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This Integrity Code sets out the general guidelines that all employees and directors must adhere to, to ensure their actions are consistent with high ethical standards and compliant with applicable laws, rules, and regulations. If any doubt arises regarding the appropriateness of a particular situation, it should be referred to an immediate supervisor.
 
The goal of this Code of Integrity is to protect POLDER CAPITAL's and its principal's aspiration and tradition of high moral, ethical, and legal standards of conduct. Every employee and management member of POLDER CAPITAL is required to comply fully with the rules and approval procedures laid out in its Code of Integrity.
 
Decisions regarding requests for interpretation or exceptions to the Code of Integrity can only be made by management with the guidance of its Compliance Officer. Any violation of the provisions of this Code of Integrity by an employee will result in disciplinary action, including termination of appointment.
 
Any violation by a director will be reviewed by the General Shareholders' Meeting. POLDER CAPITAL requires strict compliance with all laws and regulations by all employees and management. The company is committed to fair dealings with investors and counterparties and is dedicated to providing high-quality products and services that meet all contractual obligations and quality standards.
 
POLDER CAPITAL respects all individuals with whom it conducts business, regardless of their affiliation, ethnicity, political or philosophical beliefs. POLDER CAPITAL does not tolerate offering or accepting any form of reward to any entity or person to effect a transaction. Corporate gifts should be reasonable and functional, and the value must not exceed €50.
 
Invitations to dinners, seminars, excursions, and events should not be in exchange for any favours or violate the standards of decency or the integrity code. POLDER CAPITAL expects its employees and management not to engage in activities to influence the choice of another party. No representative of POLDER CAPITAL may have an employment, consulting or other business relationship with a competitor, customer, or supplier unless prior written approval has been granted by management.
 
Violation of this Code of Integrity is strictly prohibited and may result in disciplinary action. POLDER CAPITAL is committed to providing an annual report to the General Meeting of Shareholders on its compliance with the standards of legal and ethical conduct outlined in the Code of Integrity.

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