Corporate Ethics Policy

1.1 Introduction

Our Corporate Ethics Policy reflects our commitment to uphold our reputation for honest and ethical conduct toward our customers, our partners, our suppliers, and our competitors. It will also help you understand and appreciate the way in which we like to do business.

This Ethics Policy applies to all employees of Argentium Collections, as well as consultants, representatives, and anyone doing business on the Company's behalf.

As an employee of Argentium Collections, you are entrusted with primary responsibility for sound business conduct and compliance with our Ethics Policy. Although the Company's ethics and principles remain constant, the environment and the situations in which they are applied are fluid. This Ethics Policy does not anticipate every ethical question that may arise, and it cannot substitute for sound judgement on your part. However, your honesty, integrity, and good faith as an employee will help safeguard Argentium Collections' reputation for ethical business practices.

If you have any questions about interpreting or applying this Ethics Policy, or if you disagree with any part of this or any other Company policy, your responsibility is to consult your Line Manager, Director, or Managing Director. A violation of any policy or guideline can put you, your co-workers, and the Company at risk and may result in disciplinary action, including dismissal. This Ethics Policy does not create any contractual right to employment, employee benefits, or any other terms and conditions of employment.

1.2 Directors' and Managers' Responsibility

Directors or Line Managers at Argentium Collections have additional responsibilities. They must:

• Develop and support a work environment where ethical conduct is recognised, valued, and exemplified
• Assist and support employees who raise questions or concerns about ethics and legal compliance
• Monitor and enforce compliance with the standards in this Policy
• Set a good example and encourage others to do likewise

1.3 Seeking Help and Reporting a Concern

In keeping with Argentium Collections' commitment to open communication and the highest standards of conduct, as an employee and a representative of the Company, you must immediately report whatever you know or have heard about a situation that appears to you to be unlawful or unethical. You may make a report anonymously if you wish (please refer to Argentium Collections' Whistleblowing Policy). The Director, Manager, or employee to whom you make the report must pass the information to a Director. Your report will be reviewed promptly, and we will not tolerate threats or acts of retaliation against you for making a report.

1.4 Personal Conduct of Employees

Every day, we each make decisions and statements and take other actions that collectively create the reality and perception of the fairness and integrity of Argentium Collections. Everything you do as an individual reflects the Company as a whole. It is expected that you support the spirit and abide by the letter of the Ethics Policy and ask for guidance from a Director or your Line Manager when any questions arise.

It is not the policy of the Company to set standards for the conduct of your personal life. However, when your actions outside of work affect the Company's interests, your own performance, or that of your co-workers, the Ethics Policy will apply. In addition, if your personal conduct negatively affects Argentium Collections, its employees, or other aspects of the business, it may also be appropriate for the Company to take action to protect its interests.

1.5 Bribes, Gifts and Entertainment

1.5.1 Acceptable and Unacceptable Gifts

Different companies offer a wide variety of gifts. These can range from conference souvenirs, which you may readily give or accept, to bribes, which unquestionably must not be given or accepted. Gifts include not only material goods, but also services, promotional premiums, and discounts.

1.5.2 Receiving Gifts

If a gift has a value greater than the equivalent of £25 (or the equivalent in any other currency), or if at any time the value or commercial context of a gift raises questions of influence, you must report it to your Manager and seek management guidance and approval before accepting it. Always consider the appearance (how would your receipt of the gift appear to other employees and people outside the Company?) and the reasons why the gift was made (is it intended to influence your objectivity?). If you are offered a gift of substantial value that could be construed as a reward or incentive for doing business with a particular company, you must politely refuse the gift, explain that Company policy prohibits its retention, and report the incident. Examples of such gifts include any gift of cash, vouchers, or a paid overnight trip to a resort.

Sometimes you may find it difficult to determine whether the value or context of a gift raises an inference of undue influence or conflict of interest. As stated above, you should always seek management guidance and authorisation before accepting anything. Never accept a gift from a UK or foreign government official. Contact your Line Manager or a Director if you have any specific questions.

1.5.3 Giving Gifts

Under no circumstances are you to give money or any gift to an executive, official, or employee of any supplier, customer, vendor, or other organisation if doing so would influence or give the appearance of influencing that organisation's relationship with Argentium Collections. Like Argentium Collections, customers may have strict policies regarding the receipt of gifts. You may offer a gift of nominal value, such as an advertising novelty, if it is not prohibited by law or the customer's known business policies and practices.

1.5.4 Bribery

Argentium Collections does business with customers and other organisations that have a reputation for ethical business conduct, but there is always a risk that you may be offered something of value intended to result in an illicit advantage for the giver. Likewise, you may be considering a valuable gift to a decision-making employee of a customer in the hope that they will choose Argentium Collections over another vendor. A bribe or improper payment, including kickbacks on any portion of a contract payment, or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers, their employees, or government officials, must not be accepted.

A bribe is something of value (usually money) offered to a person in a position of trust to influence their judgement or conduct, e.g. to circumvent ethical or other rules. Bribes can include but are not limited to:

• Cash payments (including vouchers)
• Gifts
• Travel and entertainment
• Kickbacks
• Preferential treatment
• Unexplained rebates
• Payments for advertising or other disguised allowances or expenses

1.6 Clear Communication Is Essential

Employees must not make misrepresentations or dishonest statements to anyone when conducting business for Argentium Collections. If you believe the person with whom you are conducting business may have misunderstood you, promptly clarify or correct your statement. Honesty based on clear communication is essential to forming and maintaining sound, lasting business relationships and upholding the ethical reputation of the Company.

1.7 Fraud

Fraud is an act or intent to cheat, trick, steal, deceive, or lie. Fraud is an act of dishonesty and, in most cases, a criminal act. Intentional acts of fraud are treated very seriously and will be subject to strict disciplinary action, up to and including termination of employment and possible further legal action. Some examples of fraud include:

• Submitting false expense reports
• Forging or altering cheques
• Misappropriating assets or misusing Company property
• Unauthorised handling or reporting of transactions

1.8 Supplier Conduct

Argentium Collections considers there are many benefits to be had by trading ethically, and one way we can do this is by ensuring, as far as possible, that our suppliers behave ethically too.

The potential benefits to Argentium Collections include:

• Promoting our corporate social responsibility credentials
• Attracting ethically motivated customers
• Attracting ethically motivated investors
• Avoiding harmful publicity linking us to our suppliers' practices

All Argentium Collections staff should be aware of this when doing business with suppliers and should ensure, wherever possible, that suppliers are made aware of the principles outlined below.

Forced or Involuntary Labour — Suppliers will not use forced or involuntary labour of any type (e.g. forced, bonded, indentured, or involuntary prison labour); employment is voluntary.

Child Labour — Suppliers will not use child labour. The term "child" refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. We support the use of legitimate workplace apprenticeship programs which comply with all applicable laws and regulations.

Wages and Benefits — Suppliers will, at a minimum, comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime hours, piece rates, and other elements of compensation, and will provide legally mandated benefits.

Working Hours — Suppliers will not exceed prevailing local work hours and will appropriately compensate overtime. Suppliers shall not require employees to work more than 60 hours per week, including overtime, except in extraordinary business circumstances with their consent. Where the maximum work week is less under local law, that standard shall apply. Suppliers' employees should be allowed at least one day off per seven-day week.

Non-Discrimination — Suppliers will not discriminate in hiring and employment practices on the grounds of race, religion, age, nationality, social or ethnic origin, sexual orientation, gender, gender identity or expression, marital status, pregnancy, political affiliation, or disability.

Respect and Dignity — Suppliers will treat all employees with respect and will not use corporal punishment, threats of violence, or other forms of physical coercion or harassment.

Freedom of Association — Suppliers shall respect the legal rights of employees to join or refrain from joining worker organisations, including trade unions. Suppliers have the right to establish favourable employment conditions and maintain effective employee communication programs as a means of promoting positive employee relations that make employees view third-party representation as unnecessary.

Health and Safety — Suppliers will provide employees with a safe and healthy workplace in compliance with all applicable laws and regulations. Consistent with these obligations, suppliers must implement effective programs covering life safety, incident investigation, chemical safety, ergonomics, and similar areas, and provide the same standard of health and safety in any housing provided for employees. Suppliers should strive to implement management systems to meet these requirements.

Protection of the Environment — Suppliers will operate in a manner that is protective of the environment. At a minimum, suppliers must comply with all applicable environmental laws, regulations, and standards, such as requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits, and environmental reporting. Suppliers must also comply with any additional environmental requirements specific to the products or services they provide to Argentium Collections, as called for in design specifications and contract documents. Suppliers should strive to implement management systems to meet these requirements.

Laws, Regulations and Other Legal Requirements — Suppliers will comply with all applicable laws and regulations in all locations where they conduct business.

Ethical Dealings — Suppliers will observe the highest ethical principles in performing work as an Argentium Collections supplier. Suppliers will be familiar with, and will strictly comply with, all laws and regulations on bribery, corruption, and prohibited business practices. Suppliers and their subsidiaries and affiliates have not and will not offer, promise, make, or agree to make any payments or gifts (of money or anything of value), directly or indirectly, to anyone for the purpose of influencing or inducing decisions in favour of Argentium Collections or any of its subsidiaries or affiliates.

1.9 Accounting and Financial Reporting Laws

Argentium Collections is required to follow strict accounting principles and standards, to report financial information accurately and completely, and to use appropriate internal controls and processes to ensure that accounting and financial reporting complies with the law.

We maintain specific policies and procedures for our financial accounting and reporting practices. We place a high value on the integrity and accuracy of our records, which are maintained in accordance with generally accepted accounting principles and regulatory requirements.

The rules for accounting and financial reporting require the proper recording of, and accounting for, revenues and expenses. If you are involved with or responsible for any of these procedures, you must understand and adhere to the rules. You must not account improperly or make false or misleading financial reports, nor encourage or assist others to commit these acts. Additionally, you must never advise anyone outside of Argentium Collections, including customers, suppliers, and business partners, on how they should record or report their own revenues or expenses.

Violations of laws associated with accounting and financial reporting can result in fines, penalties, and imprisonment, and can lead to a loss of public trust in a company. As a result, those who violate these principles will be subject to disciplinary action, including dismissal. If you learn of any action related to accounting or financial reporting that you believe may be illegal, unethical, or inappropriate, you must immediately report the situation to your Line Manager or Director. This can be done anonymously if you prefer. We will not permit retaliation of any kind against anyone who makes a report or complaint in compliance with these principles.