Compliance Framework

1. Introduction and purpose

1.1 Objective of the compliance framework

This compliance framework defines the principles, structures, processes and responsibilities for ensuring the legal compliance, integrity and transparency of SCANDIC FINANCE GROUP LIMITED and all brands and structural companies mentioned in Section 0.

The purpose of this compliance framework is, in particular:

• to comply with all applicable laws, regulations and official requirements in all relevant jurisdictions,
• to implement internationally recognised standards of good corporate governance,
• to respect and promote human rights, environmental and social standards throughout all value and supply chains,
• to prevent corruption, bribery, money laundering, terrorist financing and sanctions violations,
• the protection of personal data, trade secrets and other confidential information,
• the implementation of an effective system for whistleblowers,
• establishing clear escalation and sanction mechanisms for compliance violations.

1.2 Reference to international and national standards

The compliance framework is based in particular on:

• the United Nations Guiding Principles on Business and Human Rights,
• the Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises,
• European regulations (GDPR, supply chain due diligence),
• the Supply Chain Due Diligence Act of Germany,
• Hong Kong / SAR-PRC law, UAE law, Ukraine law, UK law, Swiss law, and all other applicable legal systems, with express jurisdiction in Hong Kong / SAR-PRC.

1.3 Nature of the document

This compliance framework is a group-wide guideline and an integral part of the company's organisation. It is binding for all bodies, managers, employees, consultants and relevant external partners, insofar as this is permissible under labour and company law.

2. Scope and target audience

2.1 Social scope

The scope of application covers:

• SCANDIC FINANCE GROUP LIMITED by Scandic Banking Hong Kong,
• all brands and services of the SCANDIC FINANCE brand ecosystem,
• the cooperating companies SCANDIC ASSETS Free Zone Company, SCANDIC TRUST GROUP LLC and LEGIER Beteiligungs GmbH,
• all subsidiaries, holdings, joint ventures, representative offices and branches, but with express jurisdiction in Hong Kong / SAR-PRC.

2.2 Personal scope

The compliance framework is aimed at: Members of the administrative and management bodies, Managing directors, directors, all employees, freelancers, agents, representatives, external service providers, intermediaries, sales partners.

3. Basic principles of compliance

SCANDIC FINANCE GROUP LIMITED is committed to the following basic principles:

• Legal compliance,
• Integrity and transparency,
• Zero tolerance for corruption,
• Respect for human rights,
• Environmental protection,
• Data protection and information security,
• Responsible financial services,
• Transparent communication,
• Effective prevention and control,
• Protection of whistleblowers.

4. Governance structure and responsibilities

4.1 Responsibility of SCANDIC FINANCE GROUP LIMITED

The ultimate responsibility for compliance lies with the management or administrative body of SCANDIC FINANCE GROUP LIMITED, with express jurisdiction in Hong Kong / SAR-PRC.

4.2 Role of cooperating companies as service providers

SCANDIC ASSETS FZCO, LEGIER Beteiligungs GmbH and SCANDIC TRUST GROUP LLC act as non-operational service providers; all legal and administrative responsibility lies with SCANDIC FINANCE GROUP LIMITED.

4.3 Compliance organisation

A multi-level compliance organisation has been established: Group-wide compliance function, Local compliance officers, External compliance officer.

4.4 Responsibilities of managers and employees

Managers bear special responsibility; all employees are obliged to be familiar with and comply with the framework.

5. Risk and compliance management

5.1 Risk identification, 5.2 Risk analysis, 5.3 Risk management and 5.4 Documentation describe the systematic identification, assessment, management and documentation of risks and are set out in the preambles to the supply chain documentation.

6. Corruption prevention and integrity

Zero-tolerance policy towards corruption and bribery. Prohibition of improper payments, permission only for appropriate, documented and transparent gifts.

7. Prevention of money laundering, terrorist financing and sanctions violations

Risk-based identification checks (Know Your Customer / Know Your Business), ongoing monitoring, sanctions list checks, reporting of suspicious circumstances.

8. Human rights, labour and social standards

Rejection of forced labour, child labour, human trafficking and discrimination. Ensuring humane working conditions, fair wages and occupational safety.

9. Environmental, climate and resource protection

Responsible use of energy and resources, reduction of emissions, consideration of ecological criteria in investments and supply chains.

10. Supplier, third-party and partner management

Transparent selection procedures, compliance clauses, auditing rights, termination of business relationships in the event of violations.

11. Data protection, information security and confidentiality

Compliance with the General Data Protection Regulation and local data protection laws, technical and organisational measures to protect personal data and confidential information.

12. Product-specific compliance in the financial and fiduciary sector

Special requirements for payment services, digital assets, asset management, trust and investment products.

13. Conflicts of interest

Avoidance and management of conflicts of interest through internal guidelines, organisational separation and disclosure requirements.

14. Whistleblower system and complaint mechanism

Provision of secure reporting channels (online system, email, telephone, external ombudsman), confidential treatment, protection against reprisals.

15. Training, communication and awareness raising

Regular training on legal and compliance issues, group-wide communication of guidelines and changes.

16. Monitoring, internal controls and investigations

Risk-based audit plans, internal audits, evaluation of key figures, internal investigations in cases of suspicion.

17. Sanctions and measures in the event of violations

Labour law, civil law and, if applicable, criminal law consequences, termination of business relationships, organisational adjustments.

18. Special features of individual legal systems

Specific requirements for Hong Kong, Switzerland, the United Arab Emirates, the United Kingdom, the Federal Republic of Germany, Ukraine and other affected countries.

19. Entry into force, review and further development

Entry into force with approval by management, annual and event-related review, continuous improvement.

20. Contact for compliance matters

SCANDIC FINANCE GROUP LIMITED by Scandic Banking Hong Kong

Room 10, Unit A, 7/F
Harbour Sky, 28 Sze Shan Street
Yau Tong, Hong Kong, SAR-PRC

Head office telephone number in Switzerland, Zurich: +41 44 7979 99 – 85
Email: Office@ScandicFinance.Global