Business Ethics Guidelines | ScandicData

Executive Summary

Commitment: Highest standards of ethical, lawful, and responsible conduct across the SCANDIC ecosystem.
Core Values: Integrity, transparency, respect, sustainability, and accountability.
Key Regulations: Compliance with AML/KYC, GDPR, financial market rules, and anti-corruption laws.
Goals: 40% female leadership by 2030, 100% annual ethics training coverage.
Whistleblowing: Anonymous reporting channels with full protection against retaliation.

Applicable to the BRAND ECO system:

- SCANDIC SEC

- SCANDIC FLY

- SCANDIC PAY

- SCANDIC COIN

- SCANDIC CARS

- SCANDIC DATA

- SCANDIC SETUP

- SCANDIC TRUST

- SCANDIC CARDS

- SCANDIC ESTATE

- SCANDIC YACHTS

- SCANDIC HEALTH

- SCANDIC FINANCE

Foreword:

SCANDIC FINANCE GROUP LIMITED is committed to the highest standards of ethical, lawful and responsible conduct. This policy defines the core values, decision-making criteria and behavioural requirements that apply to all employees, managers, agents, affiliated companies, external partners and all persons acting on behalf of SCANDIC Finance.

Objective:

Our goal is to create a corporate culture characterised by integrity, transparency, respect, sustainability and responsibility. This policy supplements the Group-wide Code of Conduct, the Human Rights and Security Policies, and all regulatory requirements of the Financial and Banking Supervisory Authority in Hong Kong (SAR-PRC) and all other relevant jurisdictions.

The aforementioned ECO system brands are represented by:

SCANDIC FINANCE GROUP LIMITED

by Scandic Banking Hong Kong

Room 10, Unit A, 7/F, Harbour Sky, 28 Sze Shan Street

Yau Tong, Hong Kong/ SAR / PRC

Phone: Swiss HQ, Zurich: +41 44 7979 99 – 85

Email: Office@ScandicFinance.Global

Commercial register: Link

In cooperation with:

SCANDIC ASSETS FZCO

Dubai Silicon Oasis DDP Building A1/A2

Dubai, 342001 / United Arab Emirates

Telephone: +971 56 929 86 – 90

Email: Info@ScandicAssets.dev

Commercial register: Verify Link

in cooperation with:

SCANDIC TRUST GROUP LLC

IQ Business Centre Bolsunovska Street 13-15

Kyiv — 01014 / Ukraine

Telephone HQ – United Kingdom of Great Britain and Northern Ireland, London: +44 7470 86 92 – 60

Email: Info@ScandicTrust.com

Commercial register: View PDF

in cooperation with:

LEGIER BETEILIGUNGS GMBH

Kurfürstendamm 14

10719 Berlin / Federal Republic of Germany

Berlin Commercial Register: HRB 57837

Telephone: +49 (0) 30 9921134 – 69

Email: Office@LegierGroup.com

Commercial register: Handelsregister.de

Legal notice: SCANDIC ASSETS FZCO, LEGIER Beteiligungs GmbH and SCANDIC TRUST GROUP LLC act as non-operational service providers. All operational and responsible activities are carried out by SCANDIC FINANCE GROUP LIMITED, Hong Kong, Special Administrative Region of the People's Republic of China.

1.1 Legal compliance and regulatory obligations
SCANDIC FINANCE GROUP LIMITED is committed to strict compliance with all applicable laws, financial market regulations, compliance requirements (including AML/KYC), industry standards and internal guidelines. Every manager and employee is personally responsible for knowing, understanding and complying with these regulations.
In particular, this includes:

Consumer protection and competition law
Data protection laws (DSG, GDPR, PDPO Hong Kong)
Financial market rules and banking regulations
Tax laws, reporting and disclosure requirements
Sanctions, embargoes and international trade restrictions
Money laundering regulations and terrorist financing guidelines

1.2 Integrity, honesty and transparency:
We always act openly, honestly and transparently. Any form of deception, misrepresentation, unfair conduct or deliberate manipulation is strictly prohibited. Decisions must always be documented in a transparent manner.

1.3 Responsibility and accountability:
Employees are responsible for their actions, their decisions and their impact on customers, business partners, society and the environment. Mistakes must be communicated openly; cover-ups are prohibited.

1.4 Fairness, respect and equal treatment:
We promote a working environment free from discrimination, harassment, bullying or intimidation. Regardless of origin, language, gender, orientation, disability, religion or opinion, dignity and respect are inviolable at SCANDIC FINANCE GROUP LIMITED.

1.5 Combating corruption
Corruption is not tolerated in any form.
This includes within the Group:

Bribery and granting of advantages
Extortion, bribery or kickbacks
Acceptance of inappropriate gifts or invitations

Non-transparent commission payments:
Gifts may only be accepted if they are of low value, documented and appropriate.

1.6 Dealing with conflicts of interest:
Conflicts of interest must be identified, disclosed and avoided at an early stage.
This applies in particular to:

Secondary employment
family ties
Personal business relationships
own financial interests in customer relationships

1.7 Whistleblower protection
All employees have the opportunity at any time to report anonymously and without reprisals:

Violations of laws
Human rights violations
Violations of compliance rules
Corruption, fraud, manipulation
Risks to customers or the company

Reports can be made to:

Management
Compliance department
Data protection officers
External whistleblower system (if activated)
Retaliation against whistleblowers is strictly prohibited.

2.1 Equality and diversity
Objective: SCANDIC Finance is committed to a balanced and diverse management team.
Target: By 2030, at least 40% of relevant management positions should be held by women.
Responsibility: Human Resources (HR) in consultation with senior management.
Monitoring: Annual reporting and progress analysis.

2.2 Ethics and compliance training
Objective: All employees must participate in mandatory ethics, compliance and AML/KYC training courses each year. Target rate: 100% training coverage per calendar year.
- AML policy: Link
- KYC policy: Link
Responsibility:

HR
Monitoring
Compliance department
Management systems management
Annual internal evaluation
Documentation in the training system
Report to management

2.3 Data protection & information security:
SCANDIC Finance respects the privacy of customers, employees and partners.
Key areas:

Protection of all personal data
Secure data processing in accordance with GDPR, PDPO & DSG
Minimisation of data access ("need-to-know principle")
Use of modern encryption and security standards
Prohibition of unauthorised data transfer

2.4 Sustainability & social responsibility:
As an internationally active financial company, SCANDIC FINANCE GROUP LIMITED bears responsibility for the environment and society.
Commitments:

Resource-efficient operations
Reduction of our ecological footprint
Promotion of sustainable business models
Social responsibility towards customers, employees and the public

2.5 Dealing with customers and business partners
The relationship with customers is based on:

Security
Transparency
Reliability
Professionalism
Deceptive, aggressive or misleading sales methods are prohibited
Business partners must comply with minimum standards in compliance, ethics and human rights.

2.6 Financial market integrity & risk management
As a financial and banking service provider, SCANDIC FINANCE GROUP LIMITED is committed to:

Accurate, complete and timely reporting
Transparent risk management
responsible financial and investment decisions
strict protection of client funds
compliance with all anti-money laundering and counter-terrorism financing requirements

3.1 Responsibilities
The following are responsible for implementing this policy:

HR
Management
Management Systems Department
Compliance & Risk Management

3.2 Sanctions for violations
Violations of this policy may result in the following consequences, depending on their severity and the legal situation:

Termination
Internal measures
Labour law sanctions
Civil law proceedings
Criminal reports to authorities

3.3 Annual review
This policy is updated once a year and sent to:

new regulatory requirements
social developments
internal requirements.

Drafted, signed and approved:

The Board of Directors of SCANDIC FINANCE GROUP LIMITED

Hong Kong, SAR - PRC, 1 January 2026

Legal representation: Clifford Chance, Global Law Firm

Business Ethics Guidelines of SCANDIC FINANCE GROUP LIMITED

Executive Summary

Foreword:

Objective:

Suppliers & Partners