Code of Conduct

Version 1.0 | Effective Date: November 1, 2025 | Last Updated: October 25, 2025

1. Purpose and Applicability

This Code of Conduct defines the ethical, professional, and compliance standards expected of all individuals and organisations associated with SUNAGO Group L.L.C-FZ ("SUNAGO").

It applies to all employees, contractors, partners, and affiliates who engage in or represent SUNAGO in any capacity.

Every user of SUNAGO tools or services agrees to comply with this Code as a condition of participation under our Terms & Conditions.

2. Guiding Values

SUNAGO's work is grounded in five core values that shape our decisions and collaborations:

Collaboration: We succeed through teamwork and shared expertise across borders.

Innovation: We encourage creativity and continuous improvement in everything we do.

Excellence: We pursue the highest professional and technical standards.

Sustainability: We promote environmental and social responsibility in our operations.

Empowerment: We enable the growth of people, partners, and communities.

These principles form the foundation of all SUNAGO partnerships and business decisions.

3. Ethical and Professional Standards

Integrity and Fair Practice

All SUNAGO representatives must act with honesty, transparency, and fairness.

Corruption, bribery, or any attempt to gain undue advantage through improper conduct is strictly prohibited.

Business decisions must be based on objective criteria and in the best interests of SUNAGO and its partners.

Conflicts of Interest

Avoid situations where personal or financial interests interfere with professional responsibilities.

Any potential conflict must be disclosed promptly to management or your designated SUNAGO contact.

Confidentiality and Data Protection

Confidential information obtained through SUNAGO systems or partnerships must be handled responsibly and protected from unauthorised disclosure.

All users are required to comply with SUNAGO's Privacy Policy and applicable data-protection laws.

4. Diversity, Inclusion, and Human Rights

SUNAGO values diversity as a source of strength and innovation.

We are committed to:

Equal opportunities for all individuals regardless of gender, age, ethnicity, religion, disability, or cultural background.

A work environment free from discrimination, harassment, or bullying.

Respect for fundamental human rights in line with the United Nations Universal Declaration of Human Rights.

Zero tolerance for forced or child labour, exploitation, or any form of abuse.

SUNAGO promotes a culture where every voice is respected and differences are embraced as part of our global identity.

5. Health, Safety, and Well-being

We aim to maintain a safe and healthy work environment across all operations.

Everyone is encouraged to report unsafe conditions or behaviours immediately.

SUNAGO also supports initiatives that promote physical and mental well-being, including fair work-life balance and open communication.

6. Environmental, Social, and Governance (ESG) Commitment

Environmental Responsibility

SUNAGO strives to minimise its environmental footprint through responsible energy use, digital efficiency, and sustainable sourcing.

Partners are encouraged to adopt environmentally conscious practices wherever feasible.

Social Responsibility

Through the SUNAGO Foundation, we support education, vocational training, and community projects that advance equitable growth and opportunity.

Governance

We operate with integrity, transparency, and accountability at every level.

Our leadership promotes compliance with applicable laws, anti-corruption standards, and ethical decision-making in all jurisdictions where we work.

7. Compliance and Sanctions

SUNAGO conducts mandatory screening to ensure compliance with international and local sanctions laws.

We reserve the right to immediately terminate any relationship if an employee, contractor, or partner or any of their beneficial owners, representatives, or affiliates is identified as a confirmed match on any of the following:

United Nations Security Council Consolidated Sanctions List

UAE Local Terrorist List

or other similar lists maintained by recognised authorities.

In the event of a partial match, SUNAGO may temporarily suspend cooperation while investigating.

We strictly adhere to applicable international sanctions and anti-terrorism regulations.

8. Reporting Concerns and Whistleblower Protection

Any individual may report suspected violations of this Code, unethical conduct, or legal non-compliance through confidential channels.

Reports should be sent to sunago@sunago-group.com.

All reports are treated seriously and confidentially. SUNAGO prohibits retaliation against anyone who raises a concern in good faith.

If you are unsure whether a situation breaches this Code, you are encouraged to seek guidance rather than remain silent.

9. Enforcement and Consequences

Compliance with this Code is mandatory.

Violations may result in disciplinary action, suspension, termination of access, or cancellation of partnership agreements.

SUNAGO reserves the right to take appropriate measures to protect its integrity and that of its partners.

10. Review and Updates

This Code is reviewed regularly to ensure ongoing relevance with evolving best practices, legal requirements, and SUNAGO's strategic direction.

Any updates will be published with a revised effective date. Continued engagement with SUNAGO platforms or services constitutes acceptance of the updated Code.

11. Contact Information

SUNAGO Group L.L.C-FZ

Meydan Grandstand, 6th Floor, Meydan Road, Nad Al Sheba, Dubai, UAE

Email: sunago@sunago-group.com