Code of Business Conduct and Ethics

1 Purpose

The purpose of this Code is to establish a clear standard for lawful, honest and responsible business conduct. It guides decisions where commercial pressure, local practice or incomplete information could otherwise create legal, financial or reputational risk.

2 Scope

This Code applies to directors, employees, consultants and any person acting for or representing DE Trading. Relevant expectations should also be communicated to brokers, agents, suppliers, logistics providers and other counterparties where appropriate.

Applicable law and binding contractual obligations take precedence. The contracting entity and governing requirements must be identified for each transaction.

3 Core standards

• Act honestly, lawfully and in DE Trading's legitimate interests.
• Treat clients, suppliers, colleagues and public authorities fairly and professionally.
• Do not make misleading statements, conceal material facts or create false records.
• Comply with applicable competition, trade, customs, tax, sanctions, anti-bribery, safety, environmental and data-protection requirements.
• Protect confidential information and use it only for an authorised business purpose.
• Do not retaliate against a person who raises a concern in good faith.

4 Conflicts fair dealing and company assets

Actual, potential or perceived conflicts of interest must be disclosed promptly to a Director or designated responsible person. The affected person must not participate in the decision unless the conflict has been considered and an appropriate safeguard is documented.

Competitive information must be obtained lawfully. Price fixing, market allocation, bid coordination and improper exchanges of commercially sensitive information are prohibited. DE Trading information, funds, systems and property must be used responsibly and only for legitimate purposes.

• Personal interests, outside roles and close relationships that could influence a transaction must be declared.
• Commitments must be made only within delegated authority.
• Books, deal records, expenses and supporting documents must be complete, accurate and retained in the approved location.

5 Roles and responsibilities

The Directors are responsible for approving this Code, setting the tone from the top and deciding material exceptions. A Director or designated responsible person should maintain the current version, coordinate proportionate training and record disclosures and concerns.

Every person in scope is responsible for understanding the requirements relevant to their work, seeking guidance when uncertain and escalating suspected misconduct promptly.

6 Reporting concerns

Concerns should be reported to any Director or another designated channel. Where a concern involves that person, it should be raised with a different Director. Reports may be made confidentially and should contain enough factual detail for a fair review.

DE Trading should protect confidentiality as far as reasonably possible, prohibit retaliation for good-faith reports and document how concerns are assessed and resolved. A deliberately false allegation may itself be misconduct.

7 Records awareness and breaches

Acknowledgements, conflict declarations, approvals, training records, investigations and corrective actions should be retained in line with applicable law and the records policy. Training should be proportionate to each person's role and risk exposure.

Suspected breaches must be assessed promptly and fairly. Responses may include additional controls, withdrawal from a transaction, contractual remedies or disciplinary action, subject to applicable law. Possible criminal or regulatory matters should be referred for legal advice.

8 Review

The Code should be reviewed at least annually and whenever there is a material change in law, ownership, business model, geography or risk profile. Material amendments require Director approval.

Implementation note. This policy should be read with the other DE Trading corporate policies, transaction-specific approvals and the law applicable to the relevant contracting entity and transaction.