CODE OF ETHICS

This Code of Ethics sets out our expectations on how our company’s employees or representatives will conduct business in accordance with the law, our policies, our values and our business-ethics principles. We expect our customers, suppliers, vendors, contractors and partners to mirror and/or adapt ethics and compliance standards that are consistent with our values in all material respects. This Code of Ethics automatically applies where everwise provides advisory and educational services.

Integrity

At every level, experts providing services on behalf of everwise are expected to be honest, trustworthy, and straightforward in both personal and business dealings, in accordance with both the letter and the spirit of all applicable laws and regulations.

Transparency

We will agree independently and in advance on the basis for our fees and expenses and will charge fees and expenses that we consider reasonable, legitimate, and commensurate with the services we deliver and the responsibility we accept.

Confidentiality and Data privacy

Safeguarding confidential information is fundamental to the services everwise provides. everwise is committed to protecting confidential and personal data including those of everwise clients and third parties, and to continually monitor legal requirements to support compliance. Client confidential information is all non-public information (regardless of whether confidential information is received verbally, on paper, in an email, or in any other form), including business plans and intellectual property of any nature, client names, the nature of our client services, our recommendations or advice, client data, and information we purchase at our clients’ expense. We keep client information and records of client engagements confidential and use proprietary client information only with the client’s permission. We only share client confidential information with colleagues within everwise and contractors, and employees and contractors of affiliated companies, if any, who need to know such confidential information, who have been informed of the confidential nature of such information, and who are obligated to keep such information strictly confidential. Confidentiality will remain during but also after the completion of the Services. You will find further information on our privacy commitments in our Privacy Notice.

Independence

We do not allow conflict of interest, or undue influence of others to override our objective professional or business judgments. Therefore, we check potential conflicts of interest before entering into new advisory services and we regularly monitor our client’s situation to make sure conflicts of interest are at all time avoided. We will not allow conflicts of interest which provide a competitive advantage to one client through our use of confidential information from another client who is a direct competitor without that competitor’s permission. We will immediately acknowledge any influences on our objectivity to our clients and will offer to withdraw from a consulting engagement when our objectivity or integrity may be impaired.

Quality

We are committed to delivering the highest quality services to the best of our ability to all our clients. We hold our experts accountable for this standard of quality. Internal processes are in place to ensure that we bring our best capabilities to every client mandate. We only accept engagements for which we consider we are qualified by our experience and competence. Staff and experts are assigned to client engagements in accordance with their experience, knowledge, and expertise. When necessary, we partner with external highly qualified experts and engage individual advisors to bring the best to our clients. Although everwise cannot be held responsible for third-party service providers, we do our utmost to only work with third-party providers that meet our own and our client’s highest expectations in terms of experience and competence. We also only engage external providers that share the same fundamental principles and values as everwise

Social and environmental responsibility

We take into consideration the social and environmental impact of our activities in our corporate decisions. This strong commitment is part of the everwise DNA and is reflected in the everwise articles of association. We fully adhere to all applicable human rights laws and applicable anti-corruption and anti-bribery regulations. We consistently address these key considerations in the advice and trainings we provide, to aid our clients in acting in a manner that is always consistent with the prevailing laws and regulations. We are also mindful of social responsibility and the potential impact of our recommendations on shareholders, employees, customers, and other stakeholders. In doing so, we strongly believe that we support our client in a holistic manner as they capitalise on new opportunities and as they assess and then manage risk to deliver responsible growth.

Internal and external stakeholders can contact us at contact@everwise.ch to communicate any business ethics-related concerns or seek guidance on their inquiries.

Version – January 2023