Cabeolica’s success is built on our commitment to conducting our business in accordance with the highest standards of ethics and integrity and complying with all applicable laws and regulations. This commitment is documented in our Code of Business Conduct & Ethics (the “Code”), which can be found on our website here: www.cabeolica.com. This Code has been adopted by Cabeolica’s Board of Directors and applies to all employees, associates, agents, and third parties.

Do not break any laws, regulations, or company policies. All personnel are expected to operate to the highest ethical and good corporate governance standards and uphold ESG best practice in all aspects of the business to maintain the company’s reputation and brand.

All personnel have a duty to familiarise themselves with company policies.

Notify the Cabeolica Compliance Officer about any potential conflicts of interest between your role with Cabeolica, and any other role or connection you may have, in order that mitigation measures can be put in place to prevent the conflict becoming material. Relevant notifications should be made using the Declaration of Personal Interests Form.

Act in the best interests of Cabeolica at all times. Do not use your position with Cabeolica to get money, gifts, or free or cheap goods or services. Travel and accommodation from third parties is not accepted unless contractual.

Cabeolica makes timely, factual, and accurate disclosure of material information about Cabeolica’s operations to its shareholders, stakeholders, and relevant regulatory authorities.

Cabeolica’s accounting and financial records are accurate, complete, and recorded in a timely manner, in reasonable detail, for every business transaction undertaken by Cabeolica.

Employees and directors who have control over Cabeolica’s assets and transactions are responsible for establishing and maintaining a system of internal controls in their area of responsibility designed to (a) prevent unauthorised, unrecorded, or inaccurately recorded transactions; (b) permit the preparation of financial statements according to generally accepted accounting principles; and (c) report any breakdown in controls to the Board.

Cabeolica takes a zero tolerance approach to tax evasion and the facilitation of tax evasion.

Do not use Cabeolica’s property for personal reasons. Report to Cabeolica if you know of anyone losing, stealing, damaging, misusing or wasting, Cabeolica’s property.

Do not use Cabeolica’s property or information to make business opportunities for yourself or your friends or relatives.

Do not disclose confidential information about Cabeolica unless that has been authorised by Cabeolica or it is legally mandated. Don’t tell or give people information that Cabeolica has been given by other people or companies or agencies on a confidential basis. You are required to keep confidential information confidential, even after you stop working for Cabeolica.

Cabeolica carefully protects personal data which comes into its possession.

Do not offer bribes or improper payments to secure an advantage. A bribe includes offering money, buying presents, or entertainment, or arranging free or cheap travel. Detailed guidance is provided in the Cabeolica Anti-Bribery & Anti-Corruption Policy.

Cabeolica has requirements relating to the prohibition, recognition, reporting, and investigation of suspected fraud, corruption, misappropriation, and other financial irregularities. Mandatory Reporting Guidance is provided in the Cabeolica Whistleblower Policy.

Cabeolica has a zero tolerance of human rights violations and promotes international human rights standards.

Personnel must not discriminate against people or harass anyone, and must not treat people differently because of their race, tribe, gender, age, sexuality, political beliefs, or religion. There is a zero tolerance of harassment and bullying, Do not take unfair advantage of people or companies that Cabeolica work with.

Cabeolica does not tolerate modern slavery in its supply chain (e.g. underage or indentured labour) and we support Freedom of Association and the Right to Collective Bargaining.

Cabeolica is committed to achieving environmental and safety standards that comply with applicable national laws and meet international standards, including the IFC Performance Standards on Environmental and Social Sustainability, the World Bank Environmental, Health and Safety Guidelines, and the UN Declarations on Human Rights.

In terms of safety, all employees are responsible for identifying and reporting to the Head of Health and Safety any occupational safety hazards in order to maintain a healthy and safe workplace, with a zero-harm culture.

Cabeolica is committed to the efficient use of natural resources, and assesses, monitors, and where necessary, addresses the environmental and social risks and negative impacts of its operations, and potential impacts on local communities. Whistleblowing and Communication:

Cabeolica personnel (or agents) must report to the Cabeolica Compliance Officer any suspected breaches of this Code, e.g. to cabeolicacompliance@cabeolica.com , in accordance with the Cabeolica Whistleblower Policy.

Cabeolica guarantees that there will be no retaliation against any person who in good faith reports an ethics concern, such as a suspected policy violation.

Cabeolica promotes this Code to all third parties and agents and requires them to abide by it.

All Cabeolica personnel are trained on this Code once per year.

Cabeolica’s business shall never include any of the following excluded activities: