Code of Conduct and Ethics

I. Purpose

The purpose of this Code of Conduct and Ethics (the "Code") is to establish the standards of ethical conduct and professional behavior expected within Ondaro LLC and its affiliates (e.g., Ondaro do Brasil Consultoria Ltda., Ondaro Canada Consulting ULC, Cask Digital Services de Mexico, S. de R.L. de C.V. Mexico, among others), which hereinafter shall be collectively referred to in this policy as "Ondaro". This Code aims to promote integrity, honesty, accountability, and compliance with applicable laws, regulations, and company policies among employees, contractors, subcontractors, vendors, suppliers, and any third party acting on behalf of Ondaro.

II. Policy Statement

Ondaro LLC ("Ondaro") is committed to conducting its business fairly, honestly, and ethically. This Code of Conduct and Ethics outlines Ondaro's commitment to maintaining the highest standards of integrity and preventing unethical conduct in all forms, whether involving government or non-government clients. All collaborators are expected to uphold this commitment and adhere to the principles set forth in this Code.

III. Scope

This Code applies to all collaborators, employees (including individuals engaged directly or through any employer of record), contractors, subcontractors, vendors and suppliers (collectively "Third Parties" and individually, a "Third-Party") and anyone acting on behalf of Ondaro, regardless of their position or location.

IV. Code of Conduct and Ethics

We often tell our collaborators to "do the right thing". This Code provides guidance regarding the ethical conduct Ondaro expects from all collaborators and how to do the "right thing." It is important to understand that this Code is intended to provide general guidance and expectations, but it cannot address every possible situation. The key takeaway is that, if you see something, say something; we all share the responsibility to ensure that Ondaro operates in an ethical manner.

This Code also promotes our Core Values, which are the foundation of our organization and reflect what we expect from all collaborators:

• INTEGRITY FIRST – Honesty and transparency in all that we do.
• CLIENT-OBSESSED – Our clients' success is our success, but never at the expense of ethics, integrity or compliance.
• CONTINUOUSLY CURIOUS – We continually learn and grow.
• DEEP ACCOUNTABILITY – We take ownership of our actions and outcomes.
• TEAM WITH EMPATHY – Every voice is heard and valued.
• SPEAK UP WITH COURAGE – We raise concerns, ask questions, and report misconduct without fear of retaliation.
• RESPECT ALWAYS – We treat others with dignity, professionalism, and respect.

V. Build Trust and Credibility

The success of our business depends on the trust and confidence we earn from our collaborators, clients, and other stakeholders. We build credibility by adhering to our commitments, acting with honesty and integrity, and achieving Ondaro's goals solely through ethical and honorable conduct. This is what differentiates us in the marketplace and strengthens our reputation with clients and competitors alike. While it is easy to say what we must do, our actions are what ultimately define us. In the end, we will be judged not only by what we say, but by what we do.

VI. Respect for the Individual

We all deserve to work in an environment where we are treated with dignity, respect, and professionalism. Ondaro is committed to fostering such an environment because it enables each of us to reach our full potential and contributes directly to our business success. We cannot afford to let anyone's talents go to waste.

Ondaro is an equal opportunity employer and is committed to providing a safe workplace free from discrimination, harassment, abusive conduct, and offensive behavior of any kind. Any collaborator who believes they have been subjected to or witnessed discrimination, harassment, or other inappropriate conduct should promptly report the matter to their Department Head, People Operations, and to the Ethics and Compliance Officer.

VII. Create a Culture of Open and Honest Communication

At Ondaro, everyone should feel comfortable speaking openly, particularly with respect to ethics and compliance concerns. Senior Management have a special responsibility to foster an open, honest, and supportive environment in which collaborators feel comfortable raising questions and concerns. We all benefit when collaborators help prevent mistakes, misconduct, or wrongdoing by asking the right questions and speaking up at the right times.

VIII. Ethics and Compliance Program

Ondaro is committed to maintaining the highest standards of integrity, ethical conduct, and compliance with all applicable laws and regulations. To support this commitment, Ondaro has established a comprehensive Ethics and Compliance Program and appointed an Ethics and Compliance Officer to help ensure that all Third Parties understand and adhere to these standards as well as feel empowered to raise concerns in good faith.

IX. Whistleblower Protection

A whistleblower, as defined by the Whistleblower Protection Policy, is an individual who reports situations or facts that may give rise to improper conduct or to violations of applicable legal, regulatory, or internal Ondaro rules. A Whistleblower is not responsible for investigating the reported activity or determining fault or corrective measures; those responsibilities are assigned to the appropriate Ondaro personnel.

Examples of illegal, dishonest or fraudulent activities include violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other forms of fraudulent financial reporting.

Any individual who becomes aware of or has a good faith concern regarding illegal, dishonest, or fraudulent activity must promptly report through the Reporting Channels. Any individual who knowingly submits a false report or makes allegations in bad faith will be subject to corrective action, up to and including termination of employment or engagement.

Whistleblower protections are provided in two important areas: confidentiality and protection against retaliation. The identity of the Whistleblower will be kept confidential to the greatest extent possible, consistent with the need to conduct a fair and thorough investigation and comply with applicable legal requirements. Ondaro strictly prohibits retaliation against any Whistleblower who raises a concern or reports suspected misconduct in good faith. This protection includes, but is not limited to, protection from adverse employment action such as termination, reduction in compensation, unfavorable work assignments, or threats of physical harm. Any Whistleblower who believes they have been subjected to retaliation must immediately contact the Ethics and Compliance Officer. However, protection against retaliation does not exempt any individual from accountability for their own misconduct if it is independently identified and investigated.

X. Set Tone at the Top

Senior Management has the added responsibility to demonstrate, through their actions, the importance of this Code. Ethical behavior does not happen by chance; it is the result of clear and direct communication of behavioral expectations, consistent leadership from the top, and conduct that is molded by example. Ultimately, our actions are what matters most.

To ensure that this Code is effective in practice, Senior Management is responsible for promptly addressing ethical questions or concerns raised by Third Parties, taking appropriate steps to address such matters, and escalating them when necessary. Senior Management should not view Third Parties ethics concerns as threats or challenges to their authority, but rather as an important and encouraged form of business communication.

XI. Uphold the Law

Ondaro's commitment to integrity begins with compliance with the laws, rules and regulations applicable in the jurisdictions where we do business. In addition, each of us is expected to understand Ondaro's policies, laws, rules and regulations relevant to our respective roles. If we are ever unsure of whether a contemplated action is permitted under applicable law or Ondaro policy, we should seek guidance from the appropriate internal resource. We are all responsible for helping prevent violations of law and for speaking up if we become aware of potential misconduct or non-compliance.

XII. Competition

We are committed to ethical, fair and vigorous competition. We market and sell Ondaro's services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and do not improperly coordinate our activities with competitors. We do not offer, authorize, or accept improper payments, gratuities, or other benefits in connection with the purchase of goods or services for Ondaro or the sales of its services, nor do we engage in or support unlawful boycotts of customers or other Third Parties. Every collaborator involved, directly or indirectly, in Ondaro's business development activities is responsible for upholding these standards and competing fairly and ethically at all times. Competition and antitrust laws prohibit anti-competitive conduct, including agreements with competitors to fix prices, allocate markets, divide customers, or refrain from competing in certain regions or for particular business opportunities.

Collaborators must also avoid improper communications or exchanges of competitively sensitive information with competitors, including information relating to pricing, costs, customers, business strategies, or bidding intentions. Special care must be taken in connection with bids, tenders, and other competitive procurement processes.

XIII. Confidential, Proprietary Information, and Intellectual Property

The protection of Ondaro's confidential and proprietary information, as well as nonpublic information entrusted to us by collaborators, customers, and other business partners, is essential to Ondaro's success. Confidential and proprietary information includes, among other things, pricing and financial data, customer information, trade secrets, business plans, and nonpublic information relating to current or prospective customers, suppliers, vendors, and other third parties. We must protect such information and may not access, use, or disclose it except for a legitimate business purpose and with proper authorization.

We must also respect the intellectual property and other property rights of others. We will not obtain or attempt to obtain a competitor's trade secrets or other proprietary or confidential information through improper means. We will not engage in the unauthorized use, copying, distribution, modification, or disclosure of software, proprietary materials, data, or other intellectual property belonging to Ondaro or to third parties. We are also expected to comply with all applicable license terms, contractual restrictions, and usage conditions relating to software, data, and other intellectual property.

Nothing in this Code prohibits or restricts a collaborator from lawfully reporting waste, fraud, or abuse relating to the performance of a government contract to a designated investigative or law enforcement representative or to a federal department or agency authorized to receive such information.

For further reference to data protection, please review the Data Retention Policy and Schedule, and the Data Privacy and Data Protection Policy.

XIV. Selective Disclosure

We will not selectively disclose material nonpublic information regarding Ondaro, including information relating to its security, business operations, strategic plans, financial condition, results of operations, or other significant developments. We should be especially careful participating in meetings, presentations, proposals, or other communications with customers or Third Parties to ensure that such communications do not include confidential, proprietary, or otherwise nonpublic information unless the disclosure has been properly authorized.

XV. Political Activities and Lobbying

Ondaro respects the integrity of the political process and is committed to complying with all laws governing its participation in political activities. Many countries, including the United States, prohibit corporations from making direct or indirect contributions of corporate funds, goods or services to political candidates at the federal and/or local level.

We are also committed to ensuring that all lobbying activities are conducted in strict compliance with applicable laws, regulations, procedures, and Ondaro policies. To ensure legal compliance and proper coordination of Ondaro's political activities, please contact the Ethics and Compliance Officer before making any political contribution or engaging in any political or lobbying contact, initiative, or communication on behalf of the company.

Voluntary collaborator involvement in the political process is encouraged, but it must take place on your own time and without the use of any Ondaro resources. If you plan to seek or accept public office, you must have prior approval of the Ethics and Compliance Officer.

XVI. Selection and Oversight of Third Parties

The actions of our consultants, technical advisors, sales representatives and any other third parties or affiliates with whom we interact reflect upon and may affect Ondaro. We will only engage consultants, business representatives, and other third parties of known integrity, and we expect their conduct to meet our standards.

Collaborators involved in the engagement or oversight of third parties must comply with all Ondaro policies and procedures relating to third-party selection, approval, due diligence and appropriate monitoring. Third parties must never be engaged for improper or illegal purposes, including paying bribes or kickbacks, engaging in industrial espionage, or obtaining the proprietary or confidential information of others through improper means.

We require our business representatives and advisors to comply with our policies. If you become aware of any actual or potential violation of these policies by a third party you must promptly report it to the Ethics and Compliance Officer.

For further reference to the selection and oversight process, please review the Third-party, Engagement & Due Diligence Policy.

XVII. Zero Tolerance for Corruption and Bribery

Our reputation for honesty is far more important than any new business opportunity. We will not engage in bribery or any other type of corruption, whether involving public officials or private individuals, even if that means losing business opportunities.

All countries in which we operate and/or pursue new business, including the United States, have laws criminalizing bribery of government officials. These laws apply to all collaborators around the world. The sanctions for violating these laws can be severe and may include significant corporate fines, suspension, debarment, adverse publicity, and serious damage of Ondaro's reputation. For collaborators who engage in bribery or other unlawful conduct, those sanctions can include individual fines, termination of employment or engagement, imprisonment, or any other sanction as per Ondaro's Handbook.

We must never offer, attempt to offer, authorize or promise a bribe, payment, kickback, or other improper benefit to a government official or private party for the purpose of obtaining or retaining business or securing an improper advantage. Likewise, we must never solicit or accept a bribe, kickback, or other improper benefit from a public official or private party. A bribe includes any payment, benefit or gift that is offered, promised, or given with the purpose of influencing a decision or outcome.

Ondaro also prohibits "facilitation payments," which are small sums paid to foreign government officials to expedite or facilitate nondiscretionary actions or services, such as obtaining an ordinary license or government service. We must never hire or use another person or entity (e.g., a sales representative, consultant, or reseller) to do anything that we cannot ethically or legally do ourselves. Ondaro and its collaborators may be held liable for bribes paid by a third-party agent, consultant, or other intermediary acting on Ondaro's behalf.

We will use reasonable diligence in vetting the legitimacy of business dealings with customers, partners, and other third parties. We will not participate in any transaction or business dealing that is known or likely to involve illegal or fraudulent conduct.

All collaborators who interact with current or potential customers have an obligation to understand and comply with all Ondaro policies and applicable laws relating to anti-bribery and anti-corruption. Ondaro provides training and resources on these standards; however, when in doubt, collaborators should consult the Ethics and Compliance Officer.

For further reference to anti-bribery and anti-corruption standards, please review the Anti-Bribery and Anti-Corruption policy.

XVIII. Avoid Conflicts of Interest

We must avoid any relationship or activity that could impair, or even appear to impair, our ability to make objective and fair decisions in the performance of our duties. From time to time, we may face situations in which actions we take on behalf of Ondaro may conflict, or appear to conflict, with our personal, family, or financial interests. We owe a duty to Ondaro to advance its legitimate interests whenever the opportunity arises. We must never use Ondaro property, information, or our position for personal gain, nor take for ourselves any business or other opportunity discovered through our role with Ondaro.

Conflicts of interest may arise in many ways, including the following:

• Being employed by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, or having a close family member in such role, regardless of the nature of the employment, while you are engaged by Ondaro.
• Hiring, supervising, or influencing employment decisions involving family members or other closely related individuals.
• Serving as a director, officer, or board member for an outside commercial company or organization that is in direct competition with Ondaro, without appropriate review and approval from the Ethics and Compliance Officer.
• Owning, directly or indirectly, or having a substantial interest in a competitor, supplier or contractor.
• Having a personal, family, or financial interest in any transaction involving Ondaro.
• Placing Ondaro business with a firm owned or controlled by a collaborator or a member of their family.
• Accepting gifts, discounts, favors or services from a customer or potential customer, competitor or supplier, unless such benefits are permitted under Ondaro policies and equally available to all collaborators.

Determining whether a conflict of interest exists is not always straightforward. Collaborators who believe they may have an actual, potential, or perceived conflict of interest should promptly seek guidance from the Ethics and Compliance Officer. Before engaging in any activity, transaction or relationship that could give rise to a conflict of interest, collaborators must disclose the matter and obtain appropriate review from the Ethics and Compliance Officer.

For further reference to conflicts of interest, please review the Conflict of Interest policy.

XIX. Gifts, Gratuities and Business Courtesies

Ondaro competes on the merits of its products and services and does not use gifts, gratuities, or business courtesies to obtain an improper business advantage. Collaborators must never offer, solicit, or accept any gift, hospitality, entertainment, gratuity, or other business courtesy that could improperly influence, or appear to improperly influence, a business decision, create a conflict of interest, or otherwise violate applicable law, Ondaro policies, or the recipient organization's rules.

All gifts, gratuities, and business courtesies must be reasonable, infrequent, transparent, properly documented, and compliant with Ondaro's Gifts and Gratuities Policy.

XX. Accurate Disclosures and Business Records

We are committed to ensuring that all disclosures made in financial reports and public documents are full, fair, accurate, timely, and understandable. This obligation applies to all collaborators, including financial executives and any other collaborators involved in the preparation, review, approval, signing, or certification of such reports or disclosures. No business objective of any kind is ever an excuse for misrepresenting facts, omitting material information, or falsifying records.

Collaborators must promptly inform the Ethics and Compliance Officer if they become aware that information contained in any filing, report, or public communication was untrue, incomplete, or misleading at the time it was made, or if subsequent information could affect the accuracy of any future filing, report, or public communication.

XXI. Document Retention

Ondaro creates, retains, and disposes of records in accordance with applicable legal, regulatory, and business requirements. All Ondaro records must be accurate, complete, and properly maintained. Collaborators must never alter, conceal, destroy, or improperly handle records in violation of applicable law, Ondaro policies, or any legal hold, audit, investigation, or other preservation requirement.

For further reference to document retention, please review the Data Retention policy and the Data Retention Schedule.

XXII. Accurate Timekeeping

Employees who charge their time to commercial projects or in support of a government contract (i.e., "direct charge" employees) are personally responsible for ensuring that all hours worked are recorded accurately and charged to the correct project code(s) or account(s). This includes maintaining an accurate and timely record of time worked by project, working in accordance with applicable work plans and Ondaro procedures, and certifying the accuracy of timesheets on a weekly or biweekly basis, as required.

Timekeeping violations undermine customer trust, compromise the integrity of Ondaro's records, and may subject Ondaro and the individuals involved to significant fines, penalties, and other disciplinary or legal consequences.

XXIII. Do the Right Thing

At times, we are all faced with decisions we would rather not make and issues we would prefer not to confront. At Ondaro, we are expected to address difficult situations with honesty, sound judgment, and integrity, confident that Ondaro is committed to doing the right thing. In some cases, this may require more than simply complying with the minimum requirements of the law. The fact that a course of action may be legally permissible does not necessarily mean that it is appropriate or consistent with this Code.

Although this Code cannot address every issue or provide an answer to every dilemma, it reflects the principles and values that guide how we conduct business. When faced with a difficult decision, ask yourself:

• Does what I am doing comply with the Company's values, this Code, and Company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable explaining my decision to my Department Head, my colleagues, or a government authority?
• How would it look if it were reported publicly?
• Am I acting with honesty, integrity, and sound judgment?
• Is this the right thing to do?

XXIV. Use of Company Resources

Ondaro resources, including time, materials, equipment, technology, systems, and information, are provided for legitimate Ondaro business purposes. Personal use is not permitted and is considered a violation of this Code.

Collaborators and those who represent Ondaro are expected to act responsibly, exercise good judgment, and protect Ondaro resources from misuse, loss, damage, theft, waste, or unauthorized access. Department Heads are responsible for the resources assigned to their teams and for helping ensure their proper use.

Despite the above, each individual is responsible for the correct and proper use of the resources assigned to them.

Ondaro resources must not be used to conduct outside business activities or to support personal, political, religious, or other non-Ondaro activities. Collaborators may not use Ondaro resources to solicit contributions or distribute non-business materials.

To the extent permitted by applicable law, Ondaro reserves the right to monitor, access, review, and retain information stored on or transmitted through Ondaro systems, devices, networks, and other resources. Collaborators should not expect privacy when using Ondaro resources, except as otherwise required by law. Ondaro prohibits the use of its resources to create, access, store, print, transmit, or distribute materials that are unlawful, harassing, threatening, abusive, discriminatory, sexually explicit, or otherwise offensive or inappropriate.

Questions regarding the proper use of Ondaro resources should be directed to your Department Head.

XXV. Media Inquiries

Ondaro is a high-profile company in our community, and from time to time, collaborators may be approached by reporters and other members of the media. To ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the Marketing Department (marketing@ondarowave.com). No one may issue a press release without first consulting with the Strategic Marketing Department.

XXVI. Reporting Channels

Ondaro has established a secure and confidential Reporting Channels that allows anyone to report suspected non-compliance with this Code anonymously and has ensured that the Reporting Channels are easily accessible to all employees, contractors, and third-party service providers.

Anyone can report suspected non-compliance through the following channels:

• Web Intake Site: ondaro.ethicspoint.com
• Mobile Intake Site: ondaromobile.ethicspoint.com
• Hotline: 1-833-718-5740
• Email: ethics@ondarowave.com

XXVII. Accountability

Each of us is responsible for understanding and complying with the values, principles, and standards set forth in this Code and in applicable Ondaro policies. We are also responsible for asking questions, seeking guidance when needed, and speaking up if we become aware of conduct that may violate this Code, Ondaro policy, or applicable law.

Ondaro takes the standards set forth in this Code seriously. Failure to comply with this Code may result in corrective action, up to and including termination of employment or engagement, as per Ondaro's Handbook.

XXVIII. Effective Date

This policy is effective as of April 1st, 2026 and will remain in effect until amended or revoked by senior management.

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