Code of Ethics

Six Floor Solutions SA (hereinafter “Six Floor”) conducts its business in accordance with the guiding principle of integrity: acting with honesty, responsibility, integrity and quality, aware that all its internal actions necessarily reflect on the external level.

The Six Floor Code of Ethics, relating to criminal risk prevention (namely, prevention of corruption crimes and related offenses, and money laundering), demonstrates how the Company and all its Employees will act when performing their work and professional duties, wherever they act on behalf of Six Floor, whether at their Head Office or any other location, national or international, in order to prevent any offenses that could lead to undesired consequences regarding the reputation of Six Floor and its Employees.

This Code of Ethics reflects the basic principles for acting responsibly, establishing a set of rules intended to assist the Company and its Employees when making decisions regarding Six Floor’ activities, namely:

• Respect for confidentiality and privacy of all;
• Guarantee of transparency of financial and accounting data;
• Correct use of new technologies;
• Proper management of conflicts of interest;
• Road safety whenever travel is involved;
• Proper treatment of colleagues;
• Rejection of work while intoxicated or under the influence of drugs;
• Acting with integrity in business;
• Maintaining a relationship of transparency with the Administration.

The following basic principles govern the work performed by Six Floor and its Employees: integrity, responsibility, and quality.

Integrity means doing what is right. Acting with integrity positively reflects Six Floor’ reputation and brand.

Responsibility means acting within the law: Six Floor, its Management and all employees must ensure that any possibility of breaking the law is excluded.

Quality means seeking excellence in business; deriving success and benefits from operations while acting responsibly.

The Code of Conduct shall be valid for the following persons:

• Six Floor;
• All persons working on behalf of Six Floor, regardless of their geographical location, the position they hold, and the contractual arrangement that determines their relationship (labor, civil, or commercial), also including Partners and Managers;
• Potential students on internships, traineeships, and/or other arrangements;
• Third parties who maintain relationships with Six Floor, namely suppliers, contractors, workers, or clients, to the extent applicable to them and provided that Six Floor has the ability to make it effective to said third parties.

All persons shall immediately bring to the attention of the Supervisory Body any irregular or unethical actions relating to this Code of Ethics. The channels for contacting the Supervisory Body are indicated below in the Code.

Acting with Integrity in Business

To do business, we try to achieve better results than our competition in a legal, fair, and honest manner. We seek competitive profits through our own merits, never through unethical or illegal business practices. This means that, in relations with suppliers, customers, and employees, workers, or public office holders, we will maintain business integrity and respect the law.

Maintaining a Relationship of Transparency with the Administration

Six Floor’ integrity toward the Administration means that we guarantee total transparency regarding the information we must communicate to public authorities at any time, namely for requesting and obtaining subsidies, exemptions, or public aid that may facilitate the development of our business.

This obligation of transparency prohibits the commission of irregularities or offenses when requesting such subsidies, exemptions, or public aid, such as falsifying the conditions required for their granting or concealing facts or relevant information that could result in the non- granting of such subsidies or aid.

Furthermore, after obtaining subsidies or public aid, we will prevent, when carrying out the activity for which we obtained the subsidy, non-compliance with the conditions imposed by the Administration to obtain and benefit from that subsidy, or alteration of the purposes for which the subsidy or aid was granted. Maintaining the aid means being transparent in our practices and budgets, facilitating external control by the Administration when required to certify the correct use and application of subsidies.

3.1 AntiCorruption Policy

Bribes and Extortion

Six Floor Employees and other persons covered by this Code of Ethics may not offer or receive bribes or illegal advantages related to their professional activity: for example, relations with authorities, public officials from Government departments, clients, or suppliers, or as part of commercial transactions. Corruption, or any type of related practices, cannot be justified by obtaining advantages in favor of any commercial interests of Six Floor or its legal representatives.

Gifts and Hospitality

Under no circumstances shall the following be acceptable:

• Cash gifts or cash equivalents (gift vouchers or purchase vouchers);
• Coverage of costs related to leisure activities, travel, or similar expenses for company guests and their companions;
• Gifts and/or offerings in poor taste, or that involve visiting places inappropriate for conducting professional relationships;
• Gifts offered during or immediately after a sensitive contractual process in which Six Floor has participated;
• Gifts whose offer results in violation of law, local regulation, or internal regulation by the company accepting the gift. In case of uncertainty regarding this aspect, the recipient should confirm whether acceptance constitutes a violation of any regulation, and whether the offer has been duly authorized;
• Facilitation payments.

Our relationships with other companies, authorities, public officials, customers, and suppliers are thus based on the strictest sense of integrity and loyalty in business.

In cases where the payment of a certain amount is the only way to safeguard the health or safety of any Six Floor Employee who is in a context of serious and imminent risk, the aforementioned prohibition may be set aside. In such case, the Supervisory Body must be informed in writing as soon as possible, indicating the value of the payment and the reasons that led to it.

Nevertheless, the person giving or offering the gift or hospitality should consider whether it compromises their independence, integrity, and/or their honesty or that of the beneficiary regarding the decision-making process.

Business meals with clients or suppliers are an acceptable and normal business practice, as long as they remain within reasonable limits regarding their objective and value. In case of uncertainty, the Supervisory Body should be contacted beforehand.

Gifts and Hospitality Offered to Public Officials

Regardless of whether or not it is considered a bribe, the offer of an item of value (gifts and souvenirs) to public officials or authorities requires prior approval from the area/department manager and the Supervisory Body. The definitions contained in this Code of Ethics should be taken into account when evaluating the appropriateness of gifts to be offered to public officials.

With regard to Six Floor’ relations with national and foreign public officials, this Code shall apply in its entirety and without any distinction, as these officials are also subject to special regulation regarding incompatibilities and prohibitions.

Donations to Political Parties and Lobbying

Six Floor does not make donations to political parties.

Six Floor does not participate in any lobbying activities.

Donations to NGOs

Donations to foundations or other non-governmental organizations must be justified by Six Floor’ activity and must be in line with the Company’s pro bono target areas, taking into account relevant procedures that may be established for this purpose.

These procedures shall establish control mechanisms to ensure that donations and contributions to foundations and other non-governmental organizations are not used as a subterfuge for practices that violate any legal rules, as well as this Code of Ethics. Thus, when a donation to a non-governmental organization exceeds €5,000.00 (five thousand euros), it will require approval from Management and the Supervisory Body.

Business and Relationships with Third Parties

Six Floor, by itself or through all its Employees subject to these rules, shall inform all its clients, suppliers, subcontractors, agents, and partners of the terms of this Code of Ethics. Furthermore, these terms must be accepted by such third parties upon signing the corresponding contracts.

Conflicts of Interest

We consider a conflict of interest to be any situation in which external economic, financial, family, political, or personal interests may affect the impartiality of members of the organization in the exercise of their professional duties.

Internal or external relationships arising from work at Six Floor shall not be used for personal benefit or for the benefit of family members or friends. Six Floor’ confidential information shall not be used for personal benefit or for the benefit of third parties.

Six Floor is committed to ensuring that business decisions are made impartially and objectively, without being affected by interests other than those of the organization. In case of doubt about a potential conflict of interest, the situation should be referred to the Supervisory Body by sending an email to the electronic address on the company’s institutional website: info@sixfloorsolutions.com.

3.2. Ad Hoc Prevention of Money Laundering and Terrorism Financing 

To that extent, not being subject to any of the obligations arising from Law No. 83/2017 of August 18, Six Floor and all its Employees are aware of the importance of preventing and suppressing money laundering and terrorism financing, reflecting this in the normal exercise of their duties, with particular care and diligence in matters and operations likely to constitute risk.

Thus, Six Floor has its own procedures and controls regarding Client acceptance, having established formal processes for capturing, processing, and archiving information.

The Supervisory Body and Six Floor Management shall ensure that all persons who are part of Six Floor and who relate to it are aware of and apply the Code of Ethics.

Likewise, all persons who are part of Six Floor are encouraged to question all matters related to Compliance that arise within the scope of their activity.

Furthermore, the Supervisory Body shall create and implement an internal communication plan for issues related to the application of this Code.

All Compliance-related matters may be reported through the following channel: info@sixfloorsolutions.com

The human resources representative and Management are responsible, independently and impartially, for:

• Promoting the dissemination of this Code to all its recipients;
• Analyzing and issuing opinions regarding situations of alleged violation of this Code;
• Receiving reports of alleged violations of this Code, carrying out the respective preliminary investigations and instituting the appropriate disciplinary proceedings, if applicable, without prejudice to any civil, criminal, or administrative liability that may apply;
• Verifying the existence of internal mechanisms for reporting violations, ensuring that such means comply with applicable legislation, namely regarding confidentiality of personal data, information processing, and the absence of retaliation against participants, and reviewing the effectiveness of these mechanisms.

Non-compliance with the rules contained in this Code of Ethics by Six Floor Solutions Employees constitutes a violation with disciplinary consequences, where applicable, and without prejudice to the consequences in terms of civil, criminal, or administrative liability that may apply.

Reports of alleged violations of this Code must be submitted in writing to the Supervisory Body.

Such reports must be suitable and contain a detailed description of the facts (namely authorship, date, location, and context), as well as the name and contact of the reporter, unless they choose anonymity with justification.

The procedure for reporting and registering reports of violations of this Code is disclosed to Stakeholders through appropriate channels.

The Supervisory Body must ensure the maintenance of a register of all complaints received regarding violations of this Code. The register must contain a complaint identification number and the date on which it was received.

This Code enters into force on April 1, 2020.

These sections are intended to complement the existing Code of Ethics (in force since April 1, 2020) to ensure alignment with international partnership requirements, particularly regarding compliance with international sanctions, human rights frameworks, and cross- border anti-corruption legislation.

Six Floor is committed to complying with all applicable national, European, and international legal and regulatory provisions, including but not limited to:

9.1. Human Rights and Labour Standards

Six Floor recognises and upholds the principles set out in:

• The Universal Declaration of Human Rights (UDHR);
• The core conventions of the International Labour Organization (ILO), including the prohibition of forced labour, child labour, discrimination, and the protection of freedom of association and collective bargaining;
• The OECD Guidelines for Multinational Enterprises, particularly regarding responsible business conduct.

Six Floor is committed to ensuring that its operations, supply chain, and business relationships do not contribute to human rights abuses.

9.2. International Anti-Corruption Legislation

In addition to the anti-corruption provisions already set out in Section 3.1 of this Code, Six Floor commits to compliance with the following international anti-corruption instruments, to the extent applicable to its activities and business relationships:

• The French Sapin 2 Law (Loi n° 2016-1691 du 9 décembre 2016) — particularly relevant when engaging in business partnerships with French entities or their subsidiaries;
• The United States Foreign Corrupt Practices Act (FCPA) — prohibiting bribery of foreign officials in connection with obtaining or retaining business;
• The United Kingdom Bribery Act 2010 — which applies extraterritorially to organisations conducting business in or connected to the UK;
• The French Criminal Code provisions pertaining to financial and economic misdemeanours and crimes;
• The OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

No Six Floor employee, officer, director, agent, or representative shall, directly or indirectly, offer, promise, authorise, or make any payment or transfer of anything of value to any government official, political party, or private party for the purpose of influencing an official act, obtaining or retaining business, or securing an improper advantage.

10.1. General Commitment

Six Floor is committed to full compliance with all applicable international trade sanctions and embargo regimes. Six Floor shall not engage in any transaction, activity, or business relationship that would violate or cause any business partner to violate any applicable sanctions or embargoes.

10.2. Applicable Sanctions Regimes

Six Floor monitors and complies with sanctions imposed by:

• The United Nations Security Council, including resolutions passed pursuant to Chapter VII of the UN Charter;
• The European Union, including restrictive measures administered by the Directorate- General for the Treasury (DGT) and the Office of Financial Sanctions Implementation (OFSI);
• The United States Government, including sanctions administered by the Office of Foreign Assets Control (OFAC);
• The French Government;
• The Portuguese Government, to the extent applicable under national law.

10.3 Sanctions Lists Screening

Six Floor shall implement reasonable screening procedures to verify that its counterparties, clients, suppliers, agents, partners, and their beneficial owners do not appear on the following restricted-party lists (non-exhaustive):

• The UN Consolidated Travel Ban and Assets Freeze List published by the United Nations Sanctions Committee;
• The Specially Designated Nationals and Blocked Persons List (SDN) maintained by OFAC;
• The Consolidated List of persons, groups and entities subject to EU financial sanctions;
• Any other applicable sanctions or watchlists.

Screening shall be conducted prior to establishing new business relationships and periodically thereafter for existing relationships.

10.4. Prohibited Activities

No Six Floor employee, officer, director, or representative shall:

• Engage in, facilitate, or support any transaction involving a sanctioned country, entity, or individual;
• Export, re-export, or transfer goods, software, technology, or services in violation of applicable export control or sanctions laws;
• Assist any third party in circumventing or evading any applicable sanctions or embargo.

10.5 Reporting

Any Six Floor employee who becomes aware of, or suspects, a potential violation of applicable sanctions or embargoes must immediately report the matter to the Supervisory Body at: info@sixfloorsolutions.com

Where Six Floor enters into agreements that require ongoing compliance certification (such as non-disclosure agreements or partnership agreements containing compliance clauses), Six Floor undertakes to:

• Provide upon request all elements reasonably necessary to demonstrate compliance with the applicable rules, regulations, and commitments referenced in any such agreement;
• Promptly inform the relevant business partner when Six Floor knows or has reason to know of any failure to comply with the applicable rules by any of its shareholders, officers, directors, employees, affiliates, sub-contractors, or representatives who are directly or indirectly involved in the performance of the relevant agreement;
• Adopt corrective measures to remedy any non-compliance and communicate such measures to the affected business partner without undue delay.

This Code of Ethics, including its supplementary sections, shall be reviewed periodically and updated as necessary to reflect changes in the applicable legal and regulatory framework or in Six Floor’ business activities and partnerships.

Any amendment to this Code shall be approved by Management and communicated to all persons within its scope of application.