Compliance & Code of
Conduct Policy

Last Updated: January 2025

Introduction

4Square Capital is committed to conducting business with the highest standards of ethics, integrity, and compliance with all applicable laws and regulations. This Code of Conduct outlines our core principles and expectations for all employees, contractors, partners, and representatives of 4Square Capital globally.

Core Values

At 4Square Capital, our values are not just words on paper – they are the fundamental principles that guide our actions and shape our culture. Through our ASPIRE values framework, we have created a foundation that ensures ethical business conduct, fosters trust with our stakeholders, and drives sustainable growth. These values represent our commitments to excellence, integrity, and responsible business practices in everything we do.

Acumen

Our actions are driven by extensive research & insight. We are subject matter experts & and lead our investors with this acumen. We commit to: - Maintaining highest professional standards - Continuous learning and development - Data-driven decision making - Sharing knowledge and expertise

Sincerity

We are sincere to our core value system & our purpose - deliver better financial outcomes for our investors, employees, partners & customers. This means: - Transparent communication - Honest business practices - Commitment to stakeholder success - Building trust through consistent actions

Persistence

We are determined to succeed in our vision and persist for excellence in our actions. At the heart of our success lies unwavering persistence. We demonstrate this through: - Resilience in facing challenges - Consistent pursuit of excellence - Long-term commitment to goals - Continuous improvement

Integrity

Our Integrity manifests itself in sincere everyday actions and decisions that reflect our steadfast dedication to doing what is right. This includes: - Ethical business conduct - Following through on commitments - Taking responsibility for our actions - Maintaining highest ethical standards

Results

We are focused on specific outcomes & measurable goals. We celebrate achievements, learn everyday and strive to exceed expectations by: - Setting clear objectives - Measuring progress - Delivering tangible value - Learning from experience

Empathy

Be it in acts of kindness or bigger decisions, we cultivate empathy & understand each other - A foundation to strong & compassionate business. We show this through: - Understanding stakeholder needs - Respectful interactions - Inclusive practices - Supportive business relationships

Business Ethics & Compliance

In today’s complex global business environment, maintaining the highest standards of ethical conduct is crucial for sustainable success. At 4Square Capital, we are committed to operating with unwavering integrity and in full compliance with all applicable laws and regulations. Our comprehensive approach to business ethics and compliance ensures that we maintain the trust of our clients, partners, and stakeholders while protecting our reputation and assets. We have established robust frameworks and procedures that guide our conduct across all aspects of our operations.

Anti-Corruption and Anti-Bribery

• Zero tolerance for bribery and corruption in any form
• Prohibition of facilitation payments
• Due diligence requirements for third-party relationships
• Mandatory reporting of suspicious activities
• Regular training and awareness programs

Data Protection & Privacy

• Strict adherence to GDPR and other applicable data protection regulations
• Implementation of robust data security measures
• Regular privacy impact assessments
• Clear procedures for data handling and protection
• Mandatory reporting of data breaches

Information Security

• Comprehensive information security management system
• Regular security audits and assessments
• Secure data handling and storage procedures
• Incident response protocols
• Employee training on cybersecurity best practices

Financial Integrity

• Accurate and transparent financial reporting
• Strong internal controls
• Regular audits
• Compliance with international accounting standards
• Prevention of money laundering and financial fraud

Workplace Conduct

Creating a safe, respectful, and inclusive workplace is fundamental to our success. At 4Square Capital, we foster an environment where every individual can thrive, contribute, and grow professionally. Our workplace conduct policies reflect our commitment to maintaining the highest standards of professional behavior, ensuring equal opportunities, and promoting a culture of mutual respect and dignity. We believe that a positive workplace environment is essential for innovation, collaboration, and sustainable business growth.

Equal Opportunity & Non-Discrimination

• Zero tolerance for discrimination
• Commitment to diversity and inclusion
• Fair hiring and promotion practices
• Equal access to opportunities
• Regular diversity training

Harassment Prevention

• Zero tolerance for harassment of any kind
• Clear reporting procedures
• Protection against retaliation
• Regular training and awareness programs
• Swift investigation of complaints

Health & Safety

• Commitment to workplace safety
• Regular safety assessments
• Emergency response procedures
• Health and safety training
• Incident reporting and investigation

Environmental Responsibility

• Commitment to environmental sustainability
• Waste reduction and recycling programs
• Energy efficiency initiatives
• Environmental impact assessments
• Regular environmental compliance audits

Business Practices

Our approach to business practices is built on principles of fairness, transparency, and responsibility. At 4Square Capital, we understand that sustainable success comes from maintaining the highest standards in all our business interactions. We have established comprehensive guidelines that ensure fair competition, protect intellectual property, maintain strong relationships with suppliers, and manage conflicts of interest effectively. These practices not only ensure compliance with legal requirements but also build lasting trust with our stakeholders.

Fair Competition

• Compliance with antitrust laws
• Fair dealing with competitors
• Prohibition of anti-competitive practices
• Clear guidelines for market conduct
• Regular competition law training

Intellectual Property Protection

• Respect for IP rights
• Confidentiality agreements
• Clear IP ownership guidelines
• Protection of trade secrets
• Regular IP audits

Supplier Code of Conduct

• Ethical sourcing requirements
• Human rights compliance
• Environmental standards
• Quality assurance requirements
• Regular supplier audits

Conflict of Interest

• Clear disclosure requirements
• Regular conflict checks
• Management of potential conflicts
• Documentation procedures
• Annual declarations

Implementation & Enforcement

Reporting Mechanisms

• Confidential whistleblower hotline
• Multiple reporting channels
• Protection for good faith reporting
• Non-retaliation policy
• Clear investigation procedures

Training & Communication

• Regular compliance training
• Code of conduct certification
• Ongoing communication programs
• Access to compliance resources
• Regular policy updates

Monitoring & Auditing

• Regular compliance assessments
• Internal audits
• External verification
• Performance metrics
• Continuous improvement

Disciplinary Actions

• Clear consequences for violations
• Fair and consistent enforcement
• Appeal procedures
• Documentation requirements
• Regular policy review

Certification

All employees, contractors, and business partners must certify their understanding and compliance with this Code of Conduct annually. Violations may result in disciplinary action up to and including termination of employment or business relationship.

Contact Information

For questions or concerns regarding this Code of Conduct, please contact:

Compliance Department
4Square Capital
Srikanth.Gaurav@4sqcapital.com

This Code of Conduct is reviewed and updated annually to ensure continued effectiveness and alignment with global best practices.