1. PROTECTING THE COMPANY’S ASSETS, RESOURCES AND DATA

We often have sensitive confidential information about Epoch Digital Pte. Ltd. and its subsidiaries (“Epoch Digital”), about other companies, about our clients and about our directors, officers, and employees; preserving the integrity of this information is vital to our business and reputation and is necessary to meet our obligations under data protection laws.

2. ACCURACY OF BOOKS AND RECORDS AND PUBLIC DISCLOSURES

We should take care that our books and records are accurate and that all our business transactions are properly authorized.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

3. DUTIES TO STAKEHOLDERS

In data infrastructure management, one’s reputation is everything and we should act responsibly in dealings with our security holders, customers, clients, suppliers, other stakeholders, and competitors.

We have obligations to our clients and must manage their capital as though it were our own.

4. COMMUNICATIONS AND MEDIA

In this digital era in which we operate, be careful in your written communications made over company information systems, such as email, as this is a permanent record. You must ensure that any of your online activities, including your use of online social media, are appropriate and reflect well on Epoch Digital.

5. CONFLICTS OF INTEREST AND PERSONAL BEHAVIOR

As a representative of Epoch Digital, your personal behavior must be consistent with our values.

As a steward of third party capital, be mindful that we face a heightened risk that one’s personal interests may conflict with or appear to conflict with the interests of the company.

6. POSITIVE WORK ENVIRONMENT

We are committed to maintaining an environment that is safe and respectful; our shared success depends on it.

You are expected not only to refrain from engaging in workplace discrimination, violence and harassment, but also to identify and report these behaviors as they occur.

7. COMPLIANCE WITH LAWS, RULES, REGULATIONS AND POLICIES

We operate in many jurisdictions and are subject to different laws, rules and regulations; you need to be aware of the laws that apply to your activities so that you can comply with them; ignorance of the law is no excuse.

The company has corporate policies that you must be familiar with, as they govern your trading activities, business practices and other conduct while at Epoch Digital.