Members of Victorum Capital Inc.’s Executive Board and the Board of Directors must act in the best interests of the company, not their personal interests. You may not pursue any personal interests when making decisions and are prohibited from engaging in competitive activities in the course of your job duties for Victorum Capital Inc. In addition, you may not use Victorum Capital Inc.’s facilities and resources for personal purposes.

Members of the Executive Board and employees shall not solicit or accept an improper benefit from third parties for themselves or for others, or provide an improper benefit to third parties as part of their job duties.

Each member of the Victorum Capital Inc.’s Executive Board must immediately report any conflicts of interest to the Supervisory Board and inform the other members of the Executive Board. All transactions between the company on the first part, and members of the Board and its affiliates or companies on the other, must comply with generally accepted industry standards.

Victorum Capital Inc. is represented by the CEO in transactions with the Board of Directors. At the same time, all significant transactions with affiliated persons, companies, or projects of a member of the Executive Board shall be carried out only with the consent of the Supervisory Board.

Members of the Executive Board may engage in incidental activities, such as having Supervisory Board powers outside of Victorum Capital Inc. only with the approval of the CEO.