CODE OF BUSINESS CONDUCT AND ETHICS

Governance

The Wingu Group is dedicated to conducting business consistent with the highest standards of business ethics. Wingu’s Code of Conduct sets forth the policies and standards regarding conflicts of interest, confidential information, competition, fair dealing, corporate gifts and donations, compliance with laws and regulations, environmental, health and safety practices and employment practices. The Code applies to all employees, officers, directors, agents, contractors, customers and suppliers (“Business Partners”). Reporting/Monitoring

Should any suspicious transactions be reported, an appropriate investigation will be undertaken. If the investigation determines that any illegal activities have taken place, a full report of the incident will be provided to the board of directors. This report will detail the incident, weaknesses believed to have led to the incident and the actions that were taken and will be taken to rectify the weaknesses that led to the incident. The ESG Officer will make the board aware of the following, by way of written submission within one month of being made aware:

• Any suspicious transactions and what was done about them.
• Suspicious transactions that have been notified to local law enforcement authorities.

The ESG Officer will take local professional advice on what, if any, further action needs to be taken. In the case of further action being required, the ESG Officer will comply with relevant reporting obligations in the relevant jurisdiction.

Code of Business Conduct and Conflicts of Interest

The Code of Practice

This code is designed to help Business Partners deal with disciplinary and grievance situations in the workplace. Disciplinary situations include misconduct and/or poor performance, and the basic principles of fairness set out in this code should be followed when dealing with these. Grievances are concerns, problems or complaints that Business Partners raise with Wingu. Whenever a disciplinary or grievance process is being followed it is important to deal with issues fairly.

Wingu is committed to creating a culture where everyone is encouraged and supported to achieve and maintain acceptable standards of conduct.

Fair Treatment at Work

Wingu is committed to eliminating discrimination and encouraging diversity in its workforce. Wingu’s intention is to provide a framework for equality and fairness for all, and not to discriminate directly or indirectly in recruitment, employment or promotion, based on age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership.

All employees, officers and contractors, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be based on aptitude and ability. All employees, officers and contractors are responsible for the promotion and advancement of this policy. Behaviour, actions or words that go against this policy will not be tolerated and may lead to reprimands or disciplinary actions. Wingu is committed to creating a harmonious and respectful workplace which supports the potential of its employees.

Disciplinary and Grievance Procedures

Wingu seeks to create a culture of good relations among all Business Partners. However, it is recognised that, from time to time, concerns or disputes may arise which require resolution.

Wingu aims to facilitate a quick, fair and effective resolution of Business Partner concerns or disputes, to maintain an effective working relationship with all parties. Wingu may notify and cooperate with the police or other governmental authorities regarding acts of Business Partners which involve violations of law. Wingu keeps a written record for five years of any disciplinary or grievances cases it deals with.