Findev, Inc Code of Conduct

Introduction

FinDev, Inc. (“FinDev” or “We”) is committed to the highest standards of ethical conduct, corporate responsibility and regulatory compliance. This Code of Conduct defines the principles and expectations that guide our own business operations and extends to all individuals and organizations acting on behalf of FinDev or engaged by FinDev and/or its affiliates and subsidiaries. This includes employees, directors, contractors, vendors, suppliers and consultants (collectively, “Employees and Suppliers”).

Suppliers must adopt and enforce standards at least equivalent to those described in this Code. This document applies globally and is reviewed periodically to ensure it remains aligned with evolving laws, stakeholder expectations, and sustainability goals.

01. Legal and Regulatory Compliance

All parties must operate in full compliance with:

• Local, national, and international laws in every jurisdiction where they conduct business.
• Applicable financial regulations, including those governing fintech, cybersecurity, and data privacy.
• Anti-corruption, anti-money laundering (AML) and antitrust laws.
• Industry-specific compliance requirements and professional standards.

02. Ethical Business Practices

FinDev demands integrity, transparency, and fairness in every business transaction. All stakeholders must:

• Prevent and report fraud, embezzlement, misstatements, or deceptive conduct.
• Disclose and avoid conflicts of interest – whether actual or perceived.
• Never offer, request, or accept bribes, kickbacks, or improper gifts.
• Refrain from manipulation, concealment, or abuse of confidential or privileged information.

03. Workplace Behavior and Human Rights

We promote a safe, secure and healthy workplace. FinDev prohibits:

• Discrimination or harassment based on race, color, religion, gender identity, sexual orientation, disability, or any protected characteristic.
• Any form of forced or child labor.
• Payment of wages below the applicable legal minimum. All workers must receive compensation –whether hourly, salaried, or through other lawful arrangements – that meets or exceeds the minimum wage requirements of the jurisdiction in which they work. This includes full compliance with local laws governing overtime, benefits, and other legally mandated compensation.
• Retaliation against those who report misconduct in good faith.

04. Diversity and Inclusion

We foster diversity of thought, background, and culture. FinDev values an inclusive environment where everyone can thrive and innovate.

05. Data Privacy and Security

Data protection is fundamental to FinDev’s operations. All parties must:

• Safeguard confidential, personal, and proprietary information with appropriate technical and organizational controls.
• Comply with data privacy laws such as GDPR, CCPA, and others applicable to their jurisdiction.
• Report any data breaches immediately to FinDev.
• Respect intellectual property rights and avoid unauthorized use of FinDev’s trademarks, inventions, code, or trade secrets.

06. Financial Integrity and Anti-Corruption

We expect absolute honesty in all financial dealings. Employees and Suppliers must:

• Prevent fraud, embezzlement, and financial misstatements.
• Comply with anti-bribery, anti-money laundering, and anti-corruption laws.
• Never offer or accept improper payments or gifts.

07. Insider Trading

FinDev prohibits all forms of insider trading and tipping involving any securities. All parties with access to material, non-public information (MNPI) are prohibited from misusing it.

Definition of MNPI:

Material, non-public information is information not generally available to the public that a reasonable investor would likely consider important when making an investment decision. Examples may include:

• Unannounced financial results or projections.
• Mergers, acquisitions, or divestitures.
• Changes in executive leadership.
• Product launches or failures.
• Regulatory actions or investigations.

Prohibited Activities:

• Trading on MNPI: Buying or selling securities of any company (including clients, partners, or competitors) while in possession of MNPI.
• Tipping: Sharing MNPI with others who may use it to trade securities.
• Improper Disclosure: Discussing MNPI with anyone not authorized to receive it, including friends or family.

Compliance Expectations:

• Maintain Confidentiality: MNPI must only be shared internally on a strict need-to-know basis.
• Avoid Improper Trading: Individuals must not trade securities when in possession of MNPI, even if trading through personal accounts or accounts of family members.
• Report Concerns: Any suspected insider trading or tipping must be reported immediately to FinDev.

Violations of insider trading laws may lead to severe civil and criminal penalties. FinDev enforces a zero-tolerance policy and will take corrective or disciplinary action against violators, up to and including termination of employment or engagement.

08. Conflicts of Interest

At FinDev, we are committed to maintaining the highest standards of integrity and ethical conduct. All Employees and Suppliers are expected to make business decisions that are in the best interest of FinDev and its stakeholders, free from personal or external influences.

Definition of a Conflict of Interest:

A conflict of interest arises when personal interests interfere, or appear to interfere, with the interests of FinDev. This includes situations where an individual's personal, financial, or other interests could compromise their judgment, decisions, or actions in the workplace.

Examples of Potential Conflicts:

• Engaging in activities that compete with FinDev's business interests.
• Having a financial interest in a supplier, customer, or competitor of FinDev.
• Accepting gifts, favors, or entertainment that could influence business decisions.
• Using FinDev's confidential information for personal gain.

Disclosure and Management:

All potential or actual conflicts of interest must be promptly disclosed to FinDev. FinDev will assess the situation and determine the appropriate course of action, which may include recusal from certain decisions, reassignment of duties, or other measures to mitigate the conflict.

Obligation to Act:

Failure to disclose a conflict of interest may result in disciplinary action, up to and including termination of employment or engagement. Maintaining transparency and integrity in all business dealings is essential to uphold FinDev's reputation and trust with stakeholders.

09. Intellectual Property and Innovation

FinDev values proprietary tools and technology. Employees and Suppliers must:

• Respect intellectual property rights.
• Protect the owner’s intellectual property rights, covering inventions, software, trademarks, and confidential trade secrets.
• Avoid unauthorized use or sharing of proprietary materials.

10. Environmental Responsibility

We encourage eco-conscious operations that:

• Reduce waste and energy consumption.
• Support sustainable business practices and responsible sourcing.
• Consider the environmental impact of products, services, and vendor selection.

11. Community Engagement and Ethics

FinDev believes in giving back. We support:

• Ethical partnerships that benefit communities.
• Responsible AI and technology use that respects human rights and enhances global well-being.

12. Use of FinDev Name and Brand

FinDev name, logo, visual assets and other intellectual property must never imply endorsement without prior written consent.

13. Monitoring, Certification, and Enforcement

FinDev reserves the right to audit Suppliers to ensure compliance with this Code. Suppliers may be required to:

• Complete compliance certifications upon request.
• Cooperate fully in investigations of alleged violations.
• Remedy violations through corrective action plans or, if necessary, termination of engagement.

FinDev reserves the right to terminate employment or engagement if this Code is violated, or if there is a reasonable belief that a violation may occur. This applies regardless of whether the breach has resulted in actual harm and includes failure to cooperate with investigations or efforts to conceal misconduct.

14. Reporting Violations

Any individual may report concerns confidentially or anonymously via:

• Email: ethics@fin.dev
• Mailing Address: FinDev, Inc., 900 North Federal Highway, Ste 306, Hallandale Beach, FL 33009.

No retaliation will be tolerated against anyone who reports in good faith.

15. Governance and Updates

This Code might be reviewed by FinDev’s in its own discretion. Updates will be communicated promptly. All parties must comply with the Code in force at the time of cooperation.