At Aegir Consult Limited, we are committed to upholding the highest standards of ethical conduct, professionalism, and integrity in all aspects of our business operations. Our reputation and success are built upon the trust and confidence of our clients, partners, employees, and the communities we serve. Therefore, we adhere to the following Code of Conduct (Version 1.1):

1. Integrity and Honesty
• We conduct all business with honesty, integrity, and fairness, adhering to the highest moral and ethical standards.
• We do not engage in any form of deceptive, misleading, or fraudulent practices.
• We maintain accurate records and reports and ensure transparency in all business transactions.
2. Compliance with Laws and Regulations
• We comply with all applicable laws, regulations, and industry standards in every jurisdiction where we operate.
• We respect intellectual property rights and confidential information of others and ensure that our actions do not infringe upon them.
3. Confidentiality and Privacy
• We safeguard the confidentiality and privacy of sensitive information entrusted to us by clients, employees, partners, and other stakeholders.
• We do not disclose confidential information unless authorized or required by law, and we take appropriate measures to protect it from unauthorized access or disclosure.
4. Conflict of Interest
• We avoid conflicts of interest and refrain from engaging in activities that may compromise our impartiality, objectivity, or independence.
• We disclose any potential conflicts of interest promptly and take appropriate steps to mitigate them in the best interest of the company and its stakeholders.
5. Respect and Diversity
• We treat all individuals with dignity, respect, and fairness, regardless of their race, ethnicity, gender, religion, sexual orientation, disability, or any other characteristic.
• We foster an inclusive and diverse workplace where everyone feels valued, empowered, and able to contribute their unique perspectives and talents.
6. Professionalism and Excellence
• We strive for excellence in everything we do, delivering high-quality services and products that meet or exceed the expectations of our clients and stakeholders.
• We maintain a professional demeanor and adhere to the highest standards of competence, diligence, and ethical conduct in our interactions with clients, colleagues, and the broader community.
7. Environmental and Social Responsibility
• We are committed to minimizing our environmental footprint and promoting sustainable practices in our operations and business activities.
• We actively contribute to the well-being and development of the communities in which we operate, supporting social causes and initiatives that create positive impact and promote societal progress.
8. Reporting Violations
• We encourage employees to speak up and report any suspected violations of this Code of Conduct or unethical behaviour through appropriate channels, such as management, HR, or anonymous reporting mechanisms.
• We ensure that no retaliation is taken against individuals who report violations in good faith, and we investigate all reports promptly and impartially.
9. Continuous Improvement
• We are committed to continuous improvement and periodic review of our policies, practices, and procedures to ensure they remain aligned with the principles and values outlined in this Code of Conduct.
• We welcome feedback from employees, clients, partners, and other stakeholders to help us identify areas for improvement and strengthen our commitment to ethical conduct and corporate responsibility.
10. Enforcement and Accountability
• All employees are expected to familiarize themselves with this Code of Conduct and adhere to its principles and guidelines in their daily activities.
• Violations of this Code may result in disciplinary action, up to and including termination of employment, and may also lead to legal consequences depending on the severity of the violation.
11. Data Protection and Confidentiality
• We respect the privacy rights of individuals and ensure that personal data is processed lawfully, fairly, and transparently.
• We protect the confidentiality of sensitive information entrusted to us by clients, employees, partners, and other stakeholders, and only disclose such information as necessary for legitimate business purposes and with appropriate authorization.
12. Compliance with Data Protection Laws
• We comply with all applicable data protection laws, regulations, and industry standards, including but not limited to the Kenyan Data Protection Act (2019), and other relevant privacy frameworks as outlined by the Office of the Data Protection Commissioner (OPDC) of Kenya.
• We respect individuals' rights regarding their personal data, including the right to access, rectify, erase, restrict processing, and data portability, and we provide mechanisms for individuals to exercise these rights.
13. Data Transfer and International Compliance
• We ensure that any transfer of personal data outside of the jurisdiction where it was originally collected is conducted in accordance with applicable data protection laws and regulations, including the use of appropriate safeguards such as standard contractual clauses or binding corporate rules.
• We respect the privacy rights of individuals in all jurisdictions where we operate and strive to comply with the highest standards of data protection regardless of location.
14. Continuous Improvement
• We are committed to continuous improvement in our data privacy and security practices, regularly reviewing and updating our policies, procedures, and controls to reflect changes in technology, regulations, and industry standards.
• We engage with clients, partners, and other stakeholders to solicit feedback and incorporate their input into our data privacy and security initiatives, fostering a culture of collaboration and shared responsibility..
15. Reporting Data Breaches
• • In the event of a data breach or security incident involving personal data, we have procedures in place to promptly assess the incident, mitigate any harm, and notify affected individuals, regulators, and other relevant parties in accordance with legal requirements and best practices.

By adhering to this Code of Conduct, we demonstrate our commitment to ethical conduct, integrity, and responsible corporate citizenship, thereby contributing to the long-term success and sustainability of Aegir Consult Limited and the communities we serve.

Date of Adoption: 4th March 2024

This Code of Conduct on Data Privacy and Security is effective immediately upon adoption and supersedes any previous versions.