Code of Conduct and Ethics

At Shub Connect, we are revolutionizing the way Nigerian students and young professionals access flexible work opportunities. Our success isn’t just measured by the secure platform we build, but by how we build it. It demands more than technical skill — it requires unwavering integrity from every one of us. This Code of Conduct and Ethics is a living document that defines our shared commitment to transparency, trust, empowerment, inclusion, and innovation. It reflects our core values and sets the ethical bar for every decision we make, every transaction we process, and every interaction we have — whether internal or external. We are responsible for upholding this Code. We succeed together by always choosing the ethical path. If you are ever in doubt, remember: Ask Questions. Speak Up. Protect Our Culture.

This Code outlines the standards of ethical conduct expected of all Shub Connect employees, directors, officers, contractors, consultants, and vendors. It helps us navigate situations where the right course of action may not be obvious, ensuring we comply with the law and uphold our reputation.

The Code applies to everyone who represents Shub Connect, including full‑time, part‑time, and temporary employees, board members, consultants, contractors, and vendors. Failure to follow the Code or other company policies can result in disciplinary action, up to and including termination of employment or contract.

Mission: We empower Nigerian job seekers, by providing immediate, flexible work opportunities, fostering professional development, and promoting financial independence through a secure, integrated income platform.

Vision: To be the platform of choice for flexible work opportunities in Nigeria. Core Values: Our values are the engine of Shub Connect. They guide our business strategy and daily behaviour:

1. Transparency & Trust – We are open in our communication and accountable (Accountability) for our actions. Trust is the currency of our platform and our internal team.

2. Empowerment – We provide tools, resources, and flexible schedules that empower our users and employees to succeed.

3. Inclusion – We cultivate a collaborative ecosystem where everyone from employees to partners to job seekers feels valued, respected, and heard.

4. Innovation – We push the boundaries of fintech and HR technology to meet the evolving needs of the Nigerian market.

Every day, we make decisions on behalf of the Company and the communities we serve. Most choices are straightforward, but some carry ethical weight.

When in doubt, ask yourself:

1. Is it legal? Does it comply with all applicable laws and regulations, including the Nigerian Labour Act, the Companies and Allied Matters Act (CAMA), data protection legislation, anti‑corruption statutes, and any other relevant local or international laws?

2. Is it fair? Is the action balanced and fair to our customers, community, partners, and colleagues? Does it respect human rights and equality?

3. Is it transparent? Would you be comfortable if your decision was reported on the front page of a major Nigerian newspaper or shared on social media?

4. Is it consistent with our values? Does it honour our commitments to transparency, trust, empowerment, inclusion, and innovation?

If the answer to any of these questions is no or unclear, stop and seek guidance. Speak to your manager, Human Resources, the Legal & Compliance team, or use the Ethics Hotline (contact details in the Resources section). Document your concern, the advice received, and the final decision.

We celebrate differences in background, perspective, and experience. Employment decisions at Shub Connect are based solely on qualifications, performance, merit, and business needs. We comply with anti‑discrimination provisions under the Nigerian Labour Act and strive to meet or exceed international best practices. Discrimination based on race, gender, religion, nationality, disability, or any other legally protected characteristic is strictly prohibited.

We are committed to fostering a workplace that reflects the diversity of the communities we serve. Every individual has a right to feel welcomed and respected. Managers should encourage open dialogue, celebrate diversity, and address any behaviour that undermines our inclusive environment.

Hiring, promotion, compensation, training, and termination decisions must be based on objective criteria. We do not tolerate retaliation against anyone who files a complaint of discrimination or participates in an investigation. Our performance management processes must be transparent and free from bias. If you experience or witness discrimination or retaliation, contact Human Resources or the Ethics Hotline.

We prohibit harassment, bullying, and violence in any form. Harassment includes unwelcome conduct—verbal, physical, or visual—that creates an intimidating, hostile, or offensive work environment, including sexual harassment. Bullying includes repeated aggressive or intimidating behaviour. Violence includes threats or acts of physical aggression. If you experience or witness any form of ©2025 SHUB Connect Ltd. All rights reserved. harassment or violence, report it immediately to Human Resources or the Ethics Hotline.

We have a duty of care under Nigerian law to provide a safe work environment. Team members must follow all health and safety policies and report hazards or incidents promptly. Safety extends to our remote and hybrid workforce: those working from home or on client sites must ensure that their environment is safe and compliant with the Company’s policies.

Shub Connect is committed to workplace security. Do not bring weapons into the company premises. Follow security protocols to prevent unauthorised access to facilities or information systems.

We treat one another with dignity and respect. Managers should lead by example, listen with an open mind, and prevent retaliation against anyone who raises a concern in good faith. We encourage honest feedback and provide avenues for constructive discussion. When disagreements arise, address them professionally and seek mediation if necessary.

Conflicts of interest arise when personal relationships or interests could interfere with your professional judgment or actions on behalf of Shub Connect. Examples include:

• Having a financial interest in a competitor, supplier, or vendor.

• Hiring or supervising a close relative or significant other (nepotism).

• Accepting excessive gifts or favours that could influence decision‑making.

• Using company resources or information for personal gain.

Disclose any actual or potential conflicts to Legal & Compliance or Human Resources. Managers must recuse themselves from hiring or performance decisions involving a person with whom they have a close personal relationship.

Confidential information includes pricing, customer lists, financial data, strategic plans, proprietary software, and personal data about employees, customers, and partners. We must protect confidential information belonging to Shub Connect and third parties.

Under the Nigeria Data Protection Regulation (NDPR) and the Nigeria Data Protection Act 2023, personal data may only be collected for specific, legitimate, and lawful purposes and must be processed securely. Employees must:

• Collect only the data necessary for business purposes.

• Use company–approved systems and ensure devices are password‑protected and encrypted;

• Obtain consent where required and respect data‑subjects’ rights;

• Retain data only as long as necessary and dispose of it securely.

• Refrain from disclosing confidential information without authorisation.

If you suspect a data breach, report it immediately to the Legal & Compliance team.

Company assets — physical, financial, digital, and intellectual — must be used responsibly and solely for legitimate business purposes. This includes laptops, phones, funds, software, and proprietary information. Fraud or misappropriation of company funds will result in disciplinary action and may lead to criminal prosecution.

All work created in the course of your employment or engagement — including code, designs, documentation, research, marketing material, and ©2025 SHUB Connect Ltd. All rights reserved. platform configurations — is the property of Shub Connect. Do not use company information or opportunities for personal gain, and do not incorporate unlicensed third‑party software or content into company products.

Maintaining accurate records is essential for building trust with regulators, investors, and stakeholders. We record transactions promptly and accurately in accordance with generally accepted accounting principles. We do not create false or misleading entries or disguise the nature of a transaction. We comply with all laws relating to tax, corporate filings, and financial reporting.

Only authorised personnel may speak on behalf of Shub Connect to investors, analysts, or the media. When producing reports or communicating financial information, ensure that data is complete, truthful, and presented in a fair and understandable manner. If you become aware of inaccurate or misleading records, report it promptly.

We obey all applicable Nigerian and international laws. Key legislation includes, but is not limited to:

• Nigerian Labour Act – Governing employment standards, wages, hours of work, rest periods, and terms of service;

• Companies and Allied Matters Act (CAMA) – Governing corporate governance, directors’ duties, and reporting obligations;

• NDPR/NDPA – Governing the collection, processing, and storage of personal data;

• Economic and Financial Crimes Commission (EFCC) Act, Money Laundering (Prohibition) Act – Addressing money laundering, terrorism financing, and ©2025 SHUB Connect Ltd. All rights reserved. corruption;

• Investment and Securities Act – Governing securities trading and prohibiting insider trading;

• Other local or international regulations relevant to our business operations.

When laws or company policies conflict, always follow the stricter standard. Seek advice from the Legal & Compliance team if uncertain.

Our platform impacts the livelihood of thousands of people. We must design, build, and maintain our systems responsibly, ensuring they are secure, reliable, and aligned with ethical principles. Do not deploy or permit the use of technologies that violate data protection laws or ethical standards. Test and evaluate systems for bias, discrimination, and unintended consequences.

Communications—whether in person, via email, or on social media—reflect on Shub Connect. When discussing the company externally, identify that your views are personal and do not speak for the company unless authorised. Do not post confidential, proprietary, or non‑public information about Shub Connect, our partners, or customers on social media.

Only designated individuals may speak to the media on behalf of Shub Connect. If a journalist or analyst contacts you, refer them to the Corporate Communications team.

We compete vigorously, honestly, and fairly. We sell our products and services based on their merits and the value they create for customers. We do not engage in anti‑competitive practices such as price‑fixing, bid‑rigging, market allocation, or collusion with competitors. We comply with Nigerian competition law and any applicable international antitrust laws. Never discuss commercially sensitive information—such as pricing, production levels, or customer lists—with competitors. If you have questions, contact the Legal & Compliance team.

We are committed to preventing our platform from being used to launder money or finance terrorism. We follow robust KYC and due diligence procedures and screen customers, partners, and transactions against sanctions lists. Team members must adhere to internal processes for identifying and reporting suspicious transactions. Non‑compliance with anti‑money laundering (AML) and counter‑terrorist financing (CTF) laws can result in severe penalties.

If you become aware of unusual or suspicious activities, report them immediately to the Compliance Officer. Refer to our Anti‑Money Laundering & Sanctions Policy for detailed requirements.

We have zero tolerance for bribery and corruption. We follow the EFCC Act, Independent Corrupt Practices Commission (ICPC) Act, and other Nigerian laws, as well as international standards like the U.S. Foreign Corrupt Practices Act (FCPA) and UK Bribery Act. We do not offer or accept bribes, facilitation payments, or kickbacks to obtain business or any improper advantage.

Gifts and hospitality must never influence or appear to influence business decisions. Acceptable gifts are infrequent, modest, and consistent with local law and custom (e.g., small promotional items). Gifts of cash or cash equivalents (such as gift cards or personal loans) are strictly prohibited. Business meals and entertainment must have a legitimate business purpose and remain reasonable in cost and frequency. Providing anything of value to a public official is governed by strict anti‑corruption laws. Never give gifts or hospitality to public officials without prior written approval from the Legal & Compliance department.

Occasional, modest gifts or hospitality may be appropriate to build relationships and promote goodwill. However, gifts or entertainment must:

1. Be reasonable in value and frequency and in line with local custom and SHUB Connect’s values;

2. Be offered transparently and openly, without intent to influence a business decision or obtain improper advantage;

3. Be recorded accurately in expense records; and

4. Not be in cash or cash equivalents (e.g., gift cards, vouchers).

Employees must seek prior approval from the Compliance Officer before giving or receiving gifts or entertainment above a threshold determined by the Company. Under no circumstances should gifts or hospitality be offered to public officers without the prior written consent of the Compliance Officer.

The following are prohibited:

➔ Cash, cash equivalents or personal loans;

➔ Gifts, hospitality or entertainment that could be perceived as lavish or excessive;

➔ Any gift during a procurement or contract evaluation process;

➔ Gifts to family members or friends of a business contact that may indirectly influence the contact’s decisions.

Employees must avoid situations in which their personal interests conflict with those of Shub Connect. Outside employment or business interests must not compromise job performance or create competing obligations. If you plan to engage in outside work, obtain written approval from your ©2025 SHUB Connect Ltd. All rights reserved. manager and the Legal & Compliance team. Personal relationships with employees, suppliers, or clients must be disclosed and managed to avoid conflicts. All corporate opportunities discovered through your role at Shub Connect must first be offered to the Company.

During your work at Shub Connect, you may become aware of non‑public, price‑sensitive information about the Company or our partners. Insider trading—buying or selling securities based on material non‑public information—violates the Investment and Securities Act and company policy. Do not buy, sell, or recommend trades in Shub Connect securities or the securities of other companies based on inside information. Do not disclose such information to others (tipping). Consult the Insider Trading Policy for guidance.

When engaging in cross‑border business, we comply with international trade laws, export controls, and sanctions regimes. We conduct business only with countries and third parties that comply with trade regulations and are not subject to sanctions. Consult the Legal & Compliance team before exporting goods, software, data, or services across borders, or if asked to participate in a boycott.

We recognise our responsibility to improve the communities where we operate. Through the Shub Connect Foundation, we support initiatives in education, youth employment, and entrepreneurship across Nigeria. Our platform and resources are leveraged to create social impact and support local charities. We encourage employees to volunteer their time and skills.

We are committed to operating sustainably and minimising our environmental footprint. We encourage recycling, energy efficiency, and responsible procurement. When selecting suppliers and partners, we seek to ensure they share our commitment to environmental and social responsibility. Our carbon footprint may be small compared with manufacturing industries, but we strive to limit our emissions and resource usage. The Company will report on sustainability efforts and set goals to reduce its environmental impact.

We uphold human rights in all aspects of our business. We condemn child labour, forced labour, human trafficking, and any form of sexual exploitation. We align our operations with the

and local labour laws. We ensure fair wages, safe working conditions, and respect for freedom of association. We expect our suppliers, partners, and vendors to adhere to the same standards. If you become aware of human rights abuses linked to our business or supply chain, report them immediately.

You have several options for asking questions, raising concerns, or reporting potential misconduct. Choose the one most comfortable for you: Contact HR: askhr@shubconnect.com

Reports will be handled promptly and discreetly. Anonymous reporting is permitted. Confidentiality will be maintained to the greatest extent possible consistent with the law. Retaliation against anyone who reports a concern in good faith is strictly prohibited and may result in disciplinary action.

A waiver of any provision of this Code for executive officers or directors may only be granted by the Board of Directors or its designated committee and will be disclosed as required by law. Waivers for other employees must be approved by the Legal & Compliance department.

Shub Connect may amend this Code to reflect changes in laws, regulations, or business operations. Employees will be notified of significant changes. It is your responsibility to read, understand, and comply with updated policies. ©2025 SHUB Connect Ltd. All rights reserved.