CODE OF CONDUCT

Respecting The Code and applying them to our work every day.

As employees of SY Partners, we focus on doing the right thing upholding our shared commitment to complying with laws, regulations, and internal policies. Acting ethically is every employee's responsibility. This extends beyond our workday. Employees may be held accountable for actions, on or off the job, that could impair work performance or affect the company's reputation or business interests. We are accountable for being familiar with and following this Code and the Company's policies and guidelines. We understand that violations may result in discipline, up to and including termination of employment. The Code of Business Conduct forms a strong foundation for ethical business conduct, but it is not a substitute for good judgment and cannot address every situation we may encounter.

Being aware of reporting rights and responsibilities

We report when we observe a violation, or what we believe to be a violation of the law, this Code, Company policies or guidelines. We do not knowingly and willfully make false, fictitious statements or representations. To facilitate reporting, the Company maintains a number of reporting outlets, many of which allow anonymous reporting (where permitted by law):

   · Your supervisor or anyone else in your chain of command

   · Human resources department

   · Legal department

As supervisors, we demonstrate our personal commitment to the Company’s standards and foster an environment where employees feel comfortable asking questions and reporting issues. We also ensure our direct reports are aware of their obligations under the Code. We are alert to potential unlawful conduct in our department and take steps to prevent such conduct from occurring.

Cooperating with investigations and not retaliating

SY Partners investigates possible violations of the law, this Code, Company policies and guidelines, as well as any other behavior that we believe is unethical and/or could harm the Company, its employees, our property, or others. We cooperate fully with the company’s investigations.

SY Partners does not tolerate retaliation against those who seek advice, raise a question, or report suspected violations.

Doing the right thing without compromise

Ethics and integrity are foundational to all SY Partners’ people. Doing the right thing without compromise is our responsibility. We do the right thing for shareholders, customers, communities, suppliers, public authorities, and our fellow employees. They can trust that we do what we say.

Treating each other with respect and not permitting intimidation, discrimination, or harassment

SY Partners employees are protected from discrimination on the basis of race, color, religion, religious creed, national origin, ancestry, age, sex, sexual orientation, gender, physical disability, mental disability, medical condition, pregnancy, marital status, or any other characteristic protected by law. We must treat each other courteously and professionally. This extends beyond our workday. Employees may be held accountable for actions outside of work that could impair work performance or affect the company’s reputation or business interests.

Supporting an inclusive and diverse working environment

Differing viewpoints that we each bring to the workplace challenge us collectively to think more broadly and allow us to be more creative in the products and processes we develop. We respect and embrace those differences.

Creating a safe and secure place to work together

We are committed to providing a safe working environment. When public safety is at issue, we take reasonable precautions to safeguard the public, as well as our employees and customers. We follow laws, regulations, and practices related to the safety and health of the workplace. We do not tolerate or permit threats, violence, or other disruptive behavior in our work environments. We hold the personal information of our employees, retirees, and their beneficiaries in strict confidence.

 Working lawfully and in accordance with regulations that apply to us

We are diligent about following the laws and regulations that relate to our business. We do not expose the business to harm by failing to follow any rules that may apply to us. The Company’s policies and procedures support and clarify these laws and regulations and facilitate our compliance. We adjust our practices as appropriate to comply with the laws and requirements of our global markets and our diverse operations.

Managing records and information appropriately

We create, use, retain, and dispose of our business records and information carefully and in accordance with the policies on company’s records and information management. We follow instructions of the finance and legal department when records should be held for potential or pending litigation, investigations, or in response to court orders.

Following ethical sales practices

We earn and preserve our customers’ trust by treating them with honesty and integrity and in a professional, courteous manner. We deliver what we promise and do not provide goods or services that customers did not authorize.

Complying with global trade laws and regulations

We comply with all applicable international trade laws and regulations. These laws and regulations apply to the import and export of goods and services, such as hardware, software, and technology; sanctioned countries and restricted parties; and international boycotts. We consult the legal department before proceeding with any international transaction, shipment or import that may be covered by these laws.

Protecting confidential information that customers entrust to us

Confidential data which is entrusted to SY Partners will be treated as confidential and protected against disclosure to third parties. We follow laws and regulations to treat such data. Any inappropriate use of confidential customer information violates our customers’ trust and may also violate a law or regulation. SY Partners defend its own intellectual property rights whilst also respecting the intellectual property rights of other parties. We are bound to treat trade secrets and data as confidential. Preserving our customers’ trust by safeguarding their private data is critical.

Not engaging in any form of bribery

We follow ethical business practices in our dealings with public officials, other companies, and private citizens. We do not seek to influence them through any improper means, directly or indirectly. This includes unethical payments; inappropriate gifts, meals, or entertainment; or inappropriate political or charitable contributions. Such activity erodes our integrity and, in most cases, violates the law.

Supporting fair competition and complying with the antitrust laws

SY Partners succeeds in the marketplace by competing aggressively but fairly. Our products and services stand on their own merits. We do not misrepresent the characteristics of our products and services, and we do not deceive our customers or engage in any other unfair practices. We do not seek to eliminate or reduce competition through any illegal agreement with competitors.

Supporting community activities

We participate in activities to make our communities better places to live, work, and grow. We strengthen our communities by providing good jobs, donating our time and talents, supporting underserved populations, and promoting education programs that create economic opportunity.

Supporting environmental protection

We are committed to operate and to provide products and services in an environmentally responsible and sustainable manner. We follow applicable laws and regulations related to the environment. We strive to follow best practices and minimize our environmental impact in ways that are relevant to our business and important to the communities we serve.