Code of Conduct

[CODE OF CONDUCT]

1. Preliminarystatements

This Code of Conduct (hereinafter referred to as the ‘Code’) provides guidelines in matters of professional ethics to employees of the The Free Zone Mauritius, including the members of the Executive Committee (hereinafter referred to as the ‘employee(s)’). It also serves as a reference for the public with regard to the standard of conduct that third parties are entitled to expect in their dealings with employees of the Free Zone of Mauritius.

The Code makes explicit the ethical conventions and standards by which the The Free Zone of Mauritius considers it necessary for the employees to adhere to.

It also clarifies the benchmarks against which fulfillment of the obligations already assumed by the employees will be measured.

1. Basicprinciples

Employees should act with exclusive loyalty to the The Free Zone of Mauritius, with honesty, independently, impartially, with discretion and without regard to self-interest to subscribe to high standards of professional ethics, and to avoid any situation liable to give rise to a conflict ofinterest.

Privacy

The The Free Zone respects the privacy of its employees and does not wish to interfere with their personal lives and behavior outside the work place, as long as the employee’s conduct does not pose a risk to the reputation of the The Free Zonee of Mauritius.

Integrity

Employees are required to act with integrity in all their activities, avoiding any behavior that would reflect adversely on them or the The Free Zone of Mauritius. Integrity encompasses honesty, probity, and loyalty.

Impartiality

Employees must act with impartiality. They must take care that their expression of personal views and convictions do not compromise or appear to compromise the performance of their official duties or the interests of the The Free Zone of Mauritius. The employees’ conduct must at all times be characterized by objectivity and professionalism. They must not allow personal relationships or considerations, including biasness or favoritism, influence the performance of their official duties, and should avoid situations that create or may create a conflict ofinterest.

Discretion

Employees must exercise the utmost discretion in their actions and show tact and reserve in their pronouncements in a manner that is consistent with the status of a The Free Zone of Mauricio employee. They must refrain themselves from participating in any activity that is in conflict with the interests of the The Free Zone of Mauritius or would or could damage its reputation. Employees must continuously safeguard the confidentiality of information which is available to them and also strictly comply with the legal obligations imposed on them by the differentlaws.

1. Equal treatment andnon-discrimination

Employees should avoid any form of discrimination and, in particular, any discrimination based on race, nationality, gender, age, physical disability, sexual preference, political opinions, philosophical views or religious convictions.

Sexual harassment, psychological or physical bullying of any kind whatsoever are not tolerated by the The Free Zone of Mauritius. Sexual harassment can be defined as “unwanted conduct of a sexual nature, or other conduct based on sex affecting the dignity of women and men at work”. This can include unwelcome physical, verbal or non-verbal conduct. Employees need both to show sensitivity to and respect for others and to stop any behavior seen as offensive by another person at his/her firstindication.

1. Responsibility

Employees are expected to be mindful of the importance of their duties and responsibilities, to take into account the expectations of the public concerning their moral behavior, and to conduct themselves in a way that

maintains and boosts the public’s trust in the The Free Zone of Mauritius.

1. Relations with thirdparties
1. Independence
1. Avoidance of externalinfluence

In all external relations employees should support the commitment of the The Free Zone of Mauritius to act in accordance with the principle of independence. Accordingly, employees should not seek or take instructions from any organization or person outside the The Free Zone of Mauritius.

1. Negotiating prospective employment outside theThe Free Zone of Mauritius

Employees should behave with integrity and discretion vis-à-vis the The Free Zone of Mauritius regarding any negotiations concerning prospective employment and the acceptance of professional positions, in particular if such positions are taken with a financial institution. As soon as any such negotiations are under way or such a perspective exists, the employees concerned are expected to abstain from any matter that may relate to the prospective employer.

1. Gifts

Employees are strictly prohibited to solicit gifts or favors in connection with their duties at the The Free Zone of Mauritius. Employees are required to report any gift that may exceed the aforementioned amount to the Internal Audit Department, along with an estimation of the value of the gift. The gift may have to be turned in at the Internal Audit Department for an appraisal if there is a question about its value. The Internal Audit Department will advice the President on whether or not to return the gift to the sender. The final decision lies with the President.

1. Externalactivities

Employees may undertake non-remunerated and non-financial activities outside working hours in domains such as culture, science, education, sports, charity, religion, social work or other benevolent work. These activities are not meant to be exhaustive. However, remunerated activities outside working hours require prior approval in writing in accordance with the conditions of employment.

Employees are strongly advised to employ prudence and caution in any political activities so as to preserve the independence and neutrality of the The Free Zone of Mauritius. Carrying out political activities during working hours, using the facilities of the The Free Zone of Mauritius, or on its premises, are prohibited.

Employees may associate with academic societies and contribute to their material and scientific development. In particular, they may engage in research, deliver lectures, write articles or books or pursue any other similar activities involving a subject matter related to topics covered by their work. However, employees must clearly inform the public that such scientific or academic contributions are made in a personal capacity.

Employees shall neither solicit nor receive remuneration whether financial or of any other kind for any external activities carried out in the performance of their duties, unless duly authorized in writing to do so by the President.

3.2 Confidentiality

Professional secrecy, provided for in the conditions of employment and in all texts implementing them as well as in the different supervisory and other laws of which the execution is entrusted to the The Free Zone of Mauritius, requires the non-divulgence of confidential information obtained by the employees in the performance of their duties, either during employment or after its termination. The applicable laws, regulations, policies and conditions of employment in this area must be strictly adhered to by theemployees.

1. 3.3.Relations with thepublic
1. BasicPrinciples

Efficiency, correctness and courtesy should guide the employees in their relations with the public.

1. Dataprotection

Employees are prohibited from processing confidential data for non-legitimate purposes or for the transmission of such data to non-authorized persons. No confidential information or data may be transmitted to a third party without the permission of the Executive Committee.

1. Appeals

Employees should ensure that any administrative decision of theThe Free Zone of Mauritius contains an indication of the

options available to challenge the decision, as well as the competent appeal bodies and time-limits required for the exercise of such options.

1. In-houserelations
1. Loyalty andcooperation

The employees’ loyalty implies not only the fulfillment of the tasks entrusted to them by their superiors and compliance with the latters’ instructions and with the applicable reporting lines, but also assistance, advice, openness and transparency in all dealings with superiors and colleagues. In particular, employees should keep other concerned colleagues informed with regard to work in progress and enable them to contribute to it. Withholding information that may affect the conduct of business from superiors or colleagues, particularly in order to gain a personal advantage, providing false, inaccurate or exaggerated information, refusing to cooperate with colleagues or demonstrating any obstructive behavior would be contrary to the form of loyalty expected of employees.

Any communication should demonstrate due respect for the reporting channels. Instructions should be done in a clear and understandable manner, whenever orally or in writing.

1. Use of the The Free Zone of Mauritius resources

Employees should respect and protect the properties of the The Free Zone of Mauritius and not to allow third parties to make use of the The Free Zone of Mauricio services and/or facilities, unless this third party has been given approval for this use. All equipment and facilities, whatever their nature, are provided to the employees by the The Free Zone of Mauritius for official use only, unless private use is permitted either according to relevant internal rule or practices or on a discretionary basis.

Employees are also expected to take all reasonable and appropriate measures to limit the costs and expenses of the The Free Zone of Mauricio whenever possible, so that the available resources can be employed in the most efficient matter.

1. Implementation
1. Role of theemployees

Proper implementation of thisCode depends first and formoston the professionalism, consciousness, and common sense of theemployees.

In addition to the vigilance which employees in positions of authority are expected to demonstrate, they are also expected to behave in an exemplary fashion with regard to the adherence to the principles and rules laid down in this Code.

1. Questions on application of theCode

Employees who have any questions related to the application of the Code should in first instance direct their questions to the Manager of the Personnel and Organization Department. If necessary, the Manager of this department will consult with the President on the issues brought forward by the employees.

1. Distribution andfiling

A copy of this Code shall be distributed to each employee. It must be signed off by the employee as evidence that he/she has read the Code and will adhere to it. Subsequently, the signed off copy is sent to the Manager of the Personnel and Organization Department and will remain in the personnel file.

1. Reporting of perceived non-compliance with theCode

The employee who perceives non-compliance with the Code should report this to the Manager of Internal Audit Department in writing.

1. Sanctions

Failure to adhere to the Code may be grounds for disciplinary action by the The Free Zone of Mauritius, which may include termination of employment in the case of serious violations. Disciplinary action depends on the nature and seriousness of the violation and the employee’s prior record of conduct. Before disciplinary action is imposed, the employee will be given the opportunity to present his/her views on the alleged non- compliance with this Code.

Code.

1. Monitoring andcompliance

In case of non-compliance, the Manager of the Internal Audit Department will report to and advise the President on the measures to be taken to address this/these non- compliance issue(s).