Business Code of Conduct

Commitment to Integrity

Rubicon Commodities AG conducts its business with integrity, professionalism, and respect for applicable laws

All directors, officers, employees, and representatives must act honestly, transparently, and in the best interests of the company and its stakeholders.

Compliance with Laws

We comply with all applicable laws and regulations, including:

• Anti-corruption and anti-bribery laws
• Trade, sanctions, and export regulations
• Competition and commercial laws
• Environmental and safety requirements

Non-compliance is not tolerated.

Professional Conduct

All representatives are expected to:

• Treat colleagues and counterparties with respect
• Avoid discrimination, harassment, or unethical behaviour
• Fulfill contractual and professional obligations responsibly

Conflicts of Interest

Personal interests must not interfere with business decisions.
Any actual or potential conflicts of interest must be disclosed promptly.

Confidentiality

Confidential business information and personal data must be protected at all times.
Unauthorized disclosure is strictly prohibited.

Applicability

This Code applies to all individuals acting on behalf of Rubicon Commodities AG.
Adherence to these principles is a condition of engagement with the company.