Company

Code of Ethics:

To ensure complete and accurate financial records and reporting, the Company's Chief Executive Officer, Chief Financial Officer, Chief Accounting Officer and all Finance employees will:

• Act with honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional
relationships.

• Proactively promote and be an example of ethical behavior in the work environment and community.

• Provide constituents with information that is accurate, complete, objective, relevant, timely and understandable.

• Comply with rules and regulations of federal, state, provincial and local governments, and other appropriate private
and public regulatory agencies.

• Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or
allowing one's independent judgment to be subordinated.

• Respect the confidentiality of information acquired in the course of one's work except when authorized or otherwise
legally obligated to disclose. Confidential information acquired in the course of one's work shall not be used for
personal advantage.

• Share knowledge and maintain skills important and relevant to constituents' needs.

• Achieve responsible use of and control over all assets and resources employed or entrusted.

• Demand compliance with this Code by subordinates.

• Report known or suspected violations of this Code in accordance with the Company's Whistleblower Policy and Procedures or Code of Conduct.

Violations of this Code, including failure to report potential violations by others, will be viewed as a serious disciplinary matter that may result in disciplinary action, up to and including termination of employment.

This Code of Ethics is complementary, and does not replace responsibilities all employees have as outlined in Sober Ray Technologies MNC Pvt. Ltd. Code of Conduct and other Company policies.