BUSINESS ETHICS

Foreword:

SCANDIC FINANCE GROUP LIMITED is committed to the highest standards of ethical, lawful and responsible conduct. This policy defines the core values, decision-making criteria and behavioural requirements that apply to all employees, managers, agents, affiliated companies, external partners and all persons acting on behalf of SCANDIC Finance.

Objective:

Our goal is to create a corporate culture characterised by integrity, transparency, respect, sustainability and responsibility. This policy supplements the Group-wide Code of Conduct, the Human Rights and Security Policies, and all regulatory requirements of the Financial and Banking Supervisory Authority in Hong Kong (SAR-PRC) and all other relevant jurisdictions.

The aforementioned ECO system brands are represented by:

1. General principles

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

1.2 Integrity, honesty and transparency:

We always act openly, honestly and transparently. Any form of deception, misrepresentation, unfair conduct or deliberate manipulation is strictly prohibited. Decisions must always be documented in a transparent manner.

1.3 Responsibility and accountability:

Employees are responsible for their actions, their decisions and their impact on customers, business partners, society and the environment. Mistakes must be communicated openly; cover-ups are prohibited.

1.4 Fairness, respect and equal treatment:

We promote a working environment free from discrimination, harassment, bullying or intimidation. Regardless of origin, language, gender, orientation, disability, religion or opinion, dignity and respect are inviolable at SCANDIC FINANCE GROUP LIMITED.

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

1.7 Whistleblower protection

All employees have the opportunity at any time to report anonymously and without reprisals:

• Violations of laws
• Human rights violations
• Violations of compliance rules
• Corruption, fraud, manipulation
• Risks to customers or the company

Reports can be made to:

• Management
• Compliance department
• Data protection officers
• External whistleblower system (if activated)

Retaliation against whistleblowers is strictly prohibited.

2. Topics, objectives and monitoring mechanisms

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.

• AML policy: https://eur-lex.europa.eu/legal-content/DE/ALL/?uri=CELEX:32024L1640
• KYC policy: https://eur-lex.europa.eu/DE/legal-content/summary/preventing-abuse-of-the-financial-system-for-money-laundering-and-terrorism-purposes-until-2027.html

Responsibility:

• HR
• Monitoring
• Compliance department
• Management systems management
• 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. Enforcement, control and sanctions

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.

4. Final provisions

This policy is an integral part of the corporate culture of SCANDIC FINANCE GROUP LIMITED. All employees are obliged to take note of its contents and comply with it at all times. It shall enter into force upon publication.