Code of Conduct

Version 1 | Approved 25 March 2026

1. Message from the Founder

At GMA Consultancy, we ask our clients to build cultures of integrity, transparency, and accountability. This Code of Conduct is our own commitment to the same standard. It reflects who we are as a Lebanese firm proud of its regional footprint, and it reflects the international principles — in particular the United Nations Global Compact — that we believe every responsible business, large or small, should adopt.

Every person who represents GMA is expected to know this Code, live by it, and hold themselves and their colleagues to it.

Wissam Maroun, CAMS | Founder & General Manager, GMA Consultancy S.A.R.L

2. Purpose and Application

This Code of Conduct sets out the values and standards of behavior expected of the Founder, all employees, engaged consultants, and Associated Persons acting for GMA Consultancy (Governance, Monitoring & Advisory) S.A.R.L (collectively, “GMA Personnel”), in every jurisdiction in which GMA operates.

This Code should be read together with GMA’s Anti-Bribery and Corruption Manual (GMA-ABC-2026-001), which provides the detailed rules on bribery, gifts, hospitality, and conflicts of interest referenced at a principled level in this document, and with GMA’s Official Digital Presence & Institutional Communication Statement (GMA-STMT-2026-001), which governs the separation between GMA’s institutional voice and the personal digital conduct of GMA Personnel.

3. Our Commitment to the United Nations Global Compact

GMA has voluntarily aligned its Code of Conduct with the Ten Principles of the United Nations Global Compact, the world’s largest corporate sustainability initiative, spanning human rights, labour, environment, and anti-corruption. We apply these principles both to how we run GMA internally and to how we advise our clients.

These Principles are stated here at a global, aspirational level. What they mean concretely for you as a GMA employee — your actual entitlements under Lebanese labour law, and your specific rights and obligations under GMA’s own governance framework — is set out in full, in plain language, in the GMA Employee Constitution (GMA-CONST-2026-001), issued to every GMA employee at onboarding.

3.1 Human Rights

• Principle 1 — Businesses should support and respect the protection of internationally proclaimed human rights; and
• Principle 2 — Businesses should make sure they are not complicit in human rights abuses.

3.2 Labour

• Principle 3 — Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
• Principle 4 — Businesses should uphold the elimination of all forms of forced and compulsory labour;
• Principle 5 — Businesses should uphold the effective abolition of child labour; and
• Principle 6 — Businesses should uphold the elimination of discrimination in respect of employment and occupation.

3.3 Environment

• Principle 7 — Businesses should support a precautionary approach to environmental challenges;
• Principle 8 — Businesses should undertake initiatives to promote greater environmental responsibility; and
• Principle 9 — Businesses should encourage the development and diffusion of environmentally friendly technologies.

3.4 Anti-Corruption

• Principle 10 — Businesses should work against corruption in all its forms, including extortion and bribery.

These Principles are given further, detailed effect throughout this Code, and — for anti-corruption specifically — in GMA’s Anti-Bribery and Corruption Manual. GMA also has regard to UNCAC, the OECD Guidelines for Multinational Enterprises, and applicable ILO labour standards in shaping its own workplace practices.

4. Our Core Values

Integrity

We act honestly and consistently, even when no one is watching and even when it is commercially inconvenient. Our advice is only as valuable as our own credibility.

Independence

Our judgment is not for sale. We disclose and manage conflicts of interest rather than let them compromise the objectivity our clients rely on.

Confidentiality

We protect client and third-party information as carefully as we would want our own protected, and we apply this discipline consistently across every engagement.

Professionalism

We hold ourselves to the standards of the CAMS designation and to the regulatory and international best practices we advise our clients to adopt.

Accountability

We take ownership of our work, our mistakes, and our obligations — to our clients, our colleagues, and the communities in which we operate.

5. Professional Conduct

GMA Personnel are expected to conduct themselves in a manner consistent with the professional standards of the compliance discipline, including the CAMS Code of Professional Ethics where applicable, and to:

• Deliver advice that is technically sound, evidence-based, and free from undue influence;
• Represent GMA’s qualifications, experience, and track record accurately in all proposals and communications;
• Decline engagements that fall outside GMA’s genuine competence rather than overstate capability; and
• Treat colleagues, clients, regulators, and counterparties with respect and professional courtesy at all times.

6. Human Rights and Non-Discrimination

Consistent with UN Global Compact Principles 1 and 2, GMA respects the human rights and dignity of everyone it works with — employees, clients, associates, and members of the public affected by its work — and does not knowingly participate in or facilitate human rights abuses through its advisory work.

• GMA does not discriminate in hiring, engagement, promotion, or treatment on the basis of gender, religion, nationality, ethnicity, disability, age, or any other characteristic unrelated to professional merit;
• GMA provides a workplace free of harassment, intimidation, or abusive conduct; and
• GMA expects its clients and Associated Persons to uphold comparable standards, and will raise concerns — including declining an engagement — where credible evidence suggests otherwise.

6.1 Prevention of Sexual Exploitation and Abuse

6.2 Human Trafficking

GMA prohibits any involvement, direct or indirect, in human trafficking, and will not knowingly engage an Associated Person, client, or counterparty involved in trafficking in persons. GMA Personnel who become aware of a credible indication of human trafficking connected to GMA’s business must report it immediately, following the same channel used for whistleblowing under Section 15.

7. Labour Standards and a Fair Workplace

Consistent with UN Global Compact Principles 3–6, GMA:

• Respects the right of its people to raise workplace concerns freely and without fear of retaliation;
• Does not use or knowingly benefit from forced, compulsory, or child labour, in its own operations or through any Associated Person; and
• Bases remuneration and advancement on performance, competence, and contribution, applied consistently and fairly.

8. Environmental Responsibility

Consistent with UN Global Compact Principles 7–9, GMA — as a professional services firm with a modest direct environmental footprint — nonetheless commits to:

• Minimizing unnecessary paper, travel, and resource use in its own operations, favoring digital delivery of advisory work where appropriate;
• Considering environmental and governance (ESG) factors, where relevant, in the advice it provides to clients; and
• Supporting client and community initiatives that promote environmental responsibility, consistent with GMA’s broader commitment to Lebanese civic life.

9. Anti-Corruption

Consistent with UN Global Compact Principle 10, GMA has zero tolerance for bribery and corruption in any form. This principle is given full, operational effect in GMA’s Anti-Bribery and Corruption Manual (GMA-ABC-2026-001), which governs gifts and hospitality, conflicts of interest, facilitation payments, dealings with public officials, and third-party due diligence, and which forms an integral part of the standards GMA Personnel are expected to uphold.

10. Confidentiality and Data Protection

GMA routinely handles highly sensitive client, regulatory, and personal data. GMA Personnel must:

• Keep confidential all client, employee, and third-party information obtained in the course of GMA’s work, both during and after the engagement or employment relationship;
• Access and use confidential information only for the legitimate purpose for which it was provided;
• Apply data protection principles — lawfulness, purpose limitation, data minimization, and security — consistent with GMA’s data protection advisory practice; and
• Never disclose client identities or engagement details publicly (including on social media) without the client’s prior written consent.

The handling of personal data referenced in this section is governed in detail by GMA’s Website Privacy Policy (GMA-PRIV-2026-001), which GMA Personnel should consult for the firm’s data protection standards and procedures.

11. Conflicts of Interest and Independence

GMA Personnel must disclose promptly any personal, financial, or family interest that could reasonably compromise — or appear to compromise — the independence and objectivity that clients and regulators expect of GMA, following the process set out in Section 8 of the Anti-Bribery and Corruption Manual. Independence is the foundation of GMA’s credibility as an advisor, and it is protected accordingly.

12. Client Relationships

• GMA delivers services and products — as distinguished on www.gmaconsultancy.com — with equal diligence regardless of engagement size;
• GMA communicates fee structures, scope, and limitations clearly and in writing before an engagement begins; and
• GMA does not accept an engagement it cannot deliver with genuine independence and competence.

If a client, prospective client, or counterparty approaches any GMA Personnel for advice on how to avoid a regulatory obligation or reporting requirement, that GMA Personnel must report the approach to their direct manager promptly. This obligation applies regardless of whether the request was made seriously, in passing, or in a manner that could later be characterized as a misunderstanding — GMA would rather review a false alarm than miss a genuine one.

13. Use of Company Assets and Information

GMA Personnel are expected to use GMA’s name, systems, templates, and proprietary methodologies responsibly and solely for legitimate GMA business, and to safeguard them against unauthorized use, whether during or after their association with GMA.

14. Anti-Money Laundering Awareness

As a firm that advises clients on AML/CFT compliance under Lebanese Law No. 44/2015 and related regulations, GMA holds itself to the same standard internally: GMA Personnel must exercise heightened diligence regarding the source of funds in any transaction connected to GMA’s own operations, and must never facilitate, structure, or turn a blind eye to a transaction reasonably suspected of connection to money laundering or terrorist financing. GMA’s broader financial-crime compliance posture — covering sanctions, cybercrime, and staff background checks — is set out in GMA’s Compliance Statement (GMA-COMP-2026-001).

15. Reporting Violations — Speak Up

16. Consequences of Non-Compliance

A breach of this Code may result in disciplinary action up to and including termination of employment or engagement, termination of an Associated Person’s contract, and — where the breach also constitutes a legal violation — referral to the competent authorities.

17. Acknowledgement

This Code of Conduct is provided to every GMA Personnel upon joining the firm and is reviewed at least annually. By acting for or on behalf of GMA, GMA Personnel confirm that they have read, understood, and agree to abide by this Code. New employees additionally sign the GMA Employee Constitution (GMA-CONST-2026-001) at onboarding, which consolidates this Code together with employee rights and obligations under Lebanese labour law and GMA’s wider governance framework into a single reference document.

This Code of Conduct is approved and issued by: