the privacy of customers, employees and partners.

Key areas:

• –Protection of all personal data
• –Secure data processing in accordance with GDPR, PDPO & DSG
• –Minimisation of data access (need-to-know principle)
• –Use of modern encryption and security standards
• –Prohibition of unauthorised data transfer

2.4 Sustainability & social responsibility

As an internationally active financial company, SCANDIC FINANCE GROUP LIMITED bears responsibility for the environment and society.

Commitments:

• –Resource-efficient operations
• –Reduction of our ecological footprint
• –Promotion of sustainable business models
• –Social responsibility towards customers, employees and the public

2.5 Dealing with customers and business partners

The relationship with customers is based on:

• –Security
• –Transparency
• –Reliability
• –Professionalism

Deceptive, aggressive or misleading sales methods are prohibited. Business partners must comply with minimum standards in compliance, ethics and human rights.

2.6 Financial market integrity & risk management

As a financial and banking service provider, SCANDIC FINANCE GROUP LIMITED is committed to:

• –Accurate, complete and timely reporting
• –Transparent risk management
• –responsible financial and investment decisions
• –strict protection of client funds
• –compliance with all anti-money laundering and counter-terrorism financing requirements

3.1 Responsibilities

The following are responsible for implementing this policy:

• –HR
• –Management
• –Management Systems Department
• –Compliance & Risk Management

3.2 Sanctions for violations

Violations of this policy may result in the following consequences, depending on their severity and the legal situation:

• –Termination
• –Internal measures
• –Labour law sanctions
• –Civil law proceedings
• –Criminal reports to authorities

3.3 Annual review

This policy is updated once a year and sent to:

• –new regulatory requirements
• –social developments
• –internal requirements.