Code of Ethics and Compliance

This Code defines the standards of conduct that govern MKS Law. It consolidates the principles
and internal rules that shape the firm’s operations, decision making, and professional posture. It
applies to all activities and contexts in which MKS Law is represented or acts, directly or indirectly.
Its provisions are permanent, non negotiable, and binding for all personnel.

Structure

This Code is composed of structured sections, each addressing internal conduct, obligations, and
procedures. The structure ensures clarity of application, alignment across teams, and practical use
by leadership and staff. Its format supports integration into internal workflows, onboarding, audits,
and institutional reviews. Sections are interconnected, but may also be used as standalone
references when applied to specific contexts. This document is intended to guide practice, prevent
deviation, and enforce standards uniformly.

Introduction and Purpose

This Code formalizes how MKS Law defines, applies, and enforces its ethical and operational
standards. It exists to prevent misalignment, protect institutional coherence, and ensure
consistency in internal decisions and external positioning. It is mandatory and enforceable across
all roles and levels. It also functions as an internal control mechanism in situations involving
discretion, pressure, or strategic relevance. Its application is required regardless of precedent,
commercial interest, or external influence.

Scope of Application

This Code applies to all individuals acting on behalf of MKS Law, regardless of role, seniority,
contractual terms, or location. This includes permanent and temporary personnel, service providers,
interns, and external consultants. The Code remains binding in all environments where MKS Law is
present, including informal, remote, or collaborative settings. There are no implied exceptions,
operational workarounds, or discretionary exemptions. Compliance is required whether the activity
is internal facing, administrative, or client adjacent.

Fundamental Ethical Principles

Conduct must reflect integrity, consistency, and adherence to this Code. Professionals are
expected to exercise sound judgment and act in line with the firm’s standards, including when
working independently. Discretion does not override established procedures. Where guidance is
unclear, the matter must be escalated rather than decided unilaterally. Personal views do not
replace internal policy. Any ethical breach, whether by action, omission, or tolerated practice, is
treated as a violation with potential institutional impact.
Compliance with Laws and Regulations
All conduct must comply with applicable laws, regulations, and internal compliance requirements.
This includes, without limitation, AML and CFT obligations, anti corruption and anti bribery
requirements, economic and trade sanctions, data protection and privacy rules, and applicable
professional conduct standards. Where multiple rules apply, the strictest standard prevails.
Professionals must not rely on assumptions, precedent, or informal guidance to bypass obligations.
Legal or compliance uncertainty must be escalated for internal review and documented.

Conflicts of Interest

Any situation that may compromise, or appear to compromise, objectivity, independence, or
professional judgment must be identified, reported, and addressed. This includes personal,
financial, familial, or institutional connections that intersect with firm matters or client interests.
Professionals are required to proactively disclose potential conflicts and cooperate with mitigation
procedures. Failure to disclose is considered non compliance. Conflicts are not resolved through
personal judgment or informal arrangements.
Confidentiality and Information Protection
All information accessed, generated, or shared within the scope of work at MKS Law must be
protected from misuse, leakage, or unauthorized access. Confidentiality obligations apply to all
data, documents, conversations, and systems, regardless of perceived sensitivity or formality, and
remain in force after the termination of any engagement. Work related files, documents, and data
must not be stored, copied, or backed up on personal devices or personal storage media, including
personal hard drives, external drives, or personal cloud accounts. Storage, retention, and sharing
are permitted only within firm approved systems and repositories, under the access controls defined
by MKS Law. Only explicitly authorized personnel may access or disseminate restricted content,
and any exception requires prior written authorization and must be documented. Failures in
information handling are treated as serious internal breaches.

Anti Corruption and Bribery

No individual may offer, promise, authorize, or accept any form of undue advantage. This includes
gifts, hospitality, financial benefits, facilitation payments, or indirect arrangements through
intermediaries. All interactions must avoid any perception of impropriety or influence. Internal
approval does not override legal prohibitions. Violations are subject to immediate disciplinary and
legal consequences, regardless of intent or material impact.
Responsibilities of Personnel and Leadership
Compliance with this Code is a personal and collective duty. All professionals must incorporate
these standards into their daily conduct, strategic decisions, and institutional interactions.
Leadership must actively uphold, reinforce, and supervise compliance across teams and projects.
Silence, passive tolerance, or failure to act are also breaches. Delegation of tasks does not transfer
accountability for conduct, oversight, or internal consequences.

Reporting and Investigation Mechanisms

All personnel must report breaches, misconduct, or irregularities through secure internal channels.
Reports are handled confidentially and without retaliation, regardless of role or hierarchy.
Investigations follow structured procedures, with documentation and impartial analysis.
Professionals must cooperate with investigative steps, including providing information,
clarifications, or support. Failure to report known issues constitutes a secondary violation.

Training and Communication

All personnel must undergo mandatory training on this Code and any subsequent updates, with
participation formally recorded as a compliance requirement. Communication of compliance
procedures is centralized, formal, and binding, and any updates, interpretations, or clarifications
become applicable upon issuance. Lack of awareness does not exempt any individual from
responsibility, and each department remains accountable for ensuring procedural alignment and
clear understanding across its teams.

Monitoring, Audit, and Sanctions

The firm applies structured monitoring and audit practices to ensure compliance. Internal reviews
may be periodic, targeted, or event driven. Findings are documented, and corrective actions may
include warnings, suspension, termination, or legal reporting. Sanctions follow internal governance
and must be proportional, consistent, and reviewable. Recurrent violations, normalization of non
compliance, or attempts to interfere with audits escalate consequences.

Review and Update

This Code is reviewed at defined intervals and whenever legal or operational shifts occur. Reviews
are conducted by leadership or designated committees. Once approved, updates take immediate
effect and fully replace previous versions. Historical versions are archived for reference and
accountability. All professionals must ensure they are operating under the current version, without
exception