Code of Conduct

Flexibit Services S.R.L. ("FXBITS") is a Romanian software services company committed to social and environmental responsibility, and to ethical business conduct in all aspects of its activities. This Code of Conduct (the "Code") sets out the social-responsibility commitments of FXBITS, as well as the expectations that FXBITS has for its employees, contractors, suppliers, service providers, and business partners.

FXBITS identifies risks and actual or potential adverse impacts that its activities, or those of its suppliers, may have on human rights, the environment, or ethical business conduct. Where such risks or adverse impacts are identified, FXBITS acts to reduce them to a minimum and to remedy any adverse impacts directly caused or indirectly contributed to.

To give full effect to the principles established in this Code, FXBITS expects its suppliers and subcontractors to flow down equivalent requirements to their own suppliers, either by applying this Code or a code of conduct of their own, provided the latter ensures at least an equivalent standard of protection.

This Code applies to all directors, employees, contractors, interns, and any other persons acting on behalf of FXBITS. It applies in all jurisdictions where FXBITS operates and is intended to be read together with applicable law and internal FXBITS policies.

FXBITS complies with all laws and regulations applicable in each jurisdiction where it is established or operates, including all locations where it conducts business activities. This includes compliance with all relevant health and safety, security, environmental, social, and labour law provisions, as well as anti-corruption, anti-bribery, data protection, and competition laws applicable to it. Where this Code sets a higher standard than the law requires, the higher standard applies.

FXBITS conducts its business in a way that upholds and supports the protection of internationally recognised, inalienable human rights, and ensures that it is not complicit in the abuse of such rights. This commitment is grounded in the Universal Declaration of Human Rights, the International Labour Organisation's (ILO) Declaration on Fundamental Principles and Rights at Work, and the United Nations Guiding Principles on Business and Human Rights, and extends to providing fair and dignified working conditions as described below.

No child labour

FXBITS does not employ any person under the minimum legal age for employment under Romanian law, or under the legal minimum age established in the ILO Minimum Age Convention of 1973, whichever is higher. FXBITS expects equivalent commitments from its suppliers and subcontractors.

No forced labour

FXBITS prohibits and refuses to engage in any form of modern slavery, including forced or compulsory labour, human trafficking, bonded or indentured labour. All workers receive a written employment contract in a language they understand, clearly indicating their rights and obligations with regard to wages, working hours, benefits, and other working conditions. FXBITS does not charge workers recruitment fees as a precondition of employment and follows the ILO's general principles for fair recruitment. FXBITS respects the right of workers to terminate their employment after reasonable notice and to receive all owed salary and benefits.

Dignity and respect

FXBITS provides a working environment based on mutual respect and free from physical, psychological, sexual, and verbal harassment, pressure, or duress. Reports of harassment are investigated promptly and confidentially, and corrective action is taken where required.

Fair treatment and equal opportunity

FXBITS ensures fair treatment of its workforce and provides equal employment opportunity to current and prospective workers without discrimination on grounds of race, ethnic origin, nationality, gender, sexual orientation, age, religion or belief, political opinion, health or disability, family status, or any other characteristic protected by Romanian and EU law (notably Law 202/2002 on equal opportunities between women and men, and Government Ordinance 137/2000 on preventing and sanctioning all forms of discrimination). Recruitment, compensation, promotion, training, and termination decisions are based on merit and business need. FXBITS strives towards inclusiveness and gender balance at all levels of its workforce.

Health and safety

FXBITS provides safe and healthy working conditions to all employees and visitors, in line with Romanian occupational safety legislation (Law 319/2006) and applicable EU directives. Risk prevention and mitigation measures are in place, all employees receive mandatory occupational health and safety training (SSM), and where necessary appropriate personal protective equipment is provided. As a software services company, FXBITS also addresses workplace-specific risks such as prolonged screen use, ergonomic posture, and the mental-health considerations of high-cognitive-load work, and promotes balanced workloads and access to support.

Wages, benefits, and working hours

FXBITS pays its workers at regular intervals at least the minimum compensation required under Romanian law and provides all legally mandated benefits. Overtime work is compensated either by equivalent time off or by remuneration at no less than the regular hourly rate, in accordance with the Romanian Labour Code (Codul Muncii). Deductions from wages are made only as mandated by law, regulation, or collective agreement, and are communicated to workers in advance. Deductions from wages are never used as a disciplinary measure. FXBITS follows applicable ILO standards regulating working hours, rest periods, maximum consecutive days of work, and annual leave.

Freedom of association and collective bargaining

FXBITS respects the right of its workers to communicate openly with management to defend their interests and advocate for improvement of their working conditions, without fear of harassment, intimidation, penalty, interference, or reprisal. FXBITS respects the freely exercised right of its workers to join any association of their choosing within the relevant national framework and to bargain collectively.

Environmental management

FXBITS conducts its business in a manner that manages environmental risks and reduces environmental impacts across its operations and supply chain. As a software services company, FXBITS's direct environmental footprint is primarily linked to energy consumption, equipment lifecycle, business travel, and digital infrastructure. FXBITS aims to reduce this footprint by promoting energy-efficient operations and remote work where appropriate, by extending equipment lifecycle and ensuring responsible disposal and recycling of IT assets in accordance with WEEE legislation, by selecting service providers and cloud platforms with credible environmental commitments where commercially and technically feasible, and by encouraging suppliers and partners to adopt environmental management practices appropriate to the size and nature of their business (ISO 14001, EMAS, or comparable systems).

Climate and sustainable development

FXBITS recognises the importance of the Paris Agreement and, in proportion to its size and activities, takes steps to reduce its direct and indirect greenhouse gas emissions, increase the use of renewable energy where available, and minimise consumption, single-use materials, and waste. FXBITS encourages suppliers to consider the environmental, social, and economic impact of their products and services over their full life cycle.

Fraud prevention, anti-corruption, anti-bribery

FXBITS conducts its business in a way that upholds fraud prevention, anti-corruption, and anti-bribery commitments, and prohibits influence peddling, extortion, and illegal payments. FXBITS complies with Romanian anti-corruption law (Law 78/2000) and applicable EU and international standards, regardless of any local customs. FXBITS exercises due diligence to prevent and detect fraud, corruption, influence peddling, or any other misconduct in all business arrangements, including contracts, partnerships, joint ventures, and the engagement of intermediaries such as agents or consultants.

FXBITS and its representatives must never offer, promise, authorise, give, request, or accept any payment, gift, or other benefit with the intent of obtaining or retaining business or gaining an improper advantage. Facilitation payments to public officials to expedite or secure routine actions are prohibited.

Fair competition

FXBITS competes fairly for business opportunities and does not enter into formal or informal anti-competitive arrangements that aim to fix prices, allocate territories or customers, rig bids, or otherwise distort fair competition. FXBITS does not exchange commercially sensitive information with competitors. FXBITS complies with Romanian competition law (Law 21/1996) and EU competition rules.

Managing conflicts of interest

FXBITS and its employees take active measures to avoid actual, potential, or perceived conflicts of interest. Where a conflict arises or appears to arise between the professional interests of FXBITS and the personal interests of an employee or their close relatives, friends, or associates, the affected person must promptly disclose the situation in writing to management so it can be assessed and managed appropriately.

Gifts and hospitality

Gifts and hospitality exchanged in business relationships must be permitted by applicable law and regulation, must not violate the rules of the recipient's organisation, and must be consistent with reasonable market customs. No financial instruments (cash, securities, loans, or similar) are to be offered or accepted. Business courtesies must never be used to gain an unfair competitive advantage or to influence a business decision.

Accurate records and timely payment

FXBITS creates and maintains accurate records of its business transactions. Records, regardless of format, fully and accurately represent the underlying transaction or event, are not altered to conceal or misrepresent activity, and are retained in accordance with applicable retention requirements. FXBITS pays undisputed and correctly presented invoices on time, in accordance with agreed contractual terms and applicable law, and expects equivalent practices from its suppliers.

Responsible sourcing

FXBITS's core activity is software services rather than the manufacture of physical goods, and direct exposure to conflict minerals (tin, tungsten, tantalum, gold) or other EU Critical Raw Materials is limited. Where FXBITS procures IT equipment, hardware, or other products containing such materials, it gives preference to suppliers that conduct due diligence in line with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, or that operate under recognised certification schemes.

FXBITS employs appropriate physical, technical, and organisational measures to ensure the confidentiality, integrity, availability, authenticity, and non-repudiation of information processed in connection with its business and that of its customers. These measures are kept adequate to the state of the art and reviewed periodically. Detailed controls are set out in the FXBITS Information Security Policy and supporting procedures.

FXBITS processes personal data in compliance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) and Romanian data protection law (Law 190/2018). FXBITS maintains a record of processing activities, signs data processing agreements with processors and customers, trains its workforce on data protection, and operates procedures for data subject requests and personal data breaches. Security incidents and personal data breaches occurring in the context of a customer relationship are reported to the affected customer without undue delay and within the timeframes required by applicable law and contract.

Internal ethics and compliance

FXBITS operates an internal management system commensurate with the size and nature of its business to ensure, in a verifiable manner, that applicable laws and regulations and the standards of this Code are followed. The system includes assigned responsibilities (notably an Information Security Officer and a person responsible for data protection), documented policies, periodic reviews, and ethics training for employees. FXBITS promotes a culture in which employees are encouraged to make ethical, value-driven choices in their work.

Reporting channels and whistleblower protection

FXBITS provides workers and third parties with access to reporting channels through which they can raise situations or behaviours that may breach applicable laws and regulations or the principles of this Code, without fear of retaliation. Reports may be made to the employee's direct manager, to FXBITS management at office@fxbits.io, or through the internal reporting channel established by FXBITS in accordance with Romanian Law 361/2022 (transposition of EU Directive 2019/1937 on whistleblower protection). FXBITS investigates reports in good faith, maintains confidentiality to the extent legally possible, and prohibits any form of retaliation against persons making reports in good faith.

FXBITS expects its suppliers, service providers, and subcontractors to operate to standards equivalent to those set out in this Code. FXBITS communicates this Code to relevant suppliers and may reference it in supplier contracts. FXBITS applies due diligence in supplier selection, including assessment of information security, data protection, labour standards, and ethical conduct, in proportion to the nature and risk of the engagement. FXBITS may request evidence of compliance and reserves the right to terminate engagements where serious or unremediated violations are identified.

This Code is approved by the management of Flexibit Services S.R.L. and is reviewed at least annually, or earlier if material changes in business, legislation, or operations require it. Updated versions are communicated to all employees and made available to business partners on the FXBITS website. All employees, contractors, and representatives of FXBITS are required to read, understand, and acknowledge this Code. Failure to comply may result in disciplinary action up to and including termination of the employment or business relationship, and, where applicable, civil or criminal proceedings.

Approved by Tofan Paul, Administrator — 14.08.2025.