code-of-conduct-final-EN-PL-4

INTRODUCTION | 5

1. Introduction This Code of Ethics and Business Conduct (the “Code”) is a set of principles intended to support and promote the EXP Global Inc. (“EXP” or the “Company”) way of doing business. It is also intended to protect our employees, client relationships, financial integrity, public image and shareholder value. All EXP policies, including this Code, stem from our core values of: • Integrity: We promote fairness, honesty, professionalism, respectful behavior and safety in everything we do. • Passion: We’re driven to perform and deliver results because we love what we do.Innovative, Creative Spirit • Accountability : We exercise discipline and are committed to treating your money as we do our own. • Transparency: We are dedicated to direct, honest and transparent communications with our clients, employees and stakeholders. • Diversity: We foster an inclusive culture where everyone is equal and provided with opportunities to grow. • Community and sustainability: Through sustainable practices, we develop positive, constructive relationships with the communities where we live, work and play.

These common values must inspire all our actions and decisions and provide a benchmark for everyone.

a. To Whom Does the Code Apply

The Code applies, at all times, to all employees of EXP or its subsidiaries, including the Chief Executive Officer, Officers and members of the Board of Directors (collectively “employee(s)”). EXP’s consultants, representatives or agents are also expected to adhere to the Code when dealing with or acting on behalf of EXP.

b. Obligation to Comply with the Code; Annual Acknowledgment

Every employee at EXP is required to comply with the Code. Newly hired employees will sign an acknowledgment that they have read, understand and will comply with the Code prior to their commencement of work at EXP. All existing employees will be asked to provide this acknowledgement in writing or electronically on an annual basis during a period designated by the Company. The form of acknowledgment is attached as Exhibit A. It is important for all employees to understand that any non-compliance or failure to respect the letter or spirit of this Code or applicable law may result in disciplinary measures commensurate with the violation, up to and including termination of employment.

c. Responsibilities of all EXP person

As Director, Officers or employees of EXP, we assume personal responsibility for understanding and complying with the Code. We must make decisions consistent with the Code and perform our duties with fairness and integrity. Where you are unsure about how to deal with a particular situation, you should speak to your supervisor, Human Resources or the Legal Department.

d. Manager’s Responsibility

All EXP leaders must show a commitment to our values through their actions. They also must promote an environment where compliance is expected and ethical behavior is the norm.