Code of Conduct & Ethics

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Effective Date: 23 July 2025

Entity: Six Rows Global Corp.

Jurisdiction: Ontario, Canada

1. Purpose & Scope

This Code of Conduct & Ethics (“Code”) establishes the ethical principles and standards of professional conduct governing the activities of Six Rows Global Corp. (“Six Rows”, “the Company”).

This Code applies to:

• The Company’s director(s)
• Officers and representatives
• Contractors, consultants, agents, and subcontractors acting on behalf of Six Rows
• Partners and intermediaries engaged in connection with Six Rows’ operations.

This Code also applies to any individual or entity acting on behalf of Six Rows Global Corp., whether formally contracted or otherwise authorized.

This Code is designed to support ethical, lawful, and responsible conduct across all activities of Six Rows Global Corp., including but not limited to government, donor-funded, institutional, and commercial engagements.

2. Ethical Commitment

Six Rows Global Corp. is committed to conducting its operations with integrity, professionalism, and accountability.

All individuals acting on behalf of Six Rows are expected to:

• Act honestly and in good faith
• Comply with applicable laws, regulations, and contractual obligations
• Avoid conduct that could compromise the integrity or reputation of the Company or its clients

Ethical conduct is a foundational requirement for engagement with public-sector, institutional, and international partners.

3. Anti-Bribery & Anti-Corruption

Six Rows Global Corp. maintains a zero-tolerance policy toward bribery, corruption, extortion, facilitation payments, or any improper advantage.

No individual acting on behalf of Six Rows may:

• Offer, promise, give, solicit, or accept bribes or improper payments
• Provide anything of value to improperly influence decisions of public officials, institutional representatives, or counterparties
• Engage in conduct that violates applicable anti-corruption laws, including but not limited to:
• Canada’s Corruption of Foreign Public Officials Act (CFPOA)
• Applicable international anti-corruption standards

This prohibition applies regardless of local customs or business practices. Where local laws or practices conflict with this Code, the higher ethical standard shall apply.

4. Conflicts of Interest

Individuals acting on behalf of Six Rows must avoid situations where personal, financial, or other interests could conflict with the interests of the Company or its clients.

All actual, potential, or perceived conflicts of interest must be disclosed promptly and managed appropriately.

No individual may use their position for personal gain or engage in activities that compromise independent judgment or professional objectivity.

5. Compliance with Laws & Regulations

Six Rows Global Corp. is committed to compliance with:

• Applicable Canadian laws and regulations
• Host-country laws where activities are conducted
• Donor, institutional, and contractual compliance requirements
• Applicable sanctions, export controls, and trade restrictions

All engagements are conducted within the legal and regulatory frameworks governing the relevant program or jurisdiction.

6. Fair Dealing & Professional Conduct

Six Rows expects fair, transparent, and professional conduct in all business dealings.

This includes:

• Honest communication with clients, partners, and stakeholders
• Respectful engagement with public officials and institutional counterparts
• Accurate record-keeping and truthful reporting
• Refraining from misleading, deceptive, or unethical practices

7. Confidentiality & Information Integrity

Individuals acting on behalf of Six Rows must safeguard confidential, sensitive, or proprietary information obtained through their work.

Information must be:

• Used solely for legitimate business or contractual purposes
• Protected from unauthorized disclosure
• Handled in accordance with applicable legal and contractual requirements

8. Reporting & Accountability

Concerns related to unethical conduct, legal violations, or breaches of this Code may be reported to Six Rows Global Corp. through appropriate channels.

Six Rows commits to:

• Reviewing concerns in good faith
• Taking appropriate action where necessary
• Prohibiting retaliation against individuals who raise concerns responsibly

Reports may be submitted confidentially and without fear of retaliation, provided they are made in good faith.

9. Enforcement & Compliance

Compliance with this Code is a condition of engagement with Six Rows Global Corp.

Violations may result in:

• Termination of engagement or contractual relationship
• Corrective or remedial action
• Referral to appropriate authorities where required by law

10. Continuous Commitment

Six Rows Global Corp. reviews its ethical standards periodically to ensure alignment with evolving regulatory, donor, and institutional expectations.

Ethical conduct is treated as an ongoing obligation, not a one-time requirement.

Contact

Questions regarding this Code of Conduct & Ethics may be directed to:

info@6rowsglobal.com