Employee code of conduct

Prepared by Compliance Officer, Awin AG

Prepared for Awin employees

Date November 2023

Dear Colleagues,

In our journey to create the leading affiliate marketing network, our values and behaviours play a critical role. They define how we want to work together – both now and in the future in order to secure long-term business success and the well-being of every employee. We operate in a fast paced environment, in many countries around the world, and our clients, business partners and other stakeholders, in addition to ourselves, have very high expectations that we will behave responsibly, ethically and in compliance with local law. Though this is the personal responsibility of everyone, we ensure that compliance is an essential part of our daily work and want to foster a culture of honesty and trust in which managers serve as role models in promoting ethically sound and lawful conduct.

This Employee Code of Conduct is a binding set of rules that provides reliable and transparent orientation for our daily activities and behaviour. It combines our existing company principles, values, and guidelines, which comprise the ethical, moral, and legal requirements. Because we all bear joint responsibility for our company´s reputation, the Code applies equally to everyone – board members, managers and each and every employee.

Our key values are: Transparency, Openness, Accountability and Respect. Violating the Employee Code of Conduct undermines the values that we stand for and the trust that we put in each other. For this reason we ask you to watch out for compliance with this Employee Code of Conduct in your work environment, and to openly address any violations or ask about guidance if you are unsure about a certain situation or decision.

We love what we do, we have fun working together, and we operate in a culture of respect and trust – let us all work together in protecting that. Thank you for your constant support and commitment - without it the long-term success of our group would not be possible.

Adam Ross CEO

David Lloyd COO

Virpy Richter CFO

Gary Reck CPTO

Scope

This Employee Code of Conduct (“Code”) applies to the AWIN AG and all companies in which the AWIN AG holds a majority share (together the “Awin Group” or “Awin”), as well as to all employees of the Awin Group. Its rules represent minimum standards for ethical behaviour. If common legal practice, legal stipulations, jurisprudence or other rules applicable in a country in which we operate differ from the provisions set out in this Code, it is always the respective stricter rules which are to be applied in individual cases.

This Code does not cover every situation we may encounter. There is no substitute for the personal integrity and sound judgment of each individual. An important prerequisite for this is that we are all familiar with the rules relating to our work, our responsibilities and are aware of the impact of our actions and decisions.

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