Compliance Framework

This compliance framework defines the principles, structures, processes and responsibilities for ensuring the legal compliance, integrity and transparency of SCANDIC FINANCE GROUP LIMITED and all brands and structural companies mentioned in Section 0.

The purpose of this compliance framework is, in particular:

• to comply with all applicable laws, regulations and official requirements in all relevant jurisdictions,
• to implement internationally recognised standards of good corporate governance,
• to respect and promote human rights, environmental and social standards throughout all value and supply chains,
• to prevent corruption, bribery, money laundering, terrorist financing and sanctions violations,
• the protection of personal data, trade secrets and other confidential information,
• the implementation of an effective system for whistleblowers,
• establishing clear escalation and sanction mechanisms for compliance violations.

The compliance framework is based in particular on:

• the United Nations Guiding Principles on Business and Human Rights,
• the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises,
• European regulations, in particular the Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation) and the due diligence requirements for corporate supply chains,
• the Supply Chain Due Diligence Act of the Federal Republic of Germany,
• the law of the Hong Kong Special Administrative Region of the People's Republic of China (including company law and financial market law standards),
• the relevant legal provisions of the United Arab Emirates,
• the law of Ukraine,
• the law of the United Kingdom of Great Britain and Northern Ireland,
• the law of the Swiss Confederation,
• all other applicable legal systems, but with express jurisdiction in Hong Kong / SAR-PRC.

This compliance framework is a group-wide guideline and an integral part of the company's organisation. It is binding for all bodies, managers, employees, consultants and relevant external partners, insofar as this is permissible under labour and company law.

The scope of application covers:

• SCANDIC FINANCE GROUP LIMITED by Scandic Banking Hong Kong,
• all brands and services of the SCANDIC FINANCE brand ecosystem,
• the cooperating companies SCANDIC ASSETS Free Zone Company, SCANDIC TRUST GROUP Limited Liability Company and LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung,
• all subsidiaries, holdings, joint ventures, representative offices and branches, but with express jurisdiction in Hong Kong / SAR-PRC.

The compliance framework is aimed at:

• Members of the administrative and management bodies,
• Managing directors, directors,
• all employees,
• freelancers, agents, representatives,
• external service providers, intermediaries, sales partners.

The ultimate responsibility for compliance lies with the management or administrative body of SCANDIC FINANCE GROUP LIMITED, with express jurisdiction in Hong Kong / SAR-PRC.

SCANDIC ASSETS Free Zone Company, LEGIER Beteiligungs Gesellschaft mit beschränkter Haftung and SCANDIC TRUST GROUP Limited Liability Company act as non-operational service providers; all legal and administrative responsibility lies with SCANDIC FINANCE GROUP LIMITED.

A multi-level compliance organisation has been established at SCANDIC FINANCE GROUP LIMITED:

• Group-wide compliance function (Group Compliance),
• Local compliance officers,
• External compliance officer.

Managers bear special responsibility; all employees are obliged to be familiar with and comply with the framework.