Brand Atlas Code of Ethics

All employees of the Company, are required to comply with our code of ethics presented below. Their responsibility also includes helping to create and maintain a culture of high ethical standards and an overall commitment to compliance with local laws and Company policy. Directors and officers of the Company are also expected to promote an environment that encourages employees and professionals to raise concerns relating to unethical behaviour.

Each person agrees that he or she will:

1. Act with honesty and integrity in all matters.

2. Act in a manner that will not discredit the Company.

3. Represent the Company and carry out the Company’s business in accordance with the highest ethical standards.

4. Comply at all times with the laws, rules and regulations that govern the conduct of the Company’s business regardless of where the business is being performed.

5. Comply at all times with Company policies, guidelines and procedures.

6. Ensure that all of the activities undertaken are free from conflict of interest between you and the Company, customer or supplier. If a conflict of interest exists, or if there is a potential perceived conflict of interest, such conflict should be immediately disclosed.

7. Not to accept or offer anything of value that could be described as an inducement or which could impair your judgement in making a decision that is in the best interest of the client or the Company.

8. Maintain the confidentiality of all information that you become privy to in connection with the Company or client’s business, except when disclosure is required or legally mandated. Confidential information includes all non-public information that may prejudice the ability of the Company to pursue certain objectives, be of use to competitors or be harmful to the Company, its supplies or its clients, if disclosed.

9. Not use the Company’s confidential and proprietary information for personal gain or to the detriment of the Company’s competitive position.

10. Understand and comply with applicable Privacy Laws.

11. Protect the Company’s assets and resources and help ensure that they are used only for the Company’s legitimate purposes.

For those employees that have financial reporting responsibilities:

1. Ensure full, fair, accurate and timely disclosure of information in reports and / or statements that are filed with all regulatory bodies.

It is the responsibility of every employee and professional to report any deviation from this Code of Conduct and Ethics to their supervisor, manager or a member of the Company’s senior management team.