AI ETHICS CODE

Of SCANDIC FINANCE GROUP LIMITED and the SCANDIC Brand Ecosystem

Executive Summary

SCANDIC FINANCE GROUP LIMITED is committed to the responsible, legally compliant, and human-centred use of artificial intelligence. This Code of Ethics establishes the framework for AI governance across our brand ecosystem.

Human-Centric: AI serves people, respecting dignity and fundamental rights.
Compliance: Adherence to EU AI Act, GDPR, and Digital Services Act.
Governance: Interdisciplinary Ethics Committee oversight.

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 Gesellschaft mit beschränkter Haftung and SCANDIC TRUST GROUP LLC act as non-operational service providers. All operational and responsible activities are carried out by SCANDIC FINANCE GROUP LIMITED, Hong Kong, Special Administrative Region of the People's Republic of China.

Applicability in the brand ecosystem:

This AI Code of Ethics applies to the SCANDIC brand ecosystem, in particular to the following brands and services:

as well as for all structures held or supported by SCANDIC FINANCE GROUP LIMITED.

SCANDIC FINANCE GROUP LIMITED recognises the profound importance of artificial intelligence systems for financial services, media, health, mobility, real estate, data processing and digital infrastructure. The aim of this AI Ethics Code is to create a binding framework for the responsible, legally compliant and human-centred use of artificial intelligence.

This Code applies worldwide to all artificial intelligence systems operated or managed by SCANDIC FINANCE GROUP LIMITED, including those developed, operated or used in cooperation with SCANDIC ASSETS FZCO, SCANDIC TRUST GROUP LLC or LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung.

Binding for:

Employees and managers of SCANDIC FINANCE GROUP LIMITED and its affiliated companies,
External service providers, processors and suppliers,
Partner companies within the SCANDIC brand ecosystem,
Other third parties who develop, operate or provide artificial intelligence systems on behalf of or in the interests of SCANDIC FINANCE GROUP LIMITED.

2.1 Human dignity and fundamental rights

Artificial intelligence serves people, not the other way around. All artificial intelligence systems and applications must respect human dignity, fundamental rights and personal rights.

2.2 Legal compliance

SCANDIC FINANCE GROUP LIMITED is committed to complying with all relevant national and international standards. This includes, in particular, the European Union's Artificial Intelligence Regulation, the European Union's General Data Protection Regulation, the European Union's Digital Services Act, relevant copyrights, ancillary copyrights and personal rights, as well as industry-specific regulations.

2.3 Responsibility and accountability

For each artificial intelligence system, a clearly designated responsible person is appointed who is accountable for the purpose, risk assessment, documentation and ongoing monitoring.

2.4 Proportionality

The design and use of artificial intelligence must always be proportionate. The higher the risk to data subjects, the stricter the requirements for justification, transparency, oversight and safeguards.

SCANDIC FINANCE GROUP LIMITED is establishing an Ethics Committee for Artificial Intelligence. This committee is interdisciplinary and includes representatives from Technology, Legal, Data Protection, Information Security, and relevant business areas.

Tasks of the Committee:

Updating the AI Ethics Code and associated guidelines,
Approval of high-risk systems,
Evaluation of incidents with ethical relevance,
Annual review of the overall risk profile.

4.1 EU AI Act

Classification of systems into prohibited practices, high-risk systems, limited-risk systems and minimal-risk systems.

4.2 GDPR

Implementation of data protection through design and data protection-friendly default settings.

Each artificial intelligence system is assigned a risk class before it is introduced:

Prohibited practices: systems that may not be operated,
High-risk systems: significant impact on safety, health, or fundamental rights,
Limited/Minimal risks: transparency requirements or simple support functions.

SCANDIC FINANCE GROUP LIMITED implements appropriate technical and organisational measures to ensure the confidentiality, integrity and availability of data.

Encryption, pseudonymisation and anonymisation,
Logging of accesses and changes,
Separate data storage for development, test and production environments.

Data cards and model cards are created for central data sets and models. These contain information on origin, quality characteristics, intended uses, and limitations.

Artificial intelligence systems are clearly labelled for users. Where possible, understandable explanations shall be provided for decision-supporting systems.

In all critical areas, the final decision-making responsibility remains with humans. Mechanisms are established to check results and stop systems if necessary.

Systems are regularly subjected to simulated attacks (adversarial testing) to identify and remedy vulnerabilities.

SCANDIC FINANCE GROUP LIMITED is committed to respecting human rights throughout its supply chain. Service providers are assessed for compliance with social standards.

Data sets are analysed to identify biases that could lead to unfair treatment. Models are designed to achieve fair results across different groups.

Content created predominantly by generative AI is identified as such. Watermarks or metadata are used where technically possible.

Reporting channels for illegal content and complaint procedures are established in accordance with the Digital Services Act.

Committee for Ethics in Artificial Intelligence

SCANDIC FINANCE GROUP LIMITED

Keilaranta 1, 02150 Espoo, Finland

Email: ai-ethics@scandic-finance.com

Drafted, signed and approved:

The Board of Directors of SCANDIC FINANCE GROUP LIMITED

Hong Kong, SAR-PRC, 1 January 2026