Veego Code of Ethics and Professional Conduct

Adopted by the Board of Directors on April 16, 2023

1. Introduction

Veego provides elements of artificial intelligence, pattern analysis, and more to deliver the breakthroughs that are changing the face of ISP
subscriber engagement and care. Veego obeys the highest standards of ethical behavior and regulatory compliance when they sell, distributes, or markets its products and services. All Veego’s employees are required to comply with the values, regulations, policies, and laws.

2. Core Values

Veego’s standards and values reflect Veego’s continued commitment to ethical business practices and legal compliance. This code is
designed to ensure:

  • We operate our business ethically and with integrity;
  • We avoid actual or apparent conflicts of interest;
  • We comply with all applicable laws, including full, fair, accurate, timely, and understandable disclosure in the reports and documents that
  • we file with regulatory agencies and in our other public communication; and
  • The prompt internal reporting of suspected violations of this code.

To whom does this code apply? This code applies to the directors, executives, employees, and independent contractors of Veego. In addition to our own compliance, we ensure that those we manage and those we hire to work on our behalf comply with this code.

3. Integrity & Honesty

3.1. General principle. Veego’s business operations must be conducted with honesty and integrity, and organizations with which Veego has business ties, including suppliers, customers, competitors, and their employees, must be dealt with fairly and their rights respected.
3.2. Acting fairly, honestly, sincerely, and with precision, clarity, and integrity. Companies and their collaborators must make decisions and take actions that are reasonable, professional, and responsible, while maintaining fairness, integrity, honesty, and sincerity. All activities must be carried out accurately and clearly.
3.3. Non-Exploitation of Internal Information: Collaborators must avoid exploiting or relying on internal information that is not in the public domain. Furthermore, the use or transfer of non-public information for personal gain is prohibited. “Internal Information” includes information concerning financial results, tenders, work plans, various agreements, administrative and strategic decisions, information about the company’s development, changes in the company’s situation, or expected developments or changes to the company or its situation, or other information about the company that is not publicly known. Collaborators with access to Internal Information must refrain from revealing, using, or sharing such information with any third party for any purpose unless the use of such information is authorized by their superiors and within the framework of the Company’s business activities.
3.4. Proper use and protection of the Companies’ assets. Collaborators must use technological resources and their property only for the needs of the Company and its goals. Any use of the company’s assets for personal profit or personal benefit is prohibited. Collaborators must assist the company in protecting its assets from abuse, theft, damage, or loss
3.5. Communication. When communicating, appropriate discretion is to be exercised in writing e-mails, memorandums, notes, and any other
formal and informal communication related to the company’s business. Communications related to Company’s business must not include
inappropriate or slanderous remarks concerning other people or other companies, the use of unprofessional language, and unapproved comments regarding financial, business, or legal matters.
3.6. Data storage and conservation. The correct data storage and conservation of documents involving our professional activity and the administration and management of the company are essential and must be carried out according to the applicable laws.

4. Openness & Respectfulness

Veego never acts in a manner that could be perceived as threatening, intolerant, or discriminatory. Respect for dignity recognizes the
inherent worth of all human beings, regardless of perceived or real differences in social status, ethnic origin, gender, capacities, or any other such group-based characteristics. This inherent worth means that all human beings are worthy of equal moral consideration.

5. Accountability

Accountability is about taking responsibility for the commitments you make. Veego builds trust over time with the customers. Veego’s employees must accept appropriate responsibility for what is within their power, control, or management. Awareness of responsibility ensures that the trust of others is not abused, the power of influence is properly managed, and the duty towards others is always paramount.

6. Self-critical

Veego’s employees devote their energies to developing and improving their scholarly competence. They accept the obligation to exercise critical self-discipline and judgment in using, extending, and transmitting knowledge. Each employee consistently asks themselves and their co-workers how to be a better version of themselves.

7. Conflict of Interests

A conflict of interest may exist where the interests or benefits of one person or entity conflict or appear to conflict with the interests or benefits of Veego. Your decisions and actions related to Veego should be based on the best interests of Veego and not based on personal relationships or benefits, either for yourself or for others. Veego personnel must never use or attempt to use their position with Veego to obtain improper personal benefits. Evaluating whether a conflict of interest exists can be difficult and may involve several considerations. We encourage you to seek guidance from your manager and the human resources department when you have any questions or doubts. If you are aware of an actual or potential conflict of interest, or are concerned that a conflict might develop, please discuss it with your manager and then obtain approval from our chief executive officer before engaging in that activity or accepting something of value.

8. Loyalty to Veego and the Collaborators

8.1. Confidentiality and Discretion. All operations must be kept strictly confidential and secret. Veego’s secrets and information related to its operations must be protected and kept confidential.
8.2. Maintaining Veego’s reputation. Collaborators represent Veego in everything they do, and therefore have a duty to ensure that their conduct is respectful of Veego and preserves its good name and reputation.
8.3. Collaborators’ privacy. Any information held by the Companies relating to the Collaborators is confidential and personal and must be kept as such. Access to such information may be given only in exceptional cases, such as when required by law or a legal order.
8.4. Teamwork. Veego’s strength lies in the ability of its collaborators to work as a team through cooperation, synergy, tolerance, patience, and attentiveness, with the aim of achieving common goals. Fruitful cooperation, with precision and a clear intention, planning, implementation, and execution, will ensure success for Veego’s activities at various levels.

9. Complying with laws, Regulations & Policies

9.1. Intellectual Property. At Veego, we regularly create valuable business ideas, strategies, and other business information that are company property and must be protected. Such information is generated as a result of Veego’s activities and it is part of Veego’s intellectual capital, which may be protected by law in specific cases. Intellectual property created or purchased using Veego resources becomes Veego property and cannot be considered private/personal property.
9.2. Fair Competition. Veego complies with the laws and regulations designed to promote healthy competition. Antitrust laws and fair competition laws generally prohibit activities that restrain trade and restrict competition. While Veego competes in many of our business activities, it is conducted in accordance with the norms of fair competition and in conformity with applicable competition laws. Full compliance with competition law is not only a legal obligation but is related to attitudes and cultures that can have a positive impact on business.
9.3. Anti-Corruption and Anti-Fraud. Veego does not engage in, and does not tolerate corruption in any form (including bribery, facilitation payment, kickback, extortion, misuse of authority for personal gain, undue benefits, or gifts with the intent to influence), whether in the private or public sector on any scale. We maintain this view even if our commitment to this policy places Veego in a non-competitive business position, or if speaking up against such activity results in Veego losing business. Throughout our entire value chain, within our social patronage, charity, and sponsorship fields, we are committed to a zero-tolerance policy when it comes to corruption and bribery. Fraud, including the falsification of records of financial or non-financial information, money laundering, and insider dealing are prohibited.
9.4. Trade Controls. Veego complies with the laws and regulations related to the export, re-export, import, and use of our software, products, devices, components, services, and technical data. These trade controls place compliance obligations on Veego and our suppliers or partners related to the international distribution of Veego products, services, or assets.
9.5. Gifts and Hospitality. Veego only gives or accepts gifts and hospitality that are business courtesies that are neither material nor frequent and which are never meant to unduly influence decision-making. Gifts and entertainment are given without the expectation of return and should never affect, or appear to affect, impartial decision-making by anyone. They should never be offered or received in exchange for preferential treatment in any dealing.
9.6. Purchasing. In our purchasing decisions, negotiations, contract development, and contract administration, we comply with the applicable laws and regulations that govern those relationships and expect the same from our suppliers.
9.7. Suppliers and Partners. Veego suppliers and Partners must adhere to the highest standards of ethical behavior and regulatory compliance and operate in the best interest of Veego. Suppliers and partners are expected to provide high-quality services and products while maintaining flexibility and cost-effectiveness. All suppliers are required to read and comply with the Veego Code of Conduct.

10. Commitment to customers and suppliers

10.1. Customer relations. Veego’s policy is to build long-term relations with customers by providing the highest standards of service, honesty in sales and marketing while instituting professional standards. Veego’s policy prohibits false or misleading statements regarding competitors.
10.2. Protection of information concerning others. Veego is committed to keeping confidential any information that concerns its customers and suppliers. Discretion should be exercised in allowing collaborators access to confidential information regarding customers and suppliers.
10.3. Business dealings with third parties. Veego’s consultants, representatives, and other suppliers must conduct business legally and ethically with the purpose of maintaining Veego’s reputation.
10.4. Violation of the Code of Conduct. The Code of Ethics and Professional Conduct is an integral part of the terms and conditions of employment for all Company employees. The Company reserves the right to take disciplinary and/or legal measures against any Company Personnel who violate any of the rules in the Code of Conduct, including, but not limited to, dismissal.

11. Social Media

Social media, both inside and outside Veego, is transforming the way we interact. Online collaboration enables people to share knowledge and ideas regardless of rank, title, or experience. It is a way for us to take part in conversations around the work we do at Veego and showcase our expertise in these areas. While this digital interaction brings huge benefits, it also comes with certain risks and responsibilities.
Personal accounts. When creating your own accounts, one decision you need to make is whether you will use them for personal, professional, or both types of content. You may choose to have social media accounts that are entirely personal, with no mention of your employer, no sharing of Veego content, and no connection between your channel and Veego. In this case, you are free to use your channel as you wish.
Professional accounts. If you use a social media account or blog that links the content with Veego, there are specific guidelines you need to abide by:

  • You are welcome to declare your role at Veego in your user biography, but it should always be clear that the account is not a corporate channel but rather the voice of an individual.
  • Once you have declared your association with Veego, anything you post should reflect our ethical principles.
  • Do not include Veego as part of your profile or username.
  • Retweets or shares are endorsements (regardless of what people put in their bio), which means sharing content that constitutes an IPR infringement, defamation, disparagement or abuse will not be tolerated.
  • Never share content that is client confidential or reveals confidential intellectual property.

Think before you post. You are personally responsible for your words and actions, no matter where you are, including the online world. Please
remember that when you participate in social media, you are speaking as an individual and not on behalf of Veego. Identify yourself using the
first person singular. When you discuss Veego-related information online, be transparent by giving your name and role and mentioning that you work for Veego.
Confidentiality. Always protect clients’, Veego’s, and suppliers’ confidential and other proprietary information. This is a contractual and legal
requirement. Do not publish anything online that you would not share with a journalist, client, analyst, or competitor. Make sure that your reference to clients, partners, and suppliers does not violate any non-disclosure obligations. Please also remember your confidentiality obligations under your employment agreement. Do not disclose information about colleagues or other persons or misuse their personal data to publish their photos without their permission.
Copyrights. Comply with laws and regulations, particularly those governing intellectual property rights, including copyrights
and trademarks.

12. Employees Relationships

12.1. General Principles. Interpersonal relationships in the workplace based on respect, trust, and collaboration with all collaborators are
essential for optimum performance. Veego has made a firm commitment to preventing sexual and psychological harassment or harassment
based on sex as these situations violate human dignity, are harmful to the working environment, and affect a person’s health, morale, and
self-esteem. If an employee is involved in a personal relationship with a colleague, contractor, client, customer, or supplier, they must not allow that relationship to influence conduct whilst at work. Intimate behavior during work time is expressly prohibited. This rule applies during all working time, whether at the normal workplace or elsewhere on county council business. Managers and supervisors must declare any
relationship with an employee whom they supervise to a senior manager. To avoid a situation where an employee has managerial authority over another with whom they are in a personal relationship with or are related, Veego may:

  • Elect to transfer one or both employees involved to a job in another team or service area; or
  • Transfer the employees’ reporting lines to other managers.

In these circumstances, we will consult with the employees. We will seek to reach an agreement regarding the transfer of one or both of them. If an employee embarks on a personal relationship with or is related to a colleague working in the same service area, they must declare this to their manager. This is in the interests of openness and transparency. If an employee begins a personal relationship with, or is related to, a client, customer, contractor, or supplier which their job requires them to have authority over, they must declare this to their manager. For example, if the employee has the authority to decide to whom to award contracts. Veego reserves the right to transfer or alter the responsibilities of the employee’s role following consultation. If an employee is involved in appointments, they must take those appointments based only on merit. To avoid an accusation of bias, they must not be involved in an appointment where they are related to or have a personal relationship with an applicant. An employee must not be involved in decisions relating to discipline, promotion, recruitment, or pay and conditions for any employee who is relative, partner, or whom they have a personal relationship with.

13. Cyber security and digital devices

This section deals with all things digital at work. We want to set some guidelines for using computers, phones, and our internet connection
to ensure security and protect our assets.
13.1. Internet Usage. Our corporate internet connection is primarily for business but you can occasionally use our connection for personal
purposes as long as it doesn’t interfere with your job responsibilities. You must not use our internet connection to:

  • Download or upload obscene, offensive, or illegal material.
  • Send confidential information to unauthorized recipients.
  • Invade another person’s privacy and gain access to sensitive information.
  • Download or upload pirated movies, music, material, or software.
  • Visit potentially dangerous websites that can compromise the safety of our network and computers.
  • Perform unauthorized or illegal actions, like hacking, fraud, or buying/selling illegal goods.

14. Data protection

14.1. General principles on the protection of personal data. When Veego collects, accesses, uses, and discloses any personal data, it does so
in accordance with the applicable data protection laws. Personal data includes any information of any type, irrespective of the type of medium involved, that relates to an identified or identifiable natural person (e.g., name and surname, address, e-mail, tax identification number, telephone number). Data regarding legal persons are not considered personal data, although data regarding the contact persons or shareholders who are natural persons are. Personal data may only be used for legitimate business purposes in the context of appropriate
professional matters and will be properly safeguarded. Furthermore, personal data may only be kept for as long as necessary for the purposes for which they were collected. Any physical or electronic documents containing personal data must be handled with the utmost confidentiality, and the information must remain confidential unless the data are necessary to carry out the company’s duties or are requested by a court of law.

15. Amendments

We are committed to regularly reviewing and updating our policies. Therefore, we reserve the right to amend this code at any time and for any reason. We appreciate your feedback and welcome any comments you may have about this code. Please contact your manager or our compliance officer with any comments or suggestions.

16. Consequences of Non-Compliance

Any Collaborator who is deemed to be in violation of this Code may be subject to disciplinary action, which, if necessary, may include dismissal for just cause, in accordance with applicable laws and Veego’s policies.

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