Introduction

SCALES AND EMBER (PTY) LTD (the “Company”) requires the highest standards of professional and ethical conduct from its employees, officers, and directors. The Company’s reputation for honesty and integrity among its stakeholders is fundamental to the success of its business. No employee, officer, or director will be permitted to achieve results through violations of laws or regulations or through unscrupulous dealings.

The Company intends that its business practices will be compatible with the economic and social priorities of each location in which it operates. While customs vary from country to country and standards of ethics may differ across various business environments, honesty and integrity must always characterize the Company’s business activities.

This Code of Business Conduct and Ethics (this “Code”) reflects the Company’s commitment to a culture of honesty, integrity, and accountability. It outlines the fundamental principles and policies that all employees, officers, and directors are expected to adhere to. Please read this Code carefully.

In addition to following this Code in all aspects of your business activities, you are expected to seek guidance in any situation where there is a question about compliance with both the letter and spirit of the Company’s policies and applicable laws. This Code sets forth general principles and does not supersede the specific policies and procedures covered in the separate Employee Handbooks of the Company and its subsidiaries (the “Employee Handbooks”), in the separate Code of Conduct applicable to our vendors and licensees, or in the separate specific policy statements of the Company, such as the Securities Trading Policy, the Related Person Transactions Policy, the Whistleblower Policy, and the Anti-Bribery Policy. References in this Code to the Company mean SCALES AND EMBER (PTY) LTD or any of its subsidiaries.

Your cooperation is essential to the continued success of SCALES AND EMBER (PTY) LTD’s business and the cultivation and maintenance of its reputation as a responsible corporate entity.