Integrity Code of Hakrinbank N.V.

A good reputation is vital for a bank. A bank can only properly fulfill its role as a financial service provider in society if its customers, shareholders, employees, and all other parties with which it deals have confidence in it.

Rules are laid down in the integrity code that apply to all employees of the Bank. They reflect standards and values that we must adhere to. Every employee is expected to act according to the letter and spirit of all the rules.

Each of us has a duty to protect our good reputation by acting professionally and with integrity.

This code is based on the following principles.

1. Reliability

   Integrity is the highest standard we must meet.
   We respect laws and regulations and abide by them consistently.
   We take internal measures to prevent our services from being misused.
   We build solid and lasting relationships with all our stakeholders through open dialogue and respectful actions.

2. Customer focus

   We put our customers at the center of everything we do.
   We are personally involved, and are committed to maximum satisfaction in a creative and professional manner.
   We listen and understand, and continuously strive for improved and differentiating solutions.

3. Quality

   We always maintain only the highest standard of professionalism.
   We are aware that exceptional quality of our employees can give us an important competitive advantage.
   Continuous training and self-evalwwwion are a prerequisite for providing expert advice.

4. Teamwork

   To be committed to achieving results in concert with others, and thereby contributing to a common goal. Thinking and acting on the basis of common interests.

These four principles, reliability, customer focus, quality, and teamwork, form the fundamental values and standards of our company; our core values, and give direction to everything we do as a bank. Derived from these principles are the following rules of conduct, which must be strictly observed.

Rules of Conduct

1. Every employee must abide by laws and regulations, and applicable procedures, and must refrain from conduct that undermines the integrity of the Bank.
2. Casino visits by employees are prohibited.
3. We do not provide services for persons if we know or reasonably suspect that the funds offered originate from crime, or that funds from Borrowing will be used for that purpose. If such a case threatens to occur, the employee must immediately inform the head of department, or the compliance officer.
4. We do not participate in any actions that are aimed at escaping control by the competent authority of funds offered.
5. Every employee shall avoid transactions that could lead to or create the impression of a conflict of private and professional interests.
6. We do not accept gifts that are more than a usual business gift. In this way, we avoid the appearance of bribery or influence.
7. We do not use any information advantage that we have by virtue of our position.
8. We do not accept (un)paid additional positions if they could lead to a potential conflict of interest.
9. Each employee must act diligently, in good faith, and responsibly, when providing services.
10. We treat personal and financial information confidentially. Information shall not be provided to third parties unless there is a legal or regulatory obligation to do so.
11. We communicate honestly and transparently with our customers.
12. Every employee observes the rules of decency and courtesy when communicating with internal and external relations of the bank, and shall not be guilty of discrimination of any kind.
13. We ensure an optimal working climate towards each other as employees, strive for good mutual communication and cooperation, and exchange knowledge and experience from practice.
14. Bank property should only be used for business purposes.

It is virtually impossible to establish rules that, in all cases that arise in practice, provide a clear answer to the question of how to act in a specific case. That will apply particularly when there are no procedures, instructions, or precedents for that particular case. In all these cases, please consult your Department Manager or the Compliance Officer, also in the event that you have any questions about this Code.