# Code of Business Conduct and Ethics Datafalk Inc. and Parallax 84 SAS · Adopted by resolution of the Board of Directors of Datafalk Inc. and by decision of the President of Parallax 84 SAS · Effective date: 26 October 2026 ## 1. Purpose and scope This Code sets out the principles that govern how Datafalk Inc. and the companies of its group that adopt it (together, "Datafalk") do business. It applies to the directors, officers and employees of each adopting company, and to contractors and other persons acting on Datafalk's behalf through the compliance clause included in their contracts. Datafalk expects its suppliers, distributors and partners to uphold equivalent standards, according to the risk of each relationship. Where a law, a contract or a policy imposes a stricter requirement, the stricter requirement applies. ## 2. Compliance with laws Datafalk complies with the laws and regulations of every jurisdiction in which it operates, including anti-corruption, sanctions and export control, competition, data protection, intellectual property, employment and tax laws. Ignorance of the law is not an excuse; when in doubt, ask the Compliance Officer. ## 3. Honesty and integrity We deal honestly with our customers, suppliers, partners, competitors and authorities. We do not make claims about our products, our data or our security that we cannot substantiate. We do not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information or misrepresentation. ## 4. Anti-bribery and anti-corruption Datafalk prohibits bribery and corruption in all forms. The Anti-Bribery and Anti-Corruption Policy applies in full. ## 5. Conflicts of interest Datafalk Personnel act in the interest of Datafalk and disclose to the Compliance Officer, or to another director where the Compliance Officer is concerned, any situation in which a personal interest could conflict with it, including outside activities, investments in or employment by customers, suppliers or competitors, and family relationships with business partners, and abstain from the decision concerned. Business opportunities discovered in the course of work for Datafalk are offered to Datafalk first, in accordance with the fiduciary duties of directors and officers and the agreements in force. ## 6. Confidential information and data protection We protect Datafalk's confidential information and the confidential information entrusted to us by customers, partners and candidates, including the association between a customer's identity and its research, and use it only for the purpose for which it was provided. We process personal data lawfully, transparently and securely, in accordance with the Privacy Policy and applicable data protection law, and we respect the rights of the individuals who appear in our data. ## 7. Responsible data collection and artificial intelligence Datafalk's products are built from information collected from public sources and licensed datasets, processed with algorithms and artificial intelligence. We collect only what is lawfully accessible, we record the source and the permitted uses of each category of source, we do not bypass access controls, we do not extract special categories of personal data or data about the criminal history of individuals, and we provide a channel for corrections and objections. Public availability of information is not, by itself, permission to copy, republish or process it; the Public Data Collection Principles apply in full. We describe our outputs as what they are: sourced indications and inferences produced by automated processing, distinguishing source statements from inferences and never claiming a human review that did not take place. ## 8. Fair competition We compete on the merits of our products. We do not enter into agreements with competitors on prices, markets or customers, do not exchange competitively sensitive information with them, and do not obtain information about competitors through improper means. ## 9. Sanctions and export controls We do not do business with sanctioned persons or in embargoed territories, and we do not provide our Services for purposes prohibited by the export control or sanctions laws of the United States, the European Union, the United Kingdom or the United Nations, including through persons owned or controlled by sanctioned persons. Doubts about a restriction are referred to the Compliance Officer before proceeding. ## 10. People, human rights and workplace Datafalk respects internationally recognised human rights, including the principles of the United Nations Guiding Principles on Business and Human Rights and the core conventions of the International Labour Organization. We prohibit forced labour, child labour and human trafficking in our operations and expect the same of our suppliers. We provide a workplace free from discrimination and harassment, where people are treated with respect and selected and promoted on merit. ## 11. Company assets and records We use Datafalk's assets, systems and credentials for legitimate business purposes and protect them from loss, theft and misuse. We keep accurate books and records and never falsify a document, expense or report. ## 12. Security Every member of the team is responsible for the security of Datafalk's systems and data: strong authentication, least-privilege access, prompt reporting of incidents to security@datafalk.com, and compliance with Datafalk's security practices. ## 13. Communications Only authorised persons speak on behalf of Datafalk to the press, investors and the public. Personal use of social media must not disclose confidential information or purport to represent Datafalk. ## 14. Raising concerns and non-retaliation Anyone who becomes aware of a possible breach of this Code, of a policy or of the law may report it through the channels described in the Anti-Bribery and Anti-Corruption Policy, anonymously by post if preferred. Reports are handled confidentially and investigated promptly. Datafalk does not tolerate retaliation against anyone who raises a concern in good faith, and nothing in this Code prevents anyone from reporting to a public authority. ## 15. Administration The Board of Directors of Datafalk Inc. adopts this Code by resolution and is responsible for it; each other adopting company adopts it by decision of its legal representative. Any waiver of this Code for a director or officer requires the Board's approval and is disclosed as required by law. The Compliance Officer is Louis Ramard, Chief Executive Officer of Datafalk Inc.; matters concerning him are handled by another director. Every member of the team acknowledges this Code on joining and when it is updated, and the Compliance Officer records acknowledgements and training.