To our stakeholders:

I am pleased to confirm that SYNCHRO Engineering Co. Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,

Mr. Mohammed Jamaleldein
Managing Director

Significantly, SYNCHRO’s management not only see human rights as important for avoiding the negative impacts of human rights abuse during its operation, we also acknowledged the opportunities that lay in ensuring high human rights standards across our services, workforce and consumers.

Our insights have been summarized into the six best practices for SYNCHRO as small and medium-sized enterprises to integrate human rights into our business operations as follows:
1. Understand risks and impacts: We used to identify our business’s human rights risks and impacts and know our scope of responsibility.
2. Educate employees: We ensure our employee are aware of basic human rights principles so they are better prepared and can help integrate them into the business.
3. Articulate commitment: We publicly share our company’s commitment to human rights through a policy or statement.
4. Embed in the business: We integrate human rights into our existing business systems and processes; develop capacity building for relevant personnel.
5. Be transparent: We engage with relevant stakeholders and rights-holders; report publicly on progress and challenges.
6. Provide remedy: We develop an appropriate remedy where SYNCHRO has caused or contributed to harm.

By following these steps, SYNCHRO can make significant strides towards improving human rights standards along its entire value chain, which can have dramatic follow-on effects in terms of employee job satisfaction, community support, and customer satisfaction.

If we are to succeed in advancing human rights among our operations, we must also share a responsibility to move from commitments to impactful everyday actions. And we must challenge ourselves to prevent abusive conditions from happening, as companies must be prepared to understand their impacts and work with others to embed human rights in all they do until they become a universal reality, SYNCHRO remain committed to work with its stockholders to realize that.

S/N Area of Concern Type-1 Type-2
1. Human Rights Planned Abuse 0 Training 7
Actual 0 6
Progress 100% 85.7%

2.2.1. Code of Conduct and Ethics
SYNCHRO has a published it’s Code of Conduct and Ethics which is communicated to all employees and publicly available on our corporate website.

The purpose of the Code is to ensure that all SYNCHRO employees and those acting on our behalf are aware of the standards of ethical behavior and integrity in all business dealings that are required of all Directors, management and staff. These standards both protect us from business risk and support the development of trust and positive relationships with all business associates, colleagues and partners.

2.2.2. Workplace Practices
At SYNCHRO, we strive to attract, engage and retain employees who can help deliver our business strategy in a way which aligns with our core commitment to our core values, ethical conduct and integrity in all we do. Our commitment to our employees is to respect and uphold their rights in all aspects of their employment and engagement with SYNCHRO.

Our approach to creating an ethical working environment stems from a basic appreciation and respect for core internationally accepted labor standards. These employee rights are encompassed in the globally ratified International Labor Organization's Declaration of Fundamental Principles and Rights at Work which we support, and are enhanced by advanced human resources practices which make SYNCHRO not only a great place to work, but also an ethical one.

2.2.3. Employee Rights
We believe that employees should know their rights in respect of their employment with our Company. Employees join SYNCHRO out of their own free will and in full agreement to the proposed terms and conditions. We do not require any employee to remain in employment for any period of time against his or her will, or use practices which restrict employees' ability to terminate employment. We do not engage in forced labor in any way, and we do not employ children in any part of our business operations. As a minimum, SYNCHRO employees are rewarded in accordance with laws and regulations governing salaries and benefits in each country in which we operate.

Further, we respect the right of employees to open communication and human and equitable treatment. We maintain open and direct communication with our employees and encourage their full participation in our business. We provide updates to employees about business activities and results, and all other matters which affect them, or may help them perform their roles more effectively.

During the course of employment, management and members of our Human Resources team are committed to responding to all questions or grievances raised by employees relating to terms and conditions, rights and any other matters of concern.

2.2.4. Equal Opportunity, Diversity and Inclusion
SYNCHRO strive to maintain an inclusive work culture in which each employee feels respected and valued and has the opportunity to develop and grow in line with business needs and personal aspirations.

We offer all individuals equal opportunity to join the Company, and to progress within the Company according to performance and potential.

We embrace employees from all possible backgrounds representing different dimensions of diversity which include gender, race, color, religion, nationality, age, sexual orientation, disability, marital status, and other aspects of diversity.

We aim to ensure that our workplace is free of all forms of discrimination, harassment, violence and other behaviors which might negatively impact the workplace experience, such as alcohol or substance-abuse.

2.2.5. Gender Equality and Women’s Empowerment
• The promotion of gender equality and the empowerment of women are central to the mandate of SYNCHRO and intrinsic to its human rights-based approach to development programming. This effort includes advocating for women’s and girls’ human rights, combating discriminatory practices, and challenging the roles and stereotypes that create inequalities and exclusion.
• SYNCHRO Projects will be gender-responsive in their design and implementation. SYNCHRO will seek to identify and integrate the different needs, constraints, contributions and priorities of women, men, girls and boys into its programming.
• SYNCHRO Projects will promote gender equality and the empowerment of women. SYNCHRO will seek to reduce gender inequalities in access to and control over resources and the benefits of development. Projects will ensure that both women and men are able to participate meaningfully and equitably, have equitable access to Programme and Project resources, and receive comparable social and economic benefits.
• SYNCHRO will ensure that its Projects do not discriminate against women or girls or reinforce gender-based discrimination and/or inequalities

2.2.6. Employee Health and Safety
SYNCHRO aims to provide all employees with a workplace which is healthy and safe, and free from all known health and safety risks. We observe all laws and regulations regarding employee safety and nominate Safety Officers in key locations to ensure safe working practices are upheld.

2.2.7. Human Rights in our Supply Chain
SYNCHRO aim to uphold the human rights of all those affected by our business activities, and in particular, of the employees engaged in our supply chain; This is not only the right thing to do; it also helps protect our business from risk. We are guided by our respect for internationally recognized human rights, which include those set out in the Universal Declaration of Human Rights and in the International Labor Organization's Declaration of Fundamental Principles and Rights at Work.

We uphold all applicable laws in all countries in which we operate, and go beyond the law where relevant in order to do the right thing and treat all those with whom we interact with respect and dignity.

2.2.8. Supplier Engagement and Contract Operations
We work with outsourced vendors for the supply of our products and components which are manufactured and assembled to our specifications. In general, we cultivate long-term relationships with our outsourced vendors, who are of themselves large national or global, respected business operations that are familiar with our approach to human rights and labor standards. Of necessity, we work closely with our outsourced suppliers enabling us to observe the standards that are maintained and the workplace conditions provided to their employees.

We strive to have our outsourced vendors and key suppliers confirm that they observe the following practices which protect labor rights and human rights:
• Respect for employees and treating employees with dignity, applying humane, decent and fair practices. To the extent possible, suppliers will invest in employee training and development.
• Encourage diversity and avoidance of discrimination in the workplace.
• Declare support for freely chosen employment and prohibit any form of forced labor.
• Prohibit child labor under the legal age permitted by law in the country of operation.
• Act in accordance with working hours as defined by local laws.
• Observe laws and regulations relating to health and safety of employees.
• Compensate employees in accordance with applicable laws and regulations.
• Provide formal grievance mechanisms for employees to voice their concerns and receive appropriate acknowledgement without fear of retaliation.

2.2.9. Sourcing and Supply
We aim to source all the materials used in our supply chain for the manufacture of our products in a way which upholds human rights, for example, taking in to account the rights of indigenous peoples in extractive industries for metals and elements used in our products.

We expect our suppliers to engage in responsible sourcing practices, using verified sources where possible. Consistent with this Policy SYNCHRO established a detailed Conflict Minerals Policy addressing the Human Rights and environmental issues connected with the mining and trading of tantalum, tin tungsten and gold which are used in the electronics industry supply chain.

2.2.1. Code of Conduct and Ethics
SYNCHRO has a published it’s Code of Conduct and Ethics which is communicated to all employees and publicly available on our corporate website.

The purpose of the Code is to ensure that all SYNCHRO employees and those acting on our behalf are aware of the standards of ethical behavior and integrity in all business dealings that are required of all Directors, management and staff. These standards both protect us from business risk and support the development of trust and positive relationships with all business associates, colleagues and partners.

2.2.2. Workplace Practices
At SYNCHRO, we strive to attract, engage and retain employees who can help deliver our business strategy in a way which aligns with our core commitment to our core values, ethical conduct and integrity in all we do. Our commitment to our employees is to respect and uphold their rights in all aspects of their employment and engagement with SYNCHRO.

Our approach to creating an ethical working environment stems from a basic appreciation and respect for core internationally accepted labor standards. These employee rights are encompassed in the globally ratified International Labor Organization's Declaration of Fundamental Principles and Rights at Work which we support, and are enhanced by advanced human resources practices which make SYNCHRO not only a great place to work, but also an ethical one.

2.2.3. Employee Rights
We believe that employees should know their rights in respect of their employment with our Company. Employees join SYNCHRO out of their own free will and in full agreement to the proposed terms and conditions. We do not require any employee to remain in employment for any period of time against his or her will, or use practices which restrict employees' ability to terminate employment. We do not engage in forced labor in any way, and we do not employ children in any part of our business operations. As a minimum, SYNCHRO employees are rewarded in accordance with laws and regulations governing salaries and benefits in each country in which we operate.

Further, we respect the right of employees to open communication and human and equitable treatment. We maintain open and direct communication with our employees and encourage their full participation in our business. We provide updates to employees about business activities and results, and all other matters which affect them, or may help them perform their roles more effectively.

During the course of employment, management and members of our Human Resources team are committed to responding to all questions or grievances raised by employees relating to terms and conditions, rights and any other matters of concern.

2.2.4. Equal Opportunity, Diversity and Inclusion
SYNCHRO strive to maintain an inclusive work culture in which each employee feels respected and valued and has the opportunity to develop and grow in line with business needs and personal aspirations.

We offer all individuals equal opportunity to join the Company, and to progress within the Company according to performance and potential.

We embrace employees from all possible backgrounds representing different dimensions of diversity which include gender, race, color, religion, nationality, age, sexual orientation, disability, marital status, and other aspects of diversity.

We aim to ensure that our workplace is free of all forms of discrimination, harassment, violence and other behaviors which might negatively impact the workplace experience, such as alcohol or substance-abuse.

2.2.5. Gender Equality and Women’s Empowerment
• The promotion of gender equality and the empowerment of women are central to the mandate of SYNCHRO and intrinsic to its human rights-based approach to development programming. This effort includes advocating for women’s and girls’ human rights, combating discriminatory practices, and challenging the roles and stereotypes that create inequalities and exclusion.
• SYNCHRO Projects will be gender-responsive in their design and implementation. SYNCHRO will seek to identify and integrate the different needs, constraints, contributions and priorities of women, men, girls and boys into its programming.
• SYNCHRO Projects will promote gender equality and the empowerment of women. SYNCHRO will seek to reduce gender inequalities in access to and control over resources and the benefits of development. Projects will ensure that both women and men are able to participate meaningfully and equitably, have equitable access to Programme and Project resources, and receive comparable social and economic benefits.
• SYNCHRO will ensure that its Projects do not discriminate against women or girls or reinforce gender-based discrimination and/or inequalities

2.2.6. Employee Health and Safety
SYNCHRO aims to provide all employees with a workplace which is healthy and safe, and free from all known health and safety risks. We observe all laws and regulations regarding employee safety and nominate Safety Officers in key locations to ensure safe working practices are upheld.

2.2.7. Human Rights in our Supply Chain
SYNCHRO aim to uphold the human rights of all those affected by our business activities, and in particular, of the employees engaged in our supply chain; This is not only the right thing to do; it also helps protect our business from risk. We are guided by our respect for internationally recognized human rights, which include those set out in the Universal Declaration of Human Rights and in the International Labor Organization's Declaration of Fundamental Principles and Rights at Work.

We uphold all applicable laws in all countries in which we operate, and go beyond the law where relevant in order to do the right thing and treat all those with whom we interact with respect and dignity.

2.2.8. Supplier Engagement and Contract Operations
We work with outsourced vendors for the supply of our products and components which are manufactured and assembled to our specifications. In general, we cultivate long-term relationships with our outsourced vendors, who are of themselves large national or global, respected business operations that are familiar with our approach to human rights and labor standards. Of necessity, we work closely with our outsourced suppliers enabling us to observe the standards that are maintained and the workplace conditions provided to their employees.

We strive to have our outsourced vendors and key suppliers confirm that they observe the following practices which protect labor rights and human rights:
• Respect for employees and treating employees with dignity, applying humane, decent and fair practices. To the extent possible, suppliers will invest in employee training and development.
• Encourage diversity and avoidance of discrimination in the workplace.
• Declare support for freely chosen employment and prohibit any form of forced labor.
• Prohibit child labor under the legal age permitted by law in the country of operation.
• Act in accordance with working hours as defined by local laws.
• Observe laws and regulations relating to health and safety of employees.
• Compensate employees in accordance with applicable laws and regulations.
• Provide formal grievance mechanisms for employees to voice their concerns and receive appropriate acknowledgement without fear of retaliation.

2.2.9. Sourcing and Supply
We aim to source all the materials used in our supply chain for the manufacture of our products in a way which upholds human rights, for example, taking in to account the rights of indigenous peoples in extractive industries for metals and elements used in our products.

We expect our suppliers to engage in responsible sourcing practices, using verified sources where possible. Consistent with this Policy SYNCHRO established a detailed Conflict Minerals Policy addressing the Human Rights and environmental issues connected with the mining and trading of tantalum, tin tungsten and gold which are used in the electronics industry supply chain.

2. Labours Planned Hire of Disable Persons 4 Gender Balance 50%
Actual 2 30%
Progress 50% 60%

2.3.1. SYNCHRO Environmental Vision:
SYNCHRO target is to be one of the familiar leaders in the environment protection, for both, plant design and work locations, and ultimately achieve the goal of preventing all environmental accidents. Views safe design plans to be an integral part of the quality of the services supplied to the client and consider environment to be the primary duty of an employer.

2.3.2. SYNCHRO Commitment
SYNCHRO is responsibility for creating and sustaining a culture that supports the implementation of high standards of environment. Corporate Management, therefore, provides the necessary leadership and commitment to ensure that the necessary resources to develop operate and maintain the Environmental Management Program and to achieve the environment Policy and objectives.

2.3.3. Environmental Management Systems
SYNCHRO aspires to high standards of practice through a process of continuous improvement and the adoption of international codes and standards where practicable. To meet this commitment we will implement environmental management systems in; construction; operations that accord with the Requirements of environmental standards and abide to:
• Target zero accidents or incidents.
• Ensure that operations and activities comply with applicable environmental laws and regulations
• Implement procedures to insure controllable protection measure to all personnel involved in our activities, to prevent pollution and to protect Biodiversity.
• Provide environmental training to our employees and actively promote awareness of environmental issues
• Ensure that sub-contractors; consortiums are aware of SYNCHRO policy and standards and share experience of environment to meet higher standards.
• Foster a culture where accidents, incidents and near misses are reported and investigated and the lessons learned are shared throughout the organization.
• Monitor performance and conduct regular audits to ensure our controls are effective and that environmental aspirations are being achieved.
• Set objectives and targets for improving environmental performance and monitor Reports
• Ensure that a high priority is placed on emergency preparedness and contingency planning, and regularly tested, so that any incidents can be responded to in a timely and effective manner
• Work with Government and regulatory bodies in the formulation or improvement of laws, policies, regulations and procedures aimed at protecting the environment
• Consult with and respond to the concerns of other stakeholders on our environmental Performance.
• Responsibility for compliance with SYNCHRO's environment policy and standards lies with the SYNCHRO HSE executive director; managers and all personnel relatively rank. SYNCHRO General Director Assumes ultimate responsibility for environment.

2.3.1. SYNCHRO Environmental Vision:
SYNCHRO target is to be one of the familiar leaders in the environment protection, for both, plant design and work locations, and ultimately achieve the goal of preventing all environmental accidents. Views safe design plans to be an integral part of the quality of the services supplied to the client and consider environment to be the primary duty of an employer.

2.3.2. SYNCHRO Commitment
SYNCHRO is responsibility for creating and sustaining a culture that supports the implementation of high standards of environment. Corporate Management, therefore, provides the necessary leadership and commitment to ensure that the necessary resources to develop operate and maintain the Environmental Management Program and to achieve the environment Policy and objectives.

2.3.3. Environmental Management Systems
SYNCHRO aspires to high standards of practice through a process of continuous improvement and the adoption of international codes and standards where practicable. To meet this commitment we will implement environmental management systems in; construction; operations that accord with the Requirements of environmental standards and abide to:
• Target zero accidents or incidents.
• Ensure that operations and activities comply with applicable environmental laws and regulations
• Implement procedures to insure controllable protection measure to all personnel involved in our activities, to prevent pollution and to protect Biodiversity.
• Provide environmental training to our employees and actively promote awareness of environmental issues
• Ensure that sub-contractors; consortiums are aware of SYNCHRO policy and standards and share experience of environment to meet higher standards.
• Foster a culture where accidents, incidents and near misses are reported and investigated and the lessons learned are shared throughout the organization.
• Monitor performance and conduct regular audits to ensure our controls are effective and that environmental aspirations are being achieved.
• Set objectives and targets for improving environmental performance and monitor Reports
• Ensure that a high priority is placed on emergency preparedness and contingency planning, and regularly tested, so that any incidents can be responded to in a timely and effective manner
• Work with Government and regulatory bodies in the formulation or improvement of laws, policies, regulations and procedures aimed at protecting the environment
• Consult with and respond to the concerns of other stakeholders on our environmental Performance.
• Responsibility for compliance with SYNCHRO's environment policy and standards lies with the SYNCHRO HSE executive director; managers and all personnel relatively rank. SYNCHRO General Director Assumes ultimate responsibility for environment.

3. Environment Planned Accidents 0 Protection Action 2
Actual 0 2
Progress 100% 100%

2.4.1. Background and Overview
SYNCHRO aims to maintain a high standard of ethical business behavior at all times and expects its directors and employees to observe the highest standards of honesty, integrity and ethical behavior in performing their duties. Overarching this code is the value of a culture of consultation that is encouraged and practiced within SYNCHRO.

The purpose of this code is to:
• Articulate the high standards of honest, ethical and legal behavior expected of SYNCHRO directors and employees;
• Encourage the observance of those standards so as to protect and promote the interests of our investors and other stakeholders;
• Guide executive and non-executive directors and employees as to the practices thought necessary to maintain confidence in SYNCHRO’s reputation for honesty and integrity;
• Set out the responsibility and accountability of both directors and employees to report, and investigate reports of, unethical practices; and;
• Support SYNCHRO’s vision to be the preferred real estate fund manager, or development partner for investors and other stake holders (EXPAND TO INCLUDE MAXIM).

2.4.2. Compliance with Laws, Regulations, Policies & Procedures
SYNCHRO requires and expects its directors and employees to:
• Comply with all laws, rules and regulations that apply to SYNCHRO in the conduct of its business and affairs;
• Abide by all applicable rules and standards of bodies empowered to regulate the industries in which SYNCHRO operates;
• Comply with all contractual obligations and other undertakings without attempting to evade or delay compliance;
• Abide by all protocols, policies and procedures of SYNCHRO; and acquire sufficient knowledge of the laws and regulations to undertake their duties and know when to seek advice.
Employees are encouraged to seek guidance from SYNCHRO’S Managing Director concerning the appropriate response to perceived unethical behavior encountered within the business or by competitors or suppliers.
SYNCHRO, its directors and employees will cooperate with regulatory bodies in any properly constituted investigation relevant to the business or the industries in which it operates.

2.4.3. Honesty and Integrity
SYNCHRO expects that its directors and employees will:
• Deal fairly and consistently with all parties and not permit their own interests to override the interests of SYNCHRO’s investors, customers and other stakeholders;
• Be respectful in all dealings with others and treat them openly and honestly without prejudice or discrimination;
• Not behave in a manner that is fraudulent, corrupt or unlawful;
• Refuse all payments and incentives from third parties that may compromise decisions or judgments; and
• Behave in a manner that is not only lawful but that also complies with current moral and community standards.

2.4.4. Proper Use of Position and Resources
SYNCHRO requires its directors and employees to comply with their legal, statutory and fiduciary duties as officers or employees of SYNCHRO. Broadly this includes duties to:
• Act in good faith and in the best interests of SYNCHRO as a whole;
• Act with due care and diligence;
• Act for proper purposes;
• Avoid conflicts of interest or duty; and
• Refrain from:
i. Making improper use of information gained through their office or employment;
ii. Taking improper advantage of their position; and
iii. Soliciting gifts or benefits from other parties for personal use or gain.

2.4.5. Gifts and Entertainment
As stated in the previous section all directors and employees must refrain from soliciting gifts or benefits from other parties. All employees must exercise due care and discretion when giving or receiving business related gifts.
In general, reasonable offers of gifts and entertainment such as social or sporting events, of moderate value, may be provided or accepted where it is legal and in accordance with business practice. However, gifts of travel or accommodation must not be accepted unless it is approved by the Managing Director, and in the case of any director approved by the Chairman of SYNCHRO. Employees should consult the Managing Director, or failing him/her the Chairman of SYNCHRO, if they are in any doubt as to whether they should make or accept any offer of a gift or entertainment over $500.00 in value.
In addition, it is permitted to accept a discount from a supplier when that discount is made available to all SYNCHRO employees.
Accepting secret commissions is forbidden and against the law.

2.4.6. Political and Charitable Donations
SYNCHRO will not make political donations.
Employees are prohibited from engaging the services of professional lobbyists to act on behalf of SYNCHRO.
From time to time SYNCHRO may make donations to charitable and not for profit organizations and causes as part of its commitment to good corporate social responsibility.

2.4.7. Confidentiality and Privacy
All directors and employees must:
• maintain the confidentiality of all proprietary, commercial or other information that is confidential to SYNCHRO, its customers, suppliers or employees that is acquired in the course of performing their duties; and
• Not make improper use of, or improperly disclose, such confidential information to third parties, except as otherwise approved by the respective Boards of SYNCHRO, FFML, FIML, FREML and Maxim, or required by law.

All directors and employees must treat all information given to SYNCHRO by investors, customers and other stakeholders as confidential. SYNCHRO is committed to the protection of individual privacy. All directors and employees must comply with the privacy or data protection laws of those jurisdictions in which SYNCHRO operates. All directors and employees must observe SYNCHRO’s Privacy Policy when collecting, using, disclosing and providing access to personal information.
These obligations of confidentiality continue after individuals leave SYNCHRO.

2.4.8. Conflicts of Interest
Managing conflicts of interest is the key to maintaining our client’s loyalty and building business through trust. A conflict of interest may arise if directors, employees or their families, friends or business associates have a personal interest in a business decision involving SYNCHRO.
All directors and employees must use all reasonable endeavors to avoid being in a situation in which their personal or external interests could conflict with the best interests of SYNCHRO or any of the funds that it acts as Trustee or Responsible Entity.
All conflicts of interest are to be dealt with under the procedures set out in SYNCHRO’s Conflict of Interest and Related Party Transaction Policy.

2.4.9. Fair Dealing
SYNCHRO will respect the rights and dignity of employees by providing:
• fair, open, honest, dignified and non-discriminatory treatment;
• a safe and healthy working environment;
• training and development to maximize individual potential and contribution to SYNCHRO;
• Fair and equitable remuneration; and the opportunity to give and receive feedback on their work and individual performance.

SYNCHRO expects its directors and employees to deal fairly and honestly with its investors, customers, suppliers, competitors and fellow employees.
SYNCHRO expects that its directors and employees will not take unfair advantage of any party dealing with the Group through illegal conduct, manipulation, undue influence, concealment, abuse of privileged or confidential information, misrepresentation of material facts, or any other unfair dealing practice.

2.4.10. Protection and Proper use of SYNCHRO’s Assets
Directors and employees must protect the assets of SYNCHRO (including proprietary information such as intellectual property, business and marketing plans, employee information, and any other information concerning SYNCHRO that is not generally known to the public, subject to SYNCHRO’ Continuous Disclosure obligations). This obligation to protect SYNCHRO’s assets continues after directors and employees retire from or otherwise cease employment with SYNCHRO.

2.4.11. Compliance with the Code of Conduct
SYNCHRO encourages its directors and employees to report promptly, in good faith, any serious violations or suspected serious violations of this Code of Conduct. Employees should report any such violations to the Managing Director.
Where a director or employee (“Reporting Person”) reports in good faith an actual or suspected violation of this Code of Conduct, the position of the Reporting Person will be protected, including through the following measures:
• the Reporting Person’s identity will not be revealed without the consent of the Reporting Person (except where such disclosure is required by law); and
• No disciplinary, discriminating or other adverse action will be taken (or tolerated) against the Reporting Person as a consequence of reporting, in good faith, that violation or suspected violation.

SYNCHRO requires that all directors and employees who receive a report of an actual or suspected violation of this Code of Conduct to take all reasonable steps within their control to ensure that:
• The behavior alleged in the report is thoroughly investigated, the rules of natural justice are observed in that investigation and that appropriate disciplinary action is taken if the allegation is substantiated.

Directors and employees who are proven to have breached this Code of Conduct will face disciplinary action which, depending on the seriousness and severity of the breach, could include legal action or dismissal.
Directors and employees will sign an annual declaration that states they have read the SYNCHRO Code of Conduct/Ethical Business Behavior Policy and have adhered to its requirements.

2.4.1. Background and Overview
SYNCHRO aims to maintain a high standard of ethical business behavior at all times and expects its directors and employees to observe the highest standards of honesty, integrity and ethical behavior in performing their duties. Overarching this code is the value of a culture of consultation that is encouraged and practiced within SYNCHRO.

The purpose of this code is to:
• Articulate the high standards of honest, ethical and legal behavior expected of SYNCHRO directors and employees;
• Encourage the observance of those standards so as to protect and promote the interests of our investors and other stakeholders;
• Guide executive and non-executive directors and employees as to the practices thought necessary to maintain confidence in SYNCHRO’s reputation for honesty and integrity;
• Set out the responsibility and accountability of both directors and employees to report, and investigate reports of, unethical practices; and;
• Support SYNCHRO’s vision to be the preferred real estate fund manager, or development partner for investors and other stake holders (EXPAND TO INCLUDE MAXIM).

2.4.2. Compliance with Laws, Regulations, Policies & Procedures
SYNCHRO requires and expects its directors and employees to:
• Comply with all laws, rules and regulations that apply to SYNCHRO in the conduct of its business and affairs;
• Abide by all applicable rules and standards of bodies empowered to regulate the industries in which SYNCHRO operates;
• Comply with all contractual obligations and other undertakings without attempting to evade or delay compliance;
• Abide by all protocols, policies and procedures of SYNCHRO; and acquire sufficient knowledge of the laws and regulations to undertake their duties and know when to seek advice.
Employees are encouraged to seek guidance from SYNCHRO’S Managing Director concerning the appropriate response to perceived unethical behavior encountered within the business or by competitors or suppliers.
SYNCHRO, its directors and employees will cooperate with regulatory bodies in any properly constituted investigation relevant to the business or the industries in which it operates.

2.4.3. Honesty and Integrity
SYNCHRO expects that its directors and employees will:
• Deal fairly and consistently with all parties and not permit their own interests to override the interests of SYNCHRO’s investors, customers and other stakeholders;
• Be respectful in all dealings with others and treat them openly and honestly without prejudice or discrimination;
• Not behave in a manner that is fraudulent, corrupt or unlawful;
• Refuse all payments and incentives from third parties that may compromise decisions or judgments; and
• Behave in a manner that is not only lawful but that also complies with current moral and community standards.

2.4.4. Proper Use of Position and Resources
SYNCHRO requires its directors and employees to comply with their legal, statutory and fiduciary duties as officers or employees of SYNCHRO. Broadly this includes duties to:
• Act in good faith and in the best interests of SYNCHRO as a whole;
• Act with due care and diligence;
• Act for proper purposes;
• Avoid conflicts of interest or duty; and
• Refrain from:
i. Making improper use of information gained through their office or employment;
ii. Taking improper advantage of their position; and
iii. Soliciting gifts or benefits from other parties for personal use or gain.

2.4.5. Gifts and Entertainment
As stated in the previous section all directors and employees must refrain from soliciting gifts or benefits from other parties. All employees must exercise due care and discretion when giving or receiving business related gifts.
In general, reasonable offers of gifts and entertainment such as social or sporting events, of moderate value, may be provided or accepted where it is legal and in accordance with business practice. However, gifts of travel or accommodation must not be accepted unless it is approved by the Managing Director, and in the case of any director approved by the Chairman of SYNCHRO. Employees should consult the Managing Director, or failing him/her the Chairman of SYNCHRO, if they are in any doubt as to whether they should make or accept any offer of a gift or entertainment over $500.00 in value.
In addition, it is permitted to accept a discount from a supplier when that discount is made available to all SYNCHRO employees.
Accepting secret commissions is forbidden and against the law.

2.4.6. Political and Charitable Donations
SYNCHRO will not make political donations.
Employees are prohibited from engaging the services of professional lobbyists to act on behalf of SYNCHRO.
From time to time SYNCHRO may make donations to charitable and not for profit organizations and causes as part of its commitment to good corporate social responsibility.

2.4.7. Confidentiality and Privacy
All directors and employees must:
• maintain the confidentiality of all proprietary, commercial or other information that is confidential to SYNCHRO, its customers, suppliers or employees that is acquired in the course of performing their duties; and
• Not make improper use of, or improperly disclose, such confidential information to third parties, except as otherwise approved by the respective Boards of SYNCHRO, FFML, FIML, FREML and Maxim, or required by law.

All directors and employees must treat all information given to SYNCHRO by investors, customers and other stakeholders as confidential. SYNCHRO is committed to the protection of individual privacy. All directors and employees must comply with the privacy or data protection laws of those jurisdictions in which SYNCHRO operates. All directors and employees must observe SYNCHRO’s Privacy Policy when collecting, using, disclosing and providing access to personal information.
These obligations of confidentiality continue after individuals leave SYNCHRO.

2.4.8. Conflicts of Interest
Managing conflicts of interest is the key to maintaining our client’s loyalty and building business through trust. A conflict of interest may arise if directors, employees or their families, friends or business associates have a personal interest in a business decision involving SYNCHRO.
All directors and employees must use all reasonable endeavors to avoid being in a situation in which their personal or external interests could conflict with the best interests of SYNCHRO or any of the funds that it acts as Trustee or Responsible Entity.
All conflicts of interest are to be dealt with under the procedures set out in SYNCHRO’s Conflict of Interest and Related Party Transaction Policy.

2.4.9. Fair Dealing
SYNCHRO will respect the rights and dignity of employees by providing:
• fair, open, honest, dignified and non-discriminatory treatment;
• a safe and healthy working environment;
• training and development to maximize individual potential and contribution to SYNCHRO;
• Fair and equitable remuneration; and the opportunity to give and receive feedback on their work and individual performance.

SYNCHRO expects its directors and employees to deal fairly and honestly with its investors, customers, suppliers, competitors and fellow employees.
SYNCHRO expects that its directors and employees will not take unfair advantage of any party dealing with the Group through illegal conduct, manipulation, undue influence, concealment, abuse of privileged or confidential information, misrepresentation of material facts, or any other unfair dealing practice.

2.4.10. Protection and Proper use of SYNCHRO’s Assets
Directors and employees must protect the assets of SYNCHRO (including proprietary information such as intellectual property, business and marketing plans, employee information, and any other information concerning SYNCHRO that is not generally known to the public, subject to SYNCHRO’ Continuous Disclosure obligations). This obligation to protect SYNCHRO’s assets continues after directors and employees retire from or otherwise cease employment with SYNCHRO.

2.4.11. Compliance with the Code of Conduct
SYNCHRO encourages its directors and employees to report promptly, in good faith, any serious violations or suspected serious violations of this Code of Conduct. Employees should report any such violations to the Managing Director.
Where a director or employee (“Reporting Person”) reports in good faith an actual or suspected violation of this Code of Conduct, the position of the Reporting Person will be protected, including through the following measures:
• the Reporting Person’s identity will not be revealed without the consent of the Reporting Person (except where such disclosure is required by law); and
• No disciplinary, discriminating or other adverse action will be taken (or tolerated) against the Reporting Person as a consequence of reporting, in good faith, that violation or suspected violation.

SYNCHRO requires that all directors and employees who receive a report of an actual or suspected violation of this Code of Conduct to take all reasonable steps within their control to ensure that:
• The behavior alleged in the report is thoroughly investigated, the rules of natural justice are observed in that investigation and that appropriate disciplinary action is taken if the allegation is substantiated.

Directors and employees who are proven to have breached this Code of Conduct will face disciplinary action which, depending on the seriousness and severity of the breach, could include legal action or dismissal.
Directors and employees will sign an annual declaration that states they have read the SYNCHRO Code of Conduct/Ethical Business Behavior Policy and have adhered to its requirements.

4. Anti-corruption Planned Proven Cases 0 Attempts 0
Actual 0 1
Progress 100% 1%