EXG Code of Business Conduct

Who We Are: Pioneers in Collectibles Since 2017

Since our establishment in 2017, we have secured 250 global licenses, sold 10 million units, and expanded into 60 markets, generating $300 million at retail.

A Message from Our CEO and COO

At EXG Pro, we do not simply manufacture collectibles. We build bridges between passion and purpose.

From our beginnings in 2017, our mission has been clear: to elevate the world of functional fan collectibles through innovation, craftsmanship and authenticity. Our products do not sit idle. They hold. They charge. They connect. They become part of everyday life.

With more than 250 global licenses, patented technologies and award-winning design, our growth carries responsibility. Innovation without integrity is unsustainable. Scale without governance is fragile.

This Global Code of Conduct defines how we operate — ethically, legally and responsibly in every country, market and partnership.

• Integrity protects our licenses.
• Compliance protects our growth.
• Accountability protects our future.

Every director, employee, contractor and partner acting on behalf of EXG Pro is expected to understand and uphold this Code.

Alan Fenwick, Chief Executive Officer & Julie Fenwick, Chief Operating Officer

Vision, Mission & Values

Our Vision

To lead the global collectibles industry by continuously pushing the boundaries of innovation. We aim to inspire a world where fans seamlessly integrate their passions into everyday life — setting trends and redefining what it means to collect, connect, and create.

Our Mission

At EXG Pro, we are a market-leading creator of innovative, functional collectibles for gaming and pop culture fans. Our products are fully licensed by globally recognised brands, patented and trademarked, and first to market within their categories.

Every product is designed with a clear purpose and primary function, combining cutting-edge technology with quality-assured craftsmanship and meticulous attention to detail. Built around the evolving lifestyles of modern fans, our collectibles seamlessly blend fandom with everyday use. We always put the customer first.

Our Values

At EXG Pro, we lead with empowered leadership and a commitment to inclusion, championing gender diversity, youth opportunity, and innovation. With 50% female senior leadership and strong investment in emerging talent, we are shaping a forward-thinking future — driven by purpose and powered by progress.

Who This Code Applies To

This Code applies to all individuals acting on behalf of EXG Pro, including:

• All directors and officers
• All employees (full-time, part-time and temporary)
• Freelancers and contractors
• Agents and consultants
• Third parties acting on behalf of EXG Pro
• Subsidiaries and international operations

Where local laws set a stricter standard, local law prevails. Where this Code sets a higher standard, we follow this Code.

Violations may result in disciplinary action up to and including dismissal, and may carry personal legal liability in cases involving IP, bribery, or data breaches.

The Ground Rules

No one at EXG Pro has the authority to instruct you to violate the law, breach a licensing agreement, or act against this Code. If you are ever asked to do so:

• Refuse the instruction
• Report it immediately through the channels in this Code
• Know that you are fully protected from retaliation

This Code applies whether you are in the office, the warehouse, a studio, working remotely, or representing EXG Pro at an industry event or trade show.

Acting with Integrity

At EXG Pro, integrity is foundational to our success. We encourage every individual to follow our Code diligently, ensuring that ethical behaviour guides your daily choices. Speak up when you notice something amiss — your voice matters. Remember, accountability is key; we all share responsibility for our actions. Use sound judgement in every decision, balancing our values with practical solutions. Together, we can foster a culture of integrity that defines our brand.

Supporting Policies: Disciplinary & Capability Procedure · Grievance Procedure · Whistleblowing Policy

Ethical Decision-Making: Five Key Questions

Before taking action, ask yourself these questions. If any answer is NO, do not proceed.

1. Is it legal in all relevant jurisdictions? Check applicable laws and EXG Pro policies first. Our policies are roadmaps — especially across our multi-territory licensing and trade environments.

2. Does it comply with our licensing agreements? Our business model depends on licensor trust. If an action would breach or risk a licensing agreement with any of our 250+ global partners, pause and seek Legal review.

3. Would it withstand public scrutiny? Ask: "How would this look publicly?" Our customers, licensors and retail partners hold us to a high standard. Our conduct must always be something we'd be proud to defend.

4. Does it protect our customers, licensors and shareholders? Consider the impact on everyone who depends on EXG Pro — our fans, brand partners, and the team building this business every day.

5. Does it reflect our values? Innovation with purpose. Integrity without compromise. Inclusion and accountability. If it doesn't sit comfortably with our values, pause and escalate before acting.

Still unsure? Speak with your line manager, HR, the COO or CEO.

Reporting Concerns

How to Raise a Concern

EXG Pro actively encourages a speak-up culture. If you see something, say something. Concerns may be raised through:

• Your line manager or department head
• HR directly
• The COO, Julie Fenwick
• The CEO, Alan Fenwick

Concerns may relate to: harassment, bullying or unfair treatment; ethical concerns or Code violations; health & safety risks; financial irregularities; licensing, compliance or data security issues; bribery, corruption or anti-competitive conduct.

Our Non-Retaliation Commitment

EXG Pro will never retaliate against any individual who raises a concern in good faith. This protection applies even if the concern turns out to be unfounded, provided it was raised honestly and without malicious intent. Victimising a whistleblower is itself a serious disciplinary matter.

Cooperating with Investigations

All employees must cooperate fully and truthfully with any investigation into potential Code violations. Maintaining confidentiality throughout is required. Interfering with an investigation is a serious breach of this Code. Leadership is held to the same standard as all other employees.

"Your voice matters. Speaking up is not disloyalty — it is how we protect everything we've built."

Each Other

We Treat Each Other with Respect

EXG Pro brings together fans, designers, engineers, commercial leaders, and operations professionals globally. Our strength comes from our diversity — and we protect it fiercely.

We do not tolerate harassment, bullying, abuse or discrimination of any kind, including:

• Creating a hostile or offensive in-person or online environment
• Verbal or physical abuse, unwanted contact, or derogatory language
• Deliberate undermining of a colleague's career or wellbeing
• Treating someone less favourably based on any protected characteristic under the Equality Act 2010
• Offensive language, images, jokes or gestures — online or in person
• Excluding colleagues from decisions or communications without valid reason

Respect is non-negotiable at EXG Pro.

Safe, Inclusive & Wellbeing-First

We believe inclusivity fuels creativity and drives innovation. We actively promote equal opportunity across recruitment, promotion and leadership development.

We support every employee's wellbeing through:

• Realistic workloads and healthy working hours
• Encouraging annual leave and regular breaks
• Speaking up when overwhelmed — without fear of judgement
• A culture that rejects an "always on" mentality
• Safe working environments — offices, warehouse, studios and remote

We are 50% female at senior leadership level and actively invest in youth opportunity and emerging talent. Diversity is a genuine competitive advantage.

Collaboration & Remote Working

Innovation thrives on collaboration — wherever we work. For remote and hybrid employees:

• Be available during agreed working hours
• Keep calendars current and communicate availability
• Ensure relevant colleagues are included in decisions
• Share meeting outcomes with affected team members
• Use video when it improves clarity and connection

Feedback & Communication

Healthy debate strengthens ideas; respect strengthens teams. We commit to:

• Sharing ideas openly and encouraging creative thinking
• Giving constructive feedback with clarity and kindness
• Recognising and crediting contributions of others
• Supporting teammates during launches, deadlines and peak periods

We compete in the market — not with each other.

Supporting Policies: Diversity, Equity and Inclusion Policy · Anti-harassment and Bullying Policy

Our Business & Shareholders

Financial Integrity & Record Keeping

We maintain accurate, complete and transparent financial records at all times. We strictly prohibit:

• Falsification of accounts or business records
• Misrepresentation of revenue or performance
• Concealment of liabilities or off-book transactions
• Any action that misleads shareholders, auditors or regulators

If you identify a discrepancy, report it immediately to your line manager, the COO or CEO.

Fair Competition

EXG Pro succeeds through innovation and quality — not through anti-competitive conduct. We never:

• Engage in price fixing, bid rigging or market allocation
• Share competitively sensitive information with competitors
• Enter into anti-competitive agreements
• Mislead customers about product functionality
• Disparage competitors unfairly or dishonestly

If approached by a competitor on any commercial subject, consult the COO or Legal before engaging.

Conflicts of Interest

We do not allow personal interests to interfere with our EXG Pro responsibilities. Disclose promptly to HR or your line manager if you have:

• Personal financial interests in suppliers or competitors
• Outside employment or advisory roles with competitors
• Family or personal relationships influencing procurement or hiring
• Undisclosed board positions or significant external roles

Transparency protects you and the business.

Responsible Use of Company Assets

We are each responsible for the proper use of EXG Pro assets — physical and digital:

• Use company equipment and systems for business purposes
• Keep devices password protected and use secure connections
• Use only approved software and platforms
• Report loss, theft or damage immediately
• Be mindful in public — do not discuss confidential information where you may be overheard

Supporting Policies: Anti-corruption and Bribery Policy · Disciplinary & Capability Procedure · IT and Communications Systems Policy

Our Customers

We Serve Our Fans First

EXG Pro exists for the fans. Our customers trust us to deliver products that are authentic, functional, and worth their investment. We earn and protect that trust by:

• Accurately representing product functionality and specifications
• Delivering on every promise — and making it right when we fall short
• Treating every customer interaction with honesty and professionalism
• Ensuring all transactions and sales practices are fair and transparent
• Never applying misleading marketing, inflated claims, or deceptive promotions

Ask: "Would our customer recommend EXG Pro after experiencing the result of my decision?" If not — stop and escalate.

We Protect Customer Information

We handle customer data with the highest levels of care and in strict compliance with GDPR and all applicable data protection legislation:

• Use customer data only for the purposes for which it was provided
• Protect data with secure systems and approved processes
• Honour customer choices regarding data collection and use
• Report any suspected data breach immediately

Data misuse is treated as serious misconduct and may carry criminal liability.

Supporting Policies: Fair Processing Policy (Employee Data) · IT and Communications Systems Policy · Disciplinary & Capability Procedure

Licensors & Intellectual Property

Licensing Integrity is Everything

Our business model is built on the trust of more than 250 global licensing partners. Protecting their IP is fundamental — not optional. We strictly:

• Comply with all terms of every global licensing agreement
• Protect confidential designs, unreleased products and partner data
• Prevent unauthorised disclosure of licensor IP at all times
• Respect all patents, trademarks, copyrights and trade secrets
• Never engage in or facilitate counterfeiting, imitation or infringement
• Seek approval before sharing any partner-related content publicly

Intentional IP breaches may constitute gross misconduct and expose individuals to personal legal liability.

Protecting Our Own IP

EXG Pro's patents, designs, and proprietary technology represent years of innovation. Every employee must protect them:

• Do not share product designs, development plans or launch timelines with unauthorised parties
• Protect physical prototypes and samples in transit and storage
• Do not photograph or share unreleased products on personal devices or social media
• Report any suspected IP theft or unauthorised reproduction immediately

We set trends through originality, technology and attention to detail. We never copy, imitate or shortcut. Our competitive advantage is genuine innovation.

Anti-Bribery & Anti-Corruption

Zero Tolerance

EXG Pro operates a zero-tolerance approach to bribery and corruption globally — at every level, in every market. We prohibit:

• Offering, promising, or accepting bribes in any form
• Kickbacks or improper inducements of any kind
• Facilitation payments — even where locally commonplace
• Improper political or charitable contributions made on EXG Pro's behalf
• Gifts or hospitality that could influence a business decision

This applies globally, including full compliance with the UK Bribery Act 2010 and all equivalent international legislation.

Gifts & Hospitality

All business hospitality and gifts must be:

• Reasonable and proportionate to the business relationship
• Transparently recorded in line with company policy
• Approved in advance where required
• Never offered or accepted in exchange for a business advantage

If a supplier or third party offers you a gift that feels inappropriate — decline it and report the approach to your manager or HR. When in doubt, declare it. The act of declaring protects you.

"If a supplier offers you a gift in exchange for prioritising their products — decline it, and report it immediately."

Supporting Policies: Anti-corruption and Bribery Policy · Whistleblowing Policy · Disciplinary & Capability Procedure

Data Protection & Cybersecurity

We Safeguard All Data

EXG Pro handles sensitive data across all areas of the business. Our commitments include:

• Complying fully with GDPR and all applicable data protection laws
• Using only approved, secure systems and platforms
• Password protecting all devices and never sharing login credentials
• Reporting any suspected data breach immediately
• Disposing of data and records responsibly and in line with retention policies

Data misuse — whether deliberate or negligent — is treated as serious misconduct.

Cybersecurity Vigilance

Our systems, designs and partner data are high-value targets. Every employee must:

• Be alert to phishing attempts and suspicious communications
• Never open unknown attachments or click unverified links
• Use only approved software — avoid unapproved cloud storage tools
• Keep devices secure — especially when travelling or working remotely
• Report any suspicious IT activity immediately

"Protecting our data is protecting our fans, our partners, and our future."

Supporting Policies: Fair Processing Policy (Employee Data) · IT and Communications Systems Policy

Social Media & Brand Representation

We Are All Brand Ambassadors

Every EXG Pro employee represents our brand — in the office, at events, or on personal social media. We celebrate fandom and community, but we protect our brand and partners at all times:

• Protect confidential designs and unreleased products — no posting or sharing without authorisation
• Respect all licensing agreements and brand partner guidelines in public communications
• Make it clearly personal when sharing opinions that are not EXG Pro's position
• Represent EXG Pro positively and professionally in all online spaces
• Never make disparaging comments about colleagues, licensors, retail partners or competitors

Authorised Spokespersons

Only individuals expressly authorised by EXG Pro may speak publicly on the company's behalf. All media enquiries must be referred to the relevant team immediately.

Digital Conduct

Your digital presence — including personal accounts — must not bring EXG Pro or our licensing partners into disrepute. Online conduct outside of work hours is not automatically exempt from this Code if it affects our reputation or relationships.

Environmental Responsibility

Sustainability is at Our Core

At EXG Pro, sustainability is at the heart of what we do. Our goal is to design innovative, high-quality products built to last — items fans can enjoy and treasure for years, even generations. We commit to:

• Plastic-free packaging and ongoing packaging improvement
• Membership of the Ecologi climate action community
• Reduction of unnecessary cables and components
• Embracing Digital Product Passports (DPP) for supply chain transparency
• Responsible sourcing and supply chain oversight
• Adhering to all applicable environmental laws and regulations

Our Sustainability Commitments in Practice

Environmental responsibility is embedded from design through to end of life, including:

• Material and component selection with sustainability criteria
• Packaging design, reduction and plastic-free innovation
• Logistics and distribution planning to reduce emissions
• Manufacturing partner selection and sustainability auditing
• Participating in the Products of Change sustainable community

We hold our supply chain partners to the same environmental standards we set for ourselves.

"Sustainable creativity drives long-term success for our business, our fans, and our planet."

Global Trade & Sanctions Compliance

We Trade Legally and Responsibly

As a global business operating across 60+ markets, EXG Pro must comply with a complex range of trade laws, customs requirements, and international sanctions regimes. We comply fully with:

• Import and export laws in all operating territories
• Customs regulations and accurate product classification
• Sanctions and embargo regimes (UK, EU, US and equivalent)
• Anti-money laundering laws and financial crime regulations
• Restricted party and denied entity screening requirements

When to Seek Guidance

International shipments, technology transfers, and any dealings with parties in sanctioned regions must be assessed for compliance before proceeding. If you are unsure whether a transaction, shipment or partner relationship may be affected — consult the COO or Legal before proceeding.

Never assume compliance, always verify.

EXG Pro never participates in transactions that violate applicable trade laws or sanctions — regardless of commercial pressure or established relationships.

FAQs

Acting with Integrity

Q: What do I do if my manager asks me to do something that feels unethical? No one at EXG Pro has authority to instruct you to violate the law or this Code. Refuse the instruction and report it to HR, the COO, or your line manager. You are fully protected from retaliation.

Q: I saw something at a trade show that concerned me. Do I need to report it? Yes. This Code applies wherever you represent EXG Pro — including events, trade shows, supplier visits, and remote working. Report it through the usual channels.

Licensing & IP

Q: I want to post a photo of a prototype on my personal Instagram. Is that okay? No. Sharing unreleased products — even on personal accounts — breaches this Code and potentially our licensing agreements. Always seek authorisation before sharing any product content publicly.

Q: A licensor contact has informally asked about a product we're planning. Can I discuss it? Raise this with your line manager or the relevant commercial lead first. Even informal disclosures to licensors outside agreed communication channels may create compliance risks.

Anti-Bribery

Q: A supplier has offered me a gift. What should I do? Decline the gift and report it to your manager or HR. If offered in connection with a business decision, it may constitute a bribe — regardless of its value.

Respect & Inclusion

Q: A colleague makes jokes I find offensive. What can I do? Ask them to stop if you feel comfortable doing so. If not, report it to HR or your line manager. EXG Pro does not tolerate offensive conduct and will take appropriate action.

Q: A peer posted disparaging comments about a colleague on social media. Is that a problem? Yes. Making or posting disparaging comments about colleagues — on or off the job — is never acceptable. Always treat each other professionally and with respect.

Conflicts of Interest

Q: My relative has applied for a role at EXG Pro. Can I support their application? You must not attempt to influence the hiring process. Disclose the relationship to HR immediately and recuse yourself from any involvement in that recruitment process.

Q: I've been asked to join an industry board. Can I accept? Disclose it to HR and your line manager before accepting. EXG Pro will review and advise. We reserve the right to decline where the role creates a genuine conflict of interest.

Data & Cybersecurity

Q: I think a data breach may have occurred. What do I do? Report it immediately to your manager and the relevant IT/security contact. Do not wait — time is critical. Do not attempt to investigate or resolve it yourself.

Q: I received a suspicious email that looked like it was from a licensor. What should I do? Do not click any links or open attachments. Report the email to IT immediately. Phishing attacks often impersonate trusted partners — stay vigilant.

Your Commitment to This Code

All employees and applicable third parties are required to certify annually that they have:

• Read and understood this Code of Business Conduct
• Completed all required associated training
• Disclosed any known conflicts of interest
• Agreed to comply with all obligations set out herein

This certification is your personal commitment to the values and standards that protect EXG Pro, our partners, and the fans we serve.

This Code is reviewed and updated annually by the Board and Executive Leadership. All material changes will be communicated to employees.

Governance & Oversight

The Board and Executive Leadership team are responsible for:

• Monitoring compliance with this Code across the business
• Periodic review of Code content to reflect legal and operational changes
• Maintaining a risk management framework aligned with our values
• Leading and modelling an ethical culture at every level

Leadership is held to the same standard as every other employee. No exceptions.

Contact — Code of Conduct & Ethics Leadership Team

For general enquiries: info@exgpro.com