Code of Conduct

1.1 The Code applies to all employees and officers of Pareto Securities AS, whether permanently or temporarily employed, including all branches and subsidiaries in Norway and abroad (“Pareto Securities”).

1.2 The Code has been adopted by the Board of Directors, which is responsible for reviewing and assessing the need for revisions of the Code at least once every three years.

1.3 The Code is grounded in applicable legal requirements and internationally recognised standards. It is primarily based on the ten principles of the United Nation’s Global Compact, which are derived from key international agreements. These include the UN Universal Declaration of Human Rights, the Conventions of the International Labour Organisations, the UN Convention against Corruption, and the Rio Declaration on Environment and Development.

1.4 The securities legislation and other relevant applicable legislation in the jurisdictions where we operate establish a minimum standard for the conduct of Pareto Securities personnel. Such legislation has been implemented through internal regulations, procedures, and supplementary guidelines. However, compliance with the letter of the law and our internal regulations and procedures is not always sufficient. Pareto Securities is committed to promoting market integrity by upholding and advancing sound business practices. This requires each employee to actively apply ethical considerations in their daily work.

1.5 The Code cannot address every ethical dilemma that may arise. Our business and the market conditions in which we operate are constantly evolving, and we face a wide range of ethical challenges. When the Code does not provide explicit guidance, employees are expected to act in accordance with its underlying principles, using sound judgment and common sense. A key test is whether an action could withstand public scrutiny. If you are concerned about how your actions might be perceived by colleagues, clients, the media, authorities, or other stakeholders, the action is likely not aligned with the Code. All activities at Pareto Securities must be able to endure critical internal and external review.

1.6 If you are uncertain about the appropriate course of action, you are encouraged to consult with colleagues, your supervisor, or Compliance.

2.1 We shall comply with laws, regulations, and agreements. These comprise both external and internal regulations, such as policies, standards, instructions, processes, routines/procedures, and agreements. Any errors and nonconformances identified shall be managed in accordance with our reporting routines.

2.2 As an employee, you are responsible for reading all training material and keeping up to date within your discipline. All employees are expected to comply with the information and training provided, and to consult a superior if in doubt. All employees are expected to report if they become aware of any breaches of laws or regulations.

2.3 We do not engage in, facilitate, or encourage illegal activities, including financial misreporting, misconduct, or economic and financial crime.

2.4 We remain alert to potential illegal activities by maintaining a thorough understanding of our clients.

2.5 We take reasonable steps to verify compliance before making decisions and seek guidance if in doubt.

3.1 We are committed to offering our clients sound financial solutions and investment opportunities. In all circumstances, their interests must take precedence over our own. Clients should never have reason to doubt our integrity or our commitment to acting in their best interests.

3.2 Conflicts of interest may arise between clients – for example, between those seeking to sell at a high price and those aiming to buy at a low price. As intermediary, our role is to facilitate fair and informed decision-making that helps establish market equilibrium. This is achieved by ensuring that all parties have access to relevant, accurate and timely information.

4.1 We are committed to honesty and integrity in everything we do. We must never attempt to alter, conceal, or misrepresent relevant facts. There is no room for dishonesty at Pareto Securities.

4.2 All information provided to clients must be accurate, clear, balanced, and not misleading. This ensures that clients are equipped to make well-informed decisions.

4.3 All information shared with government authorities or other external parties must be, to the best of our knowledge, accurate and complete. This helps ensure a proper understanding of our activities.

4.4 These principles also apply to conduct on social media platforms, including – but not limited to – LinkedIn, X (formerly Twitter), Facebook, and Instagram. Employees should exercise caution when engaging in chats, blogs, or discussions on social media platforms, especially when commenting on topics related to our professional field. We should avoid posting work-related opinions on personal social media accounts, as this may blur the line between private views and our roles as representatives of Pareto Securities. However, sharing unaltered content from Pareto Securities' official social media channels is permitted. Employees should refer to our Social Media Policy for further guidance.

5.1 Pareto Securities shall maintain independence from other companies and from our clients.

5.2 We must actively avoid situations where our independence could be questioned, compromised or perceived as compromised.

6.1 We strive to prevent conflicts of interest, as they can impair sound judgment and decision-making. If a conflict of interest does arise, we are committed to addressing it transparently and resolving it appropriately. Please refer to our Conflicts of Interest Policy for further guidance.

6.2 Conflicts of interest may occur when the interests of Pareto Securities diverge from personal interests. Such situations can also arise between the regulatory requirements and expectations, client needs and interests, and the commercial objectives and expectations of Pareto Securities’ owners.

6.3 As an employee, you must exercise particular caution in situations where your personal interests, or those of your family and friends, may conflict with the interests of Pareto Securities or its clients. This includes being particularly vigilant when engaging in private transactions involving assets such as property or financial instruments.

7.1 All interactions, whether internal or external, shall be characterised by humility, respect, and courtesy.

7.2 We compete fairly. Clients and assignments must be won through the quality of our services and products, not by disparaging competitors or engaging in unethical business practices.

7.3 Communication channels provided by Pareto Securities, including landline telephones, mobile telephones, Bloomberg, and e-mail, must never be used to transmit messages containing racist, pornographic, unlawful, or offensive content.

7.4 Our conduct outside of work may also reflect Pareto Securities. Unacceptable behaviour, such as the use of illicit drugs, illegal gambling, or the procurement of sexual services, constitutes a violation of this Code, even if it occurs outside working hours.

7.5 Employees are expected to manage their personal finances responsibly and settle debts in a timely manner. Financial distress can impair judgment and lead to undesirable behaviour. If you experience payment difficulties, you are encouraged to speak with your immediate supervisor.

8.1 We are committed to fostering a safe, inclusive, and supportive workplace by actively promoting health, well-being, and psychological safety.

8.2 We take proactive steps to prevent workplace accidents and injuries by understanding and managing risks in our daily work environment.

8.3 Each of us shall contribute to a positive and engaging work culture. Bullying, harassment, or discrimination, towards colleagues or others, is never acceptable.

8.4 We value diversity and inclusion. Employment decisions, performance evaluations, promotions, and compensation are based on merit, competence, and performance – not on bias or personal preference. Please refer to our Diversity and Inclusion Policy for further guidance.

8.5 We are dedicated to continuous learning and development. By enhancing employees’ skills, knowledge, and capabilities, we ensure they remain qualified and contribute meaningfully to the success of the business.

9.1 We respect fundamental and internationally recognised human rights across our operations. We are responsible for ensuring that our business activities do not negatively impact these rights. Please refer to our Human Rights Policy for further guidance.

9.2 We take proactive measures to minimise the risk of being complicit in human rights violations.

9.3 We ensure our employees receive a fair, living wage and respect the legal limits on regular and overtime working hours in the countries where we operate.

9.4 We ensure that all employees have written employment contracts in place.

9.5 We recognise and respect the right to freedom of association and applicable collective bargaining agreements. Employees are free to resign in accordance with established regulations.

9.6 We are firmly committed to the effective abolition of child labour. We do not tolerate forced labour, slave labour, or any form of involuntary labour within our operations or value chain.

10.1 We maintain zero tolerance for bribery and corruption in any form. Please refer to our Anti-corruption Policy for further guidance.

10.2 We must never accept gifts or other benefits that are intended, or could be perceived as intended, to influence our professional judgement or actions.

10.3 We must not misuse our affiliation with Pareto Securities to gain undue personal advantages, such as access to private events, restaurant reservations, or personal profit. The use of our Pareto Securities title outside work should be limited to situations directly related to our professional responsibilities.

10.4 We must not offer gifts, benefits, or services that could create inappropriate dependencies between Pareto Securities and its clients.

10.5 We do not make facilitation payments and must not engage in or support any form of corruption.

11.1 Employees regularly have access to confidential information. Our trusted position with clients and public authorities depends on ensuring that such information is handled responsibly and protected against misuse or unauthorised disclosure.

11.2 Confidential information must only be used for its intended purpose. Internally, access is governed by the need-to-know principle.

11.3 Searches in internal registers or databases must only be conducted for legitimate work-related purposes.

11.4 Confidential information may, under certain circumstances, constitute inside information as defined by securities trading legislation. Such information is subject to particularly strict disclosure restrictions. We must assess whether information qualifies as inside information and take appropriate measures to prevent its misuse or unauthorised disclosure.

12.1 We are committed to safeguarding the privacy of our clients, employees, and business partners. Personal data should be collected and processed fairly, lawfully, and transparently – and only for legitimate purposes.

12.2 We respect individuals’ right to control their personal data, including how it is used, to the extent permitted by applicable legal obligations. Personal data should only be shared with authorised recipients, whether within Pareto Securities or with approved third parties.

12.3 We continuously aim to update and maintain appropriate security measures to protect personal data from loss, misuse, unauthorised access, or alteration.

13.1 We are committed to protecting Pareto Securities from being used to facilitate financial crime, including money laundering, terrorist financing, and sanctions violations.

13.2 We manage financial crime risks as part of our daily operations, in line with our risk appetite and compliance culture.

13.3 We strive to maintain a thorough understanding of our clients and other relevant parties, enabling us to identify and manage financial crime risks in both personal and digital interactions.

14.1 We acknowledge our shared responsibility in addressing climate change and supporting the transition to a climate-resilient global economy. Please refer to our Sustainability Policy for further guidance.

14.2 Environmental considerations should be integrated into our business strategy, with a focus on areas where we can, or already have an impact – including the assessment of climate-related risks.

14.3 We are committed to promoting and supporting the development and use of environmentally friendly technologies, products, and services, aiming to contribute to long-term sustainable development.

14.4 We strive to minimise the environmental footprint of our own operations and throughout our value chain. Please refer to our Code of Conduct for Business Partners and Suppliers for further guidance.

15.1 We are committed to identifying and addressing inappropriate conduct at Pareto Securities. Employees are encouraged to report concerns in accordance with designated whistleblowing procedures. The whistleblowing function allows for anonymous reporting, without fear of retaliation. Reports are handled by an independent law firm bound by a duty of confidentiality.

15.2 Pareto Securities is legally obligated to report suspicious transactions to the relevant authorities. Employees must report any potentially suspicious activity internally, in line with our procedures.

15.3 Reporting concerns will not result in negative consequences for whistleblowers. However, failure to report serious misconduct may have consequences, as outlined in Principle 17.

16.1 Each employee is personally responsible for adhering to the principles outlined in the Code.

16.2 Department heads are accountable for ensuring compliance within their teams and are expected to demonstrate these principles through their own conduct.

16.3 Compliance supports adherence to the Code by providing training and awareness initiatives designed to strengthen ethical conduct across the organisation.

17.1 Violations of the ethical principles outlined in this Code may result in disciplinary action. Depending on the severity of the breach, consequences may include formal warnings, reduction of variable remuneration, reassignment, termination of employment, referral to the Disciplinary Committee of the Norwegian Securities Dealers Association (or equivalent bodies in other jurisdictions), and/or reporting to law enforcement authorities.

17.2 All employees are responsible for staying up to date with relevant laws and regulations within their area of work, as well as any changes to internal regulations and procedures, to ensure ongoing compliance.