Code of Conduct

1. Core Principles

• Integrity: act honestly and transparently in all professional dealings
• Compliance: adhere to all applicable laws, regulations, and KGML policies
• Respect: treat all colleagues, clients, and counterparties with dignity
• Accountability: take responsibility for your decisions and their consequences
• Confidentiality: protect all proprietary, commercial, and personal information
• Conflict avoidance: identify and disclose potential conflicts of interest promptly

2. Market Conduct

All market-facing activities must comply with applicable market regulations and exchange rules. Market manipulation, insider trading, front-running, and any form of market abuse are strictly prohibited.

3. Confidentiality

All employees are required to protect the confidential information of KGML, its clients, and counterparties. This obligation continues after termination of employment.

4. Use of Company Resources

Company resources must be used only for legitimate business purposes. Personal use of company systems must not compromise security, damage the company's reputation, or violate applicable law.

5. Social Media

Employees must not make statements on behalf of KGML through social media without explicit authorisation. Statements about market conditions or company business must be approved by Compliance before publication.

6. Reporting Violations

All employees are required to report known or suspected violations of this Code through the Whistleblower channel. Retaliation against good-faith reporters is strictly prohibited.