Employees of the Company are strictly prohibited from trading in the Company's shares or other securities while in possession of material, non-public information. Likewise, if an employee acquires material, non-public information about another company through their role, they are not permitted to trade in that company's securities or assist others in doing so based on that information.

Engaging in insider trading is a serious legal offense and may lead to substantial fines, criminal charges, and disciplinary action by the Company, which may include termination of employment.

Information is considered non-public if it has not been broadly disclosed to the public through official channels such as press releases or other widely distributed communications.

MicroFix Integrated Solutions primarily serves clients within Nigeria. In the course of its operations, the Company strictly refrains from engaging in any business activities that are restricted or prohibited under Nigerian laws and trade regulations.

The Company is committed to complying with all relevant legal frameworks within Nigerian civil and trade laws, import-export regulations and environmental regulations of applicable jurisdictions. Employees are expected to understand and adhere to these legal requirements while performing their duties.

At all times, the Company upholds internal standards that may exceed the minimum requirements of applicable laws. Employees are required to operate within the Company's ethical boundaries even in cases where certain actions may be legally permissible but do not align with the Company's values.

Conversely, if a situation arises where the Company practices may appear permissible under internal guidelines but are restricted by local laws in a specific region, employees must prioritize compliance with the law over Company directives.

Because the Company operates within Nigeria, employees may be subject to the laws of multiple states and jurisdictions. In the event of a conflict between the Code of Conduct and applicable law, the law will take precedence. As MicroFix Integrated Solutions is incorporated in Nigeria, employees are often subject to Nigerian laws. Additionally, laws of other states may have extraterritorial reach and apply to Company activities and personnel.

If there is any uncertainty about which laws apply or if potential legal conflicts arise, employees are strongly advised to consult with the Company's legal counsel legal@microfix.com.ng before taking any action.

MicroFix Integrated Solutions firmly opposes the use of child labor and believes that its long-term eradication serves the best interests of children. However, any efforts to eliminate child labor must be carried out in a way that prioritizes and protects the well-being of the affected children.

Given the scope of our operations, employees may occasionally engage with government officials in various states. As a general rule, no employee should offer or promise anything of value either directly or indirectly to any government official in exchange for favorable treatment. Prior approval from the Company's legal counsel legal@microfix.com.ng must be obtained before offering any gift, payment, or benefit to a government official. Additionally, all such transactions must be accurately and transparently recorded in the Company's financial records.

Bribery of government officials is a criminal offense in Nigeria, with serious consequences such as substantial fines for both individuals and organizations, and potential imprisonment. A bribe involves offering or providing anything of value to a government official with the intent to influence a discretionary decision. This may include payments intended to secure or retain business, influence the outcome of an audit or inspection, or sway decisions on tax or regulatory matters. In some jurisdictions, even seemingly minor payments to officials may be considered bribes. Therefore, employees must seek prior approval from the Company's legal counsel legal@microfix.com.ng before making any such payments.

The Company is required to comply with all trade sanctions and restrictions imposed by the government of the Federal Republic of Nigeria. These regulations prohibit engaging in business with certain individuals or entities, particularly those linked to terrorism, narcotics trafficking, or other illegal activities. Failure to comply may lead to serious consequences, including substantial fines, imprisonment of responsible individuals, and disqualification from future trade opportunities. Furthermore, the Company must adhere to Nigeria's anti-boycott laws, which restrict involvement in any boycott not officially authorized by the Nigerian government.

The Company prohibits employees from registering with or engaging in work through freelancing platforms or job-providing agencies. Such involvement may lead to a conflict of interest and could result in disciplinary action. Employees who are currently registered with such platforms are required to terminate their memberships immediately. For further guidance, please contact the Human Resources hr@microfix.com.ng.

Exchanging gifts is a customary practice in business and can help foster positive relationships with clients and partners. However, any gift or entertainment offered or received must not, and must not appear to, influence your judgment or compromise your ability to make fair and objective business decisions on behalf of the Company.

Gifts or entertainment should only be exchanged with clients, customers, suppliers, or colleagues if they cannot be reasonably perceived as a bribe or reward for a specific business outcome. Personal gifts of modest value may be accepted or given on recognized occasions such as graduations, promotions, new jobs, weddings, retirements, or holidays.

Acceptable entertainment may include meals or event tickets that are typically extended to others in similar business relationships. When hosting staff for meals or entertainment, the senior employee or Human Resources should cover the expense initially and then seek reimbursement with proper authorization from their supervisor.

The Company generally discourages employees from accepting gifts from clients. However, in exceptional circumstances, such as when gifts are given as tokens of appreciation, recognition of performance, or in support of employee-related events, acceptance may be permitted especially if the event is co-branded with MicroFix Integrated Solutions. Such instances require prior approval from a supervisor or management.

Any further exceptions must be approved by the CEO/MD, who will evaluate requests based on factors such as the potential to enhance client relationships, boost employee morale, and ensure alignment with the Company's values and mission. Approval will only be granted if it is determined that the gift will not compromise the integrity or ethics of the Company.

From time to time, employees may choose to collectively contribute funds to present a gift to a colleague, supervisor, or subordinate. Such contributions are allowed and the occasion falls under one of the following categories:

• Farewell gift


• Birthday celebration


• Wedding gift


• Any other occasion the team wishes to commemorate

Employees are permitted to contribute funds toward social causes. All such contributions must be made through the Company's centralized process and managed under the supervision of a designated body appointed by management. The approved amount and purpose for such contributions will be determined by the Company. Contributions may be made for the following purposes:

• Company-approved projects


• Crises formally declared by the Company


• Medical emergencies


• Any other occasion approved by the Company

Employees must never be coerced into contributing money toward a collective cause. Participation is strictly voluntary, and no employee should face retaliation or negative judgment for choosing not to contribute. Additionally, care must be taken to ensure that gifts or entertainment are not perceived as bribes, kickbacks, or other improper payments under the laws of any states where the Company conducts business.

Gifts presented to clients and vendors must align with the Company's legitimate business objectives and should be modest, appropriate, and suitable for the occasion. Employees must remain mindful of the gift, meal, and entertainment policies of our clients and suppliers. Under no circumstances should Company shares or stock be given as a gift on behalf of the Company.

If a client, customer, or supplier invites you to an event that involves out-of-town travel, an overnight stay, or a high-value occasion, you must first consult your manager to assess whether there is a valid business justification for your participation. If deemed appropriate, the Company should cover the associated travel and event costs. Personal gifts from clients or vendors should generally not be accepted unless they are extended to a larger group of employees. Similarly, the use of personal vacation properties or private aircraft for individual benefit is not permitted.

Employees are expected to prioritize and promote the interests of the Company whenever an opportunity arises. If you become aware of a potential business opportunity through Company resources, confidential information, or your role within the organization, you must first offer that opportunity to the Company before considering it for personal benefit. Using Company assets, information, or your position for personal advantage is strictly prohibited, as is engaging in any activity that competes with the Company. If you wish to explore such an opportunity, you must fully disclose its details to your supervisor, who will consult with the relevant management or authority to determine if the Company intends to pursue it.

The Company recognizes that our progress to date has been made possible by our unwavering commitment to strong principles. We have never compromised our values for the sake of profit and we never will.

During your employment with the Company, you will have access to various types of confidential information. This includes internally generated business data as well as sensitive information obtained from external sources, such as details about other companies or their securities. Confidential information encompasses all non-public content that could benefit competitors or potentially harm the Company or its clients if disclosed. This may include, but is not limited to, financial, technical, or operational data; concepts; methodologies; reports; trade secrets; intellectual property; employee, vendor, or customer information; and any related materials regardless of format (documentary, digital, verbal, etc.). To ensure the confidentiality and integrity of such information, you may be required to sign a Non-Disclosure Agreement (NDA) when necessary.

Maintaining the accuracy of all Company business and financial records is essential. These records extend beyond just financial accounts and include items such as payroll, project documentation, reports, time-sheets, expense claims, emails, accounting data, performance metrics, electronic files, and any other records generated during normal business operations. This also covers submissions like benefit claims and resumes.

Ensuring the completeness and accuracy of these records is a shared responsibility not solely that of Human Resources, Finance, or Accounting. Every employee must understand and adhere to the Company's record-keeping policies. If you're unsure about any aspect, consult your supervisor for guidance. Maintaining accurate records not only upholds the Company's credibility and reputation but also ensures compliance with legal and regulatory requirements.

Employees must refrain from engaging in personal activities during work hours that could interfere with or hinder the performance of their job duties. Company systems, including computers and equipment, are to be used strictly for business purposes and should never be utilized for external business ventures or for engaging in illegal or inappropriate activities such as gambling, accessing pornography, or any other offensive content. Please also refer to the MicroFix Integrated Solutions Employee Handbook for additional guidance. It is important to protect Company assets and use them solely for their intended purposes.

Employees should understand that Company property encompasses all data and communications sent, received, or stored on the Company's electronic and telephonic systems. This includes all written communications. Where legally permitted, the Company reserves the right to monitor these systems, and such communications may be subject to disclosure to law enforcement or regulatory bodies.

Theft of Company property whether physical (such as unauthorized removal of products, equipment, or confidential information) or financial (such as embezzlement or false reporting of hours, expenses, or work) is grounds for disciplinary action, including termination and potential legal prosecution. Misappropriation of the personal property of colleagues is treated with equal seriousness. Use of Company materials, products, or resources for non-work-related purposes including personal ventures requires prior written authorization from your supervisor or management. If ongoing use is approved, this authorization must be renewed annually.

The Company places significant importance on maintaining its credibility and reputation within the community. Public perception shaped by what is communicated about the Company through the media and investment circles can greatly influence our reputation, either positively or negatively.

Our policy is to respond to public inquiries (including those from the media, analysts, and others) with timely, accurate, and complete information, while also safeguarding the confidentiality of competitive and proprietary data and avoiding the selective release of market-sensitive financial information.

To ensure adherence to this policy, all media or investor-related inquiries must be directed to the Company's Investor Relations department. All other external communications including those involving customers, vendors, or the general public should be routed through the Marketing department. These departments will collaborate with the relevant internal stakeholders to assess and coordinate an appropriate and consistent response.

The Company owes its success to the clients it has served. Operating across diverse markets, the Company recognizes the importance of fully understanding each client's needs and expectations, and is committed to working collaboratively to fulfill them. We regard our clients with the same respect we extend to our shareholders. All employees are expected to uphold this standard by safeguarding clients workforce information and trade secrets with the utmost confidentiality and professionalism.

Trust is the foundation of our daily business operations. As professionals, we are dedicated to honoring the confidence others place in us. In creating valuable products that meet user needs, we must always remember that we are entrusted with sensitive personal information. Maintaining that trust means each of us must safeguard and respect the privacy of this data. Our security protocols strictly regulate access to and use of users' personal information. We also uphold the confidentiality of our own proprietary information and demonstrate the same respect for the confidential information of others.

We are dedicated to providing high-quality services that align with our professional expertise and are tailored to address the unique needs and challenges of each client.

Being responsive is a key aspect of integrity and usefulness. We value meaningful client feedback and respond to it promptly. Whether it's a question, concern, compliment, or suggestion, we take pride in addressing client communications with attentiveness and care

Our business success relies heavily on building and maintaining strong, long-term relationships with our clients and customers. The Company is dedicated to treating them with fairness, honesty, and integrity. When engaging with clients and customers, the following principles should be upheld:

• Ensure that all information provided is accurate and complete to the best of your knowledge; do not intentionally mislead or misrepresent facts.


• Do not refuse to sell, service, or support Company products simply because a customer may also be purchasing from a competitor.


• Customer entertainment should align with standard business practices and remain within reasonable limits. Avoid offering entertainment or benefits that could be perceived as an incentive or reward for influencing purchasing decisions.

The Company is committed to engaging with suppliers in a fair, honest, and transparent manner. Our supplier relationships are grounded in merit, including factors such as price, quality, service, and reputation. Employees interacting with suppliers must maintain objectivity and avoid any conduct that could influence or appear to influence their impartial judgment.

Employees must not accept or solicit personal benefits from current or potential suppliers that could impair their ability to evaluate the supplier fairly. However, modest promotional items or reasonable entertainment may be exchanged, provided they fall within customary and responsible business practices.

The Company is firmly dedicated to promoting fair and open competition in the marketplace. Employees must refrain from engaging in any conduct that violates laws related to competitive practices, including applicable antitrust regulations. This includes, but is not limited to, the unauthorized use or disclosure of a competitor's confidential information and making misleading or defamatory statements about competitors or their practices. Such conduct is considered gross misconduct and may result in disciplinary action, up to and including termination."

The Company is dedicated to fostering an inclusive and respectful workplace where equal opportunity and fair treatment are afforded to all individuals based solely on merit. Discrimination on the basis of race, color, religion, national origin, sex (including pregnancy), age, disability, or any other characteristic protected by law is strictly prohibited. Every employee has the right to be treated with dignity and to work in an environment free from harassment, bullying, or victimization.

Harassment in any form whether physical, verbal, or non-verbal and regardless of whether it is committed by supervisors, colleagues, or external parties, will not be tolerated. Harassment is defined as any unwelcome or offensive behavior that causes discomfort or distress to another individual. This may include, but is not limited to:

• Unwanted Physical Conduct - such as inappropriate touching, patting, pinching, brushing against someone, threatening behavior, physical intimidation, or any act of sexual coercion or violence.


• Unwanted Verbal Conduct - including unwelcome sexual advances or suggestive remarks, inappropriate nicknames or titles, offensive jokes, discriminatory comments related to race, religion, gender, disability, or other protected characteristics, or repeated invitations to unwanted social engagements. This also includes such conduct through written communication, email, or electronic messages.


• Unwanted Non-verbal Conduct - such as displaying offensive or discriminatory images, gestures, graffiti, or suggestive material, whether in physical form, on digital media, or through internal communication systems.


• Bullying - defined as repeated and unjustified criticism, personal attacks, intimidation, or verbal abuse, whether conducted publicly or privately.

The Company maintains a zero-tolerance policy on harassment and bullying and will take appropriate disciplinary action against any such behavior, up to and including termination.

Employees must refrain from any conduct that may constitute harassment or discriminatory behavior, including but not limited to the following:

• Making employment decisions based on stereotypes or biased assumptions related to an individual's gender, race, age, religious beliefs, ethnic background, or disability status.


• Denying job opportunities to someone due to their marriage to, or association with, individuals of a specific race, religion, nationality, or individuals living with disabilities.


• Engaging in harassment directed at someone because of their race, color, religion, gender, national origin, disability, or age.


• Retaliating against individuals for reporting discrimination, taking part in an investigation, or challenging unfair or discriminatory treatment.

The conduct described above may target either individuals or groups. It is important to understand that the effect of the behavior, not the intent, determines its appropriateness. The Company has established clear policies and procedures outlined in the Employee Handbook to prevent unlawful discrimination and harassment, including sexual harassment.

Any form of harassment in the workplace is unacceptable and will not be tolerated. All employees are expected to uphold this policy and ensure that their interactions with colleagues and clients remain respectful and do not cause offense or constitute harassment.

Harassment based on sex, race, gender identity, age, religious beliefs, or disability is a form of discrimination and is prohibited by law. Such behavior may also breach civil and criminal law, as well as health and safety regulations.

If you believe you have experienced or witnessed discrimination or harassment, including sexual harassment, you are encouraged to report it to your supervisor or the Human Resources. All reports will be handled with sensitivity and discretion. The Company will maintain confidentiality to the greatest extent possible, in accordance with legal obligations and the need to conduct a thorough investigation.

If a complaint is substantiated, the Company will take immediate and appropriate action, which may include disciplinary measures up to and including termination of employment. Retaliation against anyone who raises a concern in good faith is strictly prohibited. Serious violations or repeated offenses may result in dismissal without notice.

MicroFix Integrated Solutions complies fully with all environmental laws, regulations, and local statutes to support and safeguard the environment. We maintain processes to ensure adherence to local requirements particularly those governing the handling, recycling, and safe disposal of hazardous materials and we are committed to actively enhancing environmental quality through proactive and continuous improvement initiatives.

At MicroFix, we believe that some of the most valuable contributions to the world are freely given. In that spirit, we regularly support open-source platforms and nonprofit organizations dedicated to the betterment of society through periodic donations.