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HUMAN RIGHTS POLICY

Respecting and protecting human rights in all our operations

Executive Summary

SCANDIC FINANCE GROUP LIMITED recognizes universal human rights as the binding framework for all global activities. We are committed to identifying, preventing, and mitigating human rights risks across our entire brand ecosystem.

  • Zero Tolerance: Strict prohibition of forced labor, child labor, and modern slavery.
  • Responsibility: Rigorous due diligence for all business partners, customers, and supply chains.
  • Rights Protection: Special focus on investor protection, passenger safety, and data privacy.

SCANDIC FINANCE GROUP LIMITED

by Scandic Banking Hong Kong

Room 10, Unit A, 7/F

Harbour Sky, 28 Sze Shan Street

Yau Tong, Hong Kong – SAR / PRC

79325926

Head office telephone number in Switzerland, Zurich: +41 44 7979 99–85

Email: Office@ScandicFinance.Global

In cooperation with:

in cooperation with:SCANDIC ASSETS FZCO

Dubai Silicon Oasis DDP Building A1/A2

342001 Dubai / United Arab Emirates

Phone: +971 56 929 86–90

Email: Info@ScandicAssets.dev

Commercial register:View Register

In cooperation with:

in cooperation with:SCANDIC TRUST GROUP LLC

IQ Business Centre Bolsunovska Street 13-15

01014 Kyiv / Ukraine

Telephone HQ – United Kingdom of Great Britain and Northern Ireland, London: +44 7470 86 92–60

Email: Info@ScandicTrust.com

Commercial register:View Register

In cooperation with:

in cooperation with:LEGIER BETEILIGUNGS GMBH

Kurfürstendamm 14

10719 Berlin / Federal Republic of Germany

Berlin Commercial Register: HRB 57837

Phone: +49 (0) 30 9921134–69

Email: Office@LegierGroup.com

Commercial register:View Register

Legal notice:

SCANDIC ASSETS FZCO, LEGIER BETEILIGUNGS GMBH and SCANDIC TRUST GROUP LLC operate as non-operational service providers. All operational activities are carried out by SCANDIC FINANCE GROUP LIMITED, Hong Kong, SAR-PRC.

We implement the United Nations Guiding Principles on Business and Human Rights. Our zero-tolerance policy covers forced labor, child labor, human trafficking, and exploitative conditions. We ensure our services do not support human rights abuses.

This policy applies company-wide, covering operational entities (Hong Kong) and service providers (Germany/UAE). It extends to all employees, consultants, and business partners (suppliers, distribution partners, financial intermediaries).

We firmly refuse business with entities involved in illegal mass surveillance, systematic torture, genocide, or modern slavery. We respect non-discrimination, freedom of association, and the protection of digital rights.

Ref: UN Declaration of Human Rights, ILO Core Labour Standards, OECD Guidelines.

Overall responsibility lies with the management board. Execution is overseen by the Chief Compliance and Human Rights Officer (CCHRO) and an interdisciplinary Human Rights, Privacy and Ethics Committee (HRPEC).

We conduct annual risk analyses to identify impacts on vulnerable groups. Prevention measures include "Human Rights by Design" and "Privacy by Design" in our payment, aviation, and data products.

SCANDIC FINANCE

Investor protection and avoidance of money laundering structures.

SCANDIC FLY

Passenger safety, dignity, and fair employment for crews.

SCANDIC DATA

Protection of freedom of the press and editorial independence.

SCANDIC ESTATE

Respect for housing and land rights; avoidance of forced evictions.

We guarantee equal opportunity, fair pay, and healthy working conditions. We strictly prohibit harassment, bullying, and any form of involuntary labor for our staff.

In our IT and media services, we uphold freedom of expression and privacy-by-design. Technical measures protect against unauthorized access and digital rights violations.

We maintain secure online portal for anonymous whistleblowing. Whistleblowers are strictly protected from reprisals. If we contribute to a violation, we take immediate remedial action.

Drafted, signed and approved:

The Board of Directors of SCANDIC FINANCE GROUP LIMITED

Hong Kong, SAR-PRC, 1 January 2026

Legal representation: Clifford Chance, Global Law Firm