The FundApps Code for Third Parties

As a business, we set ourselves high standards both in what we aspire to achieve and how we behave. The FundApps Code (“Code”) acts as a guide for our economic, social and environmental responsibility and business ethics. Our company follows the Code in spirit and letter and endeavours to always act in ways that supports and promotes FundApps’ values and our culture of care.

As a supplier, you are an extension of our organisation, and as such are expected to not only follow your contractual obligations, but also the principles of the Code or your own equivalent standards, whether in your daily business activities or in the provision of goods and services to us/our clients. By working together, we aim to uphold the highest standards of integrity and fairness, ensuring that every partnership contributes to a sustainable and equitable future.

WE BUILD TRUST IN HOW WE DO BUSINESS

CONFLICT OF INTEREST

FundApps is committed to identifying and addressing real and potential conflicts of interests to ensure we engage in ethical business practices and avoid serious commercial, reputational or client relationship issues. When conducting work for FundApps, you must always act with objectivity and in FundApps’ best interests. Should you encounter an actual or potential conflict of interest that may impact your work for or with FundApps, we request they be disclosed as soon as reasonably possible.

UNFAIR BUSINESS PRACTICES

FundApps does not condone nor tolerate any form of anti-competitive business practice. In the spirit of encouraging fair competition, you shall comply with all applicable competition laws, including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

ANTI-CORRUPTION AND ANTI-BRIBERY

FundApps conducts its business transparently, honestly and fairly and we expect that any third party we engage with does the same. We expect you to take a zero-tolerance approach towards unethical practices and comply with all applicable laws, statutes, regulations and codes relating to anti-bribery and anti-corruption. We understand that exchanging gifts or hospitality may sometimes occur in global business. However, no gifts, hospitality, or benefits should be exchanged that could be perceived as a bribe, create a sense of obligation, or influence behaviour. We strictly prohibit the acceptance of cash, cash equivalents, stocks, or any unlawful or improper benefits to ensure integrity in all business practices.

ANTI-MONEY LAUNDERING, FACILITATION OF TAX EVASION AND FRAUD

We are always on alert for any potentially suspicious or illegal transactions, requests and activities which could result in our business being used to facilitate money laundering, fraud or tax evasion. We refuse to do business with money that was acquired through illegal activities, and we expect all our business partners to comply with laws and regulations governing the fight against illegal financial activities.

SANCTIONS

You must fully comply with all applicable sanctions, export controls, and trade laws, including restrictions on transactions with sanctioned countries, entities, or individuals designated by authorities such as the United Nations, the European Union, or national governments. You are required to implement controls to prevent and detect violations, and to immediately notify us of any breaches.

WHISTLEBLOWING

As a company that values transparency, we encourage our suppliers to monitor its compliance with the Code and report any breaches as soon as possible. You shall not retaliate or take disciplinary action against any worker that has, in good faith, reported breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.

WE ACT RESPONSIBLY

EQUALITY, DIVERSITY AND INCLUSION

FundApps believes in employing individuals based solely upon merit and qualification directly related to professional competence. We require our suppliers to prohibit discrimination in any employment practice based on characteristics other than the individual’s ability to perform the job, subject to any accommodations required or permitted by law.

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

You shall not interfere with the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.

FAIR COMPENSATION, WORK HOURS AND PERFORMANCE ASSESSMENT

FundApps values fair compensation and seeks to work with suppliers who exceed minimum wage standards by adopting benchmarks such as living wage recommendations, industry standards, or collective agreements. You must ensure that working hours comply with applicable laws, are not excessive, and allow for adequate rest periods, aligning with international standards for worker welfare. Additionally, you are expected to maintain a transparent and consistent link between performance and reward, using a framework that assesses outcomes against individual and team objectives and evaluates alignment with company values through demonstrable behaviours.

HUMAN RIGHTS, SLAVERY, HUMAN TRAFFICKING AND CHILD LABOUR

FundApps is committed to protecting human rights and requires suppliers to uphold the same principles. You must ensure that their operations and supply chains are free from forced labour, slavery, human trafficking, and child labour. All work must be freely chosen, and workers must not be subjected to threats, coercion, or exploitation. You are responsible for implementing policies and controls to prevent human rights abuses, ensuring that all workers are of legal working age and employed under fair and lawful conditions.

HEALTH AND SAFETY AT WORK

The safety, health and wellbeing of our team members, business partners and others we work with is of paramount importance to us. We all have a responsibility to act in a way that does not compromise the safety and well-being of people - this is why we implement health and safety protocols to ensure workplace safety and expect you to do the same. You must provide a safe and healthy working environment for all workers, complying with all applicable laws and regulations. This includes taking proactive measures to identify, assess, and mitigate health and safety risks in the workplace. You must ensure workers have access to appropriate safety equipment, training, and facilities, as well as adequate rest breaks and emergency procedures. You are also encouraged to promote mental well-being and create a culture of health and safety awareness throughout their operations.

ENVIRONMENT AND CLIMATE PROTECTION

As a company that’s conscious of its impact on the environment, we expect our suppliers to comply with all applicable environmental laws and regulations. In line with our values, we strive to work with suppliers who go above this requirement and:

1. assess the impact of all historical, current and likely future operations;

2. proactively improve environmental performance, reduce pollution, emissions and waste; and

3. raise awareness and train workers on environmental matters.

CONFIDENTIALITY

As part of the work you do for FundApps you may access information about our business or clients or business that is confidential. You are expected to maintain the highest standards of confidentiality regarding all sensitive information shared by FundApps. You must take appropriate measures to safeguard this information, ensuring it is not disclosed to unauthorised individuals or third parties, both during and after the course of their engagement with FundApps.

ANTI-HARASSMENT, BULLYING AND VICTIMISATION

You must adhere to a zero-tolerance approach to discrimination, harassment, bullying, victimisation, and violence in any form. All workers have the right to a safe and respectful work environment where they feel valued and supported. You are expected to uphold these principles by fostering a culture of respect and dignity throughout their operations. Any violations of this standard must be addressed promptly and may result in serious consequences, including the termination of the business relationship with FundApps.

WE KEEP DATA SAFE

INFORMATION SECURITY

In line with the expectations of our clients, we have created a robust and effective control environment by adamantly incorporating security into all of our processes. Similarly, we expect you to have appropriate information security measures, commensurate with the complexity of our arrangement. Examples of steps we would expect you to take include:

1. Implement technical measures on devices that are used to access FundApps systems (cf. Security Musts)

2. Having technical and organisational measures to protect the availability, integrity and confidentiality of information (including information belonging to or supplied by FundApps) held on your systems;

3. Measures to prevent the unauthorised access of information by third parties including your representatives; and

4. Run background checks on all roles who have direct access to our client’s confidential information.

DATA PROTECTION

We take the privacy of our clients, employees and others with whom we conduct business seriously. We therefore expect you to handle any personal information you receive from us with care and comply with all applicable data privacy laws.

RESPONSIBLE USE OF AI

You must inform FundApps when AI is used in the services provided and cooperate fully with any inquiries related to our security review process. We expect suppliers to use AI responsibly, ensuring it aligns with ethical standards, legal regulations, and the core values of FundApps. You must avoid biases, respect data privacy, and ensure transparency in AI-driven decision-making. AI systems should be secure, regularly reviewed for vulnerabilities, and used in a way that maintains fairness, safeguards personal data, and upholds the highest ethical standards.

YOUR RESPONSIBILITIES UNDER THIS CODE

PROCUREMENT

You must conduct thorough due diligence before engaging any subcontractors or third-party representatives, ensuring they meet the minimum standards and principles outlined in this Code or your equivalent standards. If you engage subcontractors to perform services critical to those provided to FundApps, we must be informed of any material changes in these relationships. Contracts with subcontractors should outline compliance expectations, the consequences of non-compliance, and ensure systems are in place to monitor adherence and address any breaches or deficiencies promptly.

TRAINING, CERTIFYING COMPLIANCE AND AUDIT

You are required to provide ongoing training to all staff on the relevant principles of this Code or your equivalent standards. On request, you will also provide written confirmation that you have implemented measures necessary to monitor your compliance and no major concerns regarding such ability have been raised. We also reserve the right to request any additional third-party or self-certifications that are reasonably required to demonstrate such compliance.

REPORTING OF BREACHES

You must monitor your compliance accordingly and report any actual or suspected breaches without undue delay to [e-mail]. Where FundApps becomes aware of a breach of this Code or your equivalent standards, we may either:

1. Terminate the business relationship with you (including any contracts); or

2. Require you to produce a remediation plan specifying the actions you will take that will lead to compliance and present it to us within 30 days of being requested to do so. Failure to produce the remediation plan or to implement it without undue delay may result in the immediate termination of our business relationship (including any contracts).

WHO TO CONTACT IF YOU HAVE ANY QUESTIONS ABOUT THE CODE

Should you have any queries about the Code, please do not hesitate to contact your Supplier Relationship Manager or e-mail us at [e-mail].