Code of Ethics – Glovont

Preamble

Glovont SA and its subsidiaries are committed to supporting and investing in sustainable and innovative projects. This Code of Ethics sets out the principles and standards of conduct that all Glovont employees, executives, and appointed partners adhere to.
Its purpose is to ensure integrity, impartiality, and excellence in our relationships with clients, partners, investors, and all stakeholders.

1. General Principles

• Integrity: Act honestly, fairly, and transparently in all circumstances.

• Impartiality: Avoid favoritism and treat every client and project objectively and equitably.

• Accountability: Take full responsibility for decisions and advice provided.

• Professionalism: Deliver high-quality services and comply with best industry practices.

2. Protecting Clients’ Interests

• Glovont is committed to serving clients’ interests first within the scope of assigned mandates, ensuring confidentiality, neutrality, and efficiency.

• All conflicts of interest must be identified, disclosed, and, wherever possible, avoided.

• Recommendations and decisions must be based on objective, well-documented analysis, free from internal or external pressure.

3. Confidentiality and Data Protection

• Strict protection of business secrets and any information entrusted by clients, partners, or investors.

• Compliance with Swiss and international data protection laws (including GDPR).

• Prohibition of disclosing or personally using information obtained in the course of professional duties.

4. Conflicts of Interest

• All staff and partners must inform management of any potential or actual conflict of interest.

• They may not participate in decisions or projects where they have a direct or indirect personal interest that could impair objectivity.

5. Transparency and Communication

• Provide clear and complete information to clients regarding the nature of services, fee arrangements, and risks associated with proposed operations.

• No promises of results may be made if they cannot be guaranteed.

• Commit to courteous, accurate, and timely communication.

6. Competence and Continuous Development

• Maintain and develop professional skills through ongoing training and industry monitoring.

• Decline mandates exceeding available expertise or resources without involving qualified external experts.

7. Business Ethics and Anti-Corruption

• Zero tolerance for any form of corruption, bribery, or unlawful practices.

• Gifts and benefits received must remain symbolic and be declared in accordance with internal procedures.

• Strict compliance with competition rules; anti-competitive practices are prohibited.

8. Compliance with Laws and Standards

• Adherence to applicable national and international laws (labor law, taxation, financial markets, environmental regulations, etc.).

• Rigorous application of internal compliance and governance standards.

9. Sustainability and Social Responsibility

• Integration of environmental, social, and governance (ESG) criteria into investment and advisory decisions.

• Promotion of responsible and sustainable initiatives with clients and partners.

• Commitment to minimizing the environmental impact of internal operations (energy, mobility, waste).

10. Relations with Suppliers and Partners

• Selection and management of suppliers based on objective criteria (quality, price, reliability, ethics).

• Encourage responsible and transparent practices among partners.

• Prohibition of undue advantages or favoritism.

11. Respect and Non-Discrimination

• Foster an inclusive, respectful workplace free from discrimination (origin, gender, orientation, religion, disability, etc.).

• Prohibit all forms of harassment, including moral and sexual harassment.

• Ensure the health and safety of all employees.

12. Individual Responsibilities

• Every employee, executive, and partner is personally responsible for complying with this Code.

• Obligation to report any actual or suspected breach to designated internal bodies.

• Protection against retaliation for those who report breaches in good faith.

13. Implementation and Oversight

• This Code is distributed to all employees and partners.

• Glovont’s Management oversees its implementation and establishes monitoring procedures.

• Disciplinary measures may be taken in the event of violations.

14. Entry into Force and Updates

• This Code takes effect on the date of its adoption by Glovont SA’s Management.

• It may be revised periodically to adapt to legal, economic, and ethical developments.

Commitment

All Glovont employees, executives, and partners undertake to respect and promote the principles and rules defined in this Code of Ethics.