Code of Conduct

Effective Date: 30 Dec 2025

Preface

Employees, officers, directors, contractors, consultants, and other representatives of Synetecs, Inc. ("Synetecs," "the Company") are expected to conduct themselves in a manner that reflects the highest standards of ethical behavior, professionalism, and integrity.

This Code of Conduct ("Code") sets forth the principles and expectations governing conduct in all business activities and relationships involving Synetecs. It is designed to promote compliance with applicable laws, regulations, and internal policies, and to foster a culture of accountability, respect, and responsible innovation.

All individuals covered by this Code are required to know, understand, and comply with its provisions. Failure to do so may result in disciplinary action, up to and including termination of employment or engagement, as well as potential civil or criminal liability.

Any waiver of this Code for executive officers or members of the Board of Directors must be approved by the Board of Directors and disclosed in accordance with applicable law.

Synetecs strictly prohibits retaliation against any individual who, in good faith, reports a suspected violation of this Code or participates in an investigation.

1. Scope and Applicability

This Code applies to all employees of Synetecs, its subsidiaries, and controlled affiliates, as well as members of the Board of Directors.

In addition, contractors, consultants, temporary workers, and other members of the extended workforce who perform services for or on behalf of Synetecs are expected to comply with this Code in connection with their work for the Company.

Where local laws or employer-specific codes apply, individuals must comply with the stricter standard.

2. Conflicts of Interest

A conflict of interest arises when personal interests interfere, or appear to interfere, with the interests of Synetecs. All individuals must avoid situations that create actual, potential, or perceived conflicts of interest.

Conflicts of interest may include, but are not limited to:

• Personal financial interests in competitors, customers, suppliers, or business partners
• Outside employment or business activities that interfere with Company responsibilities
• Use of Company information, assets, or opportunities for personal gain
• Family or close personal relationships that influence business decisions

Individuals must promptly disclose any potential conflict of interest to management, Human Resources, or Legal for review and guidance.

3. Financial Integrity and Responsibility

Synetecs is committed to maintaining accurate books and records and to complying with all applicable accounting standards, laws, and regulations.

All financial transactions must be recorded accurately, completely, and in a timely manner.

• Falsification of records is strictly prohibited
• Improper payments or reimbursements are prohibited
• Interference with audits or internal controls is prohibited

Any suspected financial irregularities must be reported immediately through appropriate channels.

4. Compliance With Laws and Regulations

Synetecs operates in a highly regulated environment and is subject to laws and regulations in multiple jurisdictions. All individuals are expected to comply with all applicable legal requirements.

4.1 Trade Controls and Export Laws

Laws governing imports, exports, sanctions, and technology transfers apply to Synetecs products, services, software, and technical data.

Individuals involved in cross-border activities must ensure compliance with all applicable trade controls and seek guidance when necessary.

4.2 Competition and Antitrust Laws

Synetecs is committed to fair and lawful competition. Conduct that restrains trade, abuses market position, or misleads customers is prohibited.

4.3 Insider Trading

Individuals may not trade securities or provide investment advice based on material, non-public information obtained through their work at Synetecs.

4.4 Anti-Bribery and Anti-Corruption

Synetecs maintains a zero-tolerance policy toward bribery and corruption.

No individual may offer, promise, give, solicit, or accept anything of value to improperly influence any business decision, whether involving government officials or private parties.

5. Workplace Conduct and Respect

Synetecs is committed to maintaining a workplace that is professional, respectful, inclusive, and free from harassment, discrimination, retaliation, or abusive conduct. Discrimination or harassment based on legally protected characteristics will not be tolerated.

All reports of misconduct will be reviewed promptly and fairly.

6. Data Protection, Privacy, and Confidentiality

Individuals must protect confidential, proprietary, and personal information entrusted to Synetecs.

• Access information only for legitimate business purposes
• Safeguard information against unauthorized access or disclosure
• Comply with all applicable privacy and data protection laws

7. Responsible Use of Technology and Artificial Intelligence

Synetecs develops advanced technologies, including artificial intelligence systems, and is committed to their responsible and ethical use.

Individuals must ensure that technology is developed and deployed in accordance with Company policies, applicable law, and ethical standards.

8. Reporting Concerns and Non-Retaliation

Individuals are encouraged and expected to report suspected violations of this Code, Company policies, or applicable law. Reports may be made to management, Human Resources, Legal, or designated reporting channels.

Retaliation against anyone who reports concerns in good faith or participates in an investigation is strictly prohibited.

9. Enforcement and Accountability

Compliance with this Code is a condition of employment or engagement with Synetecs. Violations may result in disciplinary action, up to and including termination, regardless of position or tenure.

10. Conclusion

This Code reflects Synetecs' commitment to lawful, ethical, and responsible conduct. Each individual is responsible for upholding both the letter and the spirit of this Code.

11. Contact Information