Core Values Ethics

Code of Business Conduct and Ethics

In performing their job duties, CraftLipi employees & business partners / associates should always act lawfully, ethically, and in the best interests of CraftLipi. This Code of Business Conduct and Ethics (the “Code of Conduct”) sets out basic guiding principles.

Employees & Business Partners / Associates who are unsure whether their conduct or the conduct of their co-workers & partners complies with the Code of Conduct should contact their manager or Higher Authority. Employees & Business Partners / Associates may also report any suspected noncompliance to the top-level authority or the partners of the company.

Compliance with Laws, Rules and Regulations

Employees & Business Partners / Associates must follow applicable laws, rules, and regulations at all times.

• Compliance with the law is mandatory for all associated with CraftLipi
• Questions about the applicability or interpretation of any law, rule, or regulation should be directed to the Legal Department

Conflicts of Interest

Employees & business partners are expected to use their judgment to act, at all times and in all ways, in the best interests of CraftLipi. A “conflict of interest” exists when an employee’s or business partner’s personal interest interferes with the best interests of CraftLipi.

A conflict of interest may occur when an employee, family member, or business associate receives a personal benefit as a result of their position with CraftLipi. Conflicts may also arise from business or personal relationships with customers, suppliers, competitors, business partners, or other employees that impair objective judgment.

• Receipt of gifts or services may create a conflict of interest
• The Legal Partner will maintain guidelines for disclosure of gifts or services received from customers, suppliers, competitors, or business partners
• Employees & Associates should avoid conflicts wherever possible
• Any actual or potential conflict must be promptly reported to the Higher Authority
• The Legal Partner will review the matter and determine corrective or mitigating action

Insider Trading Policy

Laws prohibit trading in securities by persons who have material information that is not generally known or available to the public.

• Employees / Associates may not trade in stock or securities while in possession of material non-public information
• Material non-public information must not be passed to others or used to recommend trading
• The Company has adopted guidelines to implement this policy
• All employees / Associates / Partners must follow the CraftLipi Insider Trading Guidelines
• Certain individuals must comply with trading windows and/or preclearance requirements when trading CraftLipi.com securities

Discrimination and Harassment

CraftLipi provides equal opportunity in all aspects of employment and will not tolerate illegal discrimination or harassment of any kind.

Employment decisions at CraftLipi are based on merit, qualification, attitude, and abilities. This policy governs selection, job assignment, compensation, discipline, termination, and access to benefits and training.

• Employees with concerns regarding discrimination should report to the Higher Authority / Business Owners
• Anyone engaging in unlawful discrimination may face disciplinary action, including termination

Health and Safety

CraftLipi provides a clean, safe, and healthy work environment. Each employee & Associate is responsible for maintaining workplace safety.

• Follow safety and health rules and practices
• Report accidents, injuries, unsafe conditions, procedures, or behaviors
• Violence and threatening behavior are not permitted
• Employees must report to work fit for duty and free from the influence of illegal drugs or alcohol

Price Fixing

Employees & Associates may not discuss prices or make any formal or informal agreement with competitors regarding prices, discounts, business terms, or market segments where such actions would violate antitrust laws.

• Any activity inconsistent with competition laws is prohibited
• Questions regarding this section should be directed to the Higher Authority

Bribery; Payments to Government Personnel

Employees, Associates, and Business Partners must not bribe anyone for any reason, whether in dealings with governments or the private sector.

• Laws prohibit offering or giving anything of value to government officials to obtain or retain business
• Illegal payments must not be made directly or through third parties
• Guidance must be sought from the Legal Partner when dealing with government officials

Recordkeeping, Reporting, and Financial Integrity

CraftLipi’s books, records, accounts, and financial statements must be maintained accurately and in appropriate detail.

• Records must properly reflect company transactions
• All records must conform to applicable laws and internal control systems
• Public financial reports must contain full, fair, accurate, timely, and understandable disclosure
• Employees / Associates must cooperate with internal financial, accounting, and legal procedures

Questions; Reporting Violations

Employees / Associates should speak with their management chain or the Legal Partner if they have questions about this Code or proper conduct.

• Retaliation against individuals reporting misconduct in good faith is not permitted
• Employees must cooperate in internal investigations
• Violations of the Code may result in disciplinary action, including discharge

Owners / Managing Partner / Partners

CraftLipi’s Managing Partners & Partners must comply with the relevant provisions of this Code of Conduct, including conflicts of interest, insider trading, and compliance with all applicable laws, rules, and regulations in their service to the Company.