Code of Conduct & Ethics Policy

DUE2FYND operates in a regulated environment and is committed to full compliance with all applicable local, national, and international laws, rules, and regulatory requirements. All directors, officers, and employees must strictly adhere to applicable legal and regulatory obligations, including but not limited to securities laws, anti-corruption laws, anti-money laundering regulations, data protection laws, and insider trading prohibitions.

Failure to comply with applicable laws or Company policies may result in disciplinary action, including termination of employment and potential civil or criminal liability.

A conflict of interest arises when personal interests interfere, or appear to interfere, with the interests of DUE2FYND or its clients. Employees and directors must avoid situations where personal, financial, or other interests conflict with their professional responsibilities.

Conflicts may arise if an individual:

• Uses their position for personal benefit
• Receives improper financial or non-financial benefits
• Allows personal relationships to influence business decisions
• Competes directly or indirectly with the Company

All personnel must:

• Act solely in the best interests of clients
• Maintain the highest ethical and professional standards
• Identify and promptly disclose actual, potential, or perceived conflicts of interest
• Fully cooperate in resolving conflicts in accordance with Company policies

If uncertainty exists regarding a potential conflict, the matter must be referred immediately to management or the designated Compliance Officer.

Employees and directors who have access to material non-public information relating to DUE2FYND, its clients, partners, or any issuer must not use such information for personal gain or disclose it to others for securities trading or any other improper purpose.

Material non-public information includes any confidential information that could influence an investment decision if made public. Engaging in insider trading or tipping others constitutes a serious violation of law and may result in severe civil and criminal penalties.

Employees must exercise sound judgment when giving or receiving gifts, hospitality, or entertainment. No employee may offer, solicit, or accept anything of value that could improperly influence business decisions or create the appearance of impropriety.

Bribery, kickbacks, facilitation payments, or any form of improper inducement are strictly prohibited. Interactions with public officials are subject to heightened legal scrutiny, and providing anything of value to government officials to obtain or retain business is strictly forbidden.

All gifts and entertainment must comply with Company policy and may require prior written approval.

Political contributions made on behalf of DUE2FYND or by employees in connection with Company business must receive prior written approval from management and comply with applicable election and anti-corruption laws.

Employees and directors owe a duty of loyalty to DUE2FYND and must not:

• Exploit business opportunities discovered through Company property, information, or position without prior written consent
• Use Company assets or confidential information for personal gain
• Engage in activities that compete with the Company’s legitimate business interests

All legitimate business opportunities identified in the course of employment belong to DUE2FYND.

All employees and directors are obligated to maintain the confidentiality of proprietary and non-public information concerning DUE2FYND, its clients, partners, and stakeholders.

Confidential information includes trade secrets, financial data, client records, strategic plans, and any non-public business information. This obligation continues even after termination of employment.

Nothing in this policy prohibits employees from making lawful disclosures to regulatory authorities or exercising protected whistleblower rights under applicable laws.

Employees are required to promptly report suspected violations of laws, regulations, or Company policies, including accounting irregularities, fraud, or unethical behavior.

DUE2FYND strictly prohibits retaliation against any individual who makes a good-faith report. Reports may be made confidentially or anonymously, where permitted by law.

Employees may also directly contact regulatory authorities without prior Company approval, as protected by applicable whistleblower laws.

DUE2FYND is committed to maintaining a professional, inclusive, and respectful work environment. The Company provides equal employment opportunities without regard to race, ethnicity, religion, color, national origin, sex, gender, gender identity or expression, sexual orientation, age, disability, marital status, citizenship, political affiliation, veteran status, genetic information, or any other protected characteristic under applicable law.

Discrimination, harassment, retaliation, bullying, or any inappropriate workplace conduct will not be tolerated and may result in disciplinary action.

All employees and directors are required to review, understand, and comply with this Code of Conduct. Violations may result in disciplinary action, up to and including termination, and potential legal consequences.