Code of Conduct

FGS Global Inc. and its affiliates and subsidiaries (collectively, “FGS”) operate in many markets and countries throughout the world. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act, the US Foreign Corrupt Practices Act and the Modern Slavery Act, where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

• We, the employees of FGS, recognize our obligations to all who have a stake in our success, including our shareholders, clients and suppliers;

• Information about our business shall be communicated clearly and accurately in a non-discriminatory manner and in accordance with local regulations;

• We select and promote our employees on the basis of their qualifications and merit, without discrimination or concern for race, religion, national origin, sex, sexual orientation, gender identity or expression, age or disability;

• We believe that a workplace should be safe and civilized and that employment must be freely chosen; we will not tolerate sexual harassment, discrimination or offensive behavior of any kind, including but not limited to the persistent demeaning of individuals through words or actions, the display or distribution of offensive material, or the use or possession of weapons on FGS or client premises;

• We will not tolerate the use, possession or distribution of illegal drugs, or our employees reporting for work under the influence of drugs or alcohol;

• We will treat all information relating to FGS’s business, and to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain;

• We are committed to protecting client and employee data in accordance with applicable laws, rules and regulations;

• We will not knowingly create work product that contains statements, suggestions or images offensive to general public decency and will give appropriate consideration to the impact of our work on minority segments of the population, whether that minority be by race, religion, national origin, sex, sexual orientation, gender identity or expression, age or disability;

• We will not undertake work that is intended or designed to mislead, including in relation to social, environmental and human rights issues;

• We will consider the potential for clients or work to damage FGS’s reputation prior to taking them on. This includes reputational damage from association with clients that participate in activities that contribute to the abuse of human rights;

• We will not have any personal or family conflicts of interest within our businesses or with our suppliers or other third parties with whom we do business;

• We will not for personal or family gain directly or indirectly engage in any activity that competes with FGS or with our obligations to FGS;2

• We will not give, offer or accept bribes, whether in cash or otherwise, to or from any third party, including but not restricted to government officials, clients and brokers or their representatives. We will collectively ensure that all employees understand this policy through training, communication and by example;

• We will not offer any items of personal inducement to secure business. This is not intended to prohibit appropriate entertainment or the making of occasional gifts of minor value unless the client has a policy which restricts such entertainment or gifts;

• We will not accept for our personal benefit goods or services of more than nominal value from suppliers, potential suppliers or other third parties;

• No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties or action committees, without the prior written approval of the Global Executive Committee; and

• We will continue to strive to make a positive contribution to society and the environment by: maintaining high ethical standards; respecting human rights in our business, supply chain and through our client work; respecting the environment; supporting community organizations; supporting employee development; and managing significant corporate responsibility risks in our supply chain.