Code of Conduct & Anti-Corruption Policy

Effective date: September 2026 — Version 1.0

1. Purpose and Scope

This policy sets out the binding standards of business ethics and anti-corruption compliance for Lucky Office GmbH and its affiliated companies (together, the “Company”). It applies to all managing directors, employees, and any third parties acting on the Company’s behalf, including agents, consultants, and intermediaries, in all business dealings worldwide.

2. Legal Framework

The Company conducts its business in full compliance with all applicable anti-corruption and anti-bribery laws, including the German Criminal Code (Strafgesetzbuch, in particular §§ 299 and 331–335 StGB), the U.S. Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act 2010, as well as all other laws applicable to our business relationships and partner programs.

3. Prohibition of Bribery and Corruption

The Company prohibits bribery and corruption in any form. No director, employee, or third party acting on our behalf may offer, promise, give, request, or accept — directly or indirectly — any bribe, kickback, or other improper payment or advantage in order to obtain or retain business, influence a business decision, or secure any improper advantage. This prohibition applies equally to dealings with private businesses and with public officials.

Facilitation payments (small payments to expedite routine governmental actions) are prohibited, even where local practice may tolerate them.

4. Gifts, Hospitality, and Entertainment

Gifts and hospitality may only be offered or accepted if they are of modest value, occasional, transparent, appropriate to the business occasion, and permitted under applicable law and the recipient’s own rules. They must never be offered or accepted with the intent — or the appearance of intent — to improperly influence a business decision.

Cash and cash equivalents (such as vouchers or gift cards) are never permissible as gifts. Gifts or hospitality exceeding a customary modest value (guideline: EUR 50 per person and occasion) require prior approval by the management. All gifts and hospitality must be accurately recorded in the Company’s books and records.

5. Dealings with Government Officials

Particular caution applies to any interaction with public and government officials, including employees of public authorities, state-owned enterprises, and public institutions. Nothing of value may be offered or provided to a government official to influence an official act or decision. Any gift or hospitality involving a government official — regardless of value — requires prior approval by the management.

6. Commissions, Agents, and Intermediaries

The Company engages agents, consultants, and other intermediaries only on the basis of written agreements, for legitimate services, and against compensation that is proportionate to the services actually rendered. Before engaging an intermediary, appropriate due diligence is performed. Commissions and fees must never be used as a vehicle to channel improper payments to any third party or official. Payments are made only to the contracting party, against proper invoices, and never in cash or to accounts in third countries unrelated to the business.

7. Accurate Books and Records

All business transactions must be recorded accurately, completely, and in a timely manner in accordance with applicable accounting standards. No undisclosed or unrecorded accounts, funds, or assets may be established or maintained for any purpose.

8. Conflicts of Interest and Fair Competition

Employees must avoid situations in which personal interests conflict, or appear to conflict, with the interests of the Company, and must disclose any potential conflict to the management. The Company is committed to fair competition and complies with applicable competition and antitrust laws.

9. Raising Concerns and Non-Retaliation

Anyone who becomes aware of a suspected violation of this policy is expected to report it to the management or to the compliance contact below. Reports may be made confidentially. The Company does not tolerate retaliation of any kind against anyone who reports a concern in good faith.

10. Consequences of Violations

Violations of this policy may result in disciplinary measures up to and including termination of employment or business relationships, and may be reported to the competent authorities where required by law.

11. Responsibility and Contact

The management of Lucky Office GmbH is responsible for this policy, reviews it regularly, and ensures that employees are informed of its contents.

Compliance contact: info@lucky-office.de