Compliance Manual

Destinycloud - Ethics and Compliance Manual

Version 1.0

Date: November 2025

Company: Destinycloud, Lda

Address: Rua Dr. José Leite dos Santos, nº 44, 4760-726 Ribeirão, Vila Nova de Famalicão, Portugal

Email: compliance@destinycloud.pt

1. Message from the CEO

At Destinycloud, we believe that technology has real impact only when it is guided by integrity, responsibility, and respect. Our success has always depended on trust, the trust of our clients, our partners, and our team members around the world.

This Ethics and Compliance Manual reflects our commitment to doing business the right way: transparently, ethically, and in full compliance with the laws and principles that govern our work. Each of us plays a part in protecting Destinycloud’s reputation and ensuring that our actions always reflect our values.

We encourage everyone, employees, partners, and collaborators, to speak up when something does not seem right. Integrity is not only a policy at Destinycloud, it is part of who we are.

Thank you for upholding these principles in everything you do.

Miguel Coutinho

2. Compliance Policy

Destinycloud is committed to conducting its business in full compliance with all applicable laws, regulations, and ethical standards in every country where it operates. Compliance is a shared responsibility that supports trust, transparency, and long-term sustainability.

Scope

This policy applies to all employees, contractors, consultants, and third parties acting on behalf of Destinycloud.

Core Principles

. All actions must comply with applicable laws and regulations.

. Integrity: Employees must act honestly and responsibly in all business dealings.

. Transparency: Decisions should be made openly and documented appropriately.

. Accountability: Managers are responsible for ensuring compliance within their teams.

. Reporting: Any suspected violations must be reported immediately through the proper channels.

3. Code of Business Conduct and Ethics

Destinycloud’s Code of Business Conduct and Ethics establishes the standards of behavior expected from all who represent the company. It aims to ensure professionalism, fairness, and integrity in all operations.

Standards of Conduct

. Integrity and Honesty: Always act with integrity and truthfulness.

. Fair Competition: Compete fairly and respect intellectual property rights.

. Conflicts of Interest: Avoid situations that could compromise objectivity.

. Confidential Information: Protect company and client information from unauthorized disclosure.

. Use of Company Assets: Use company assets responsibly and for legitimate business purposes only.

. Respect and Inclusion: Treat all individuals with dignity and respect, fostering a diverse and inclusive environment.

. Data Protection: Respect privacy and comply with data protection laws, including GDPR.

4. Anti-Corruption and Anti-Bribery Policy

Destinycloud maintains a zero-tolerance policy toward bribery and corruption. We are committed to preventing, detecting, and addressing any form of corrupt practice in our operations and relationships.

Key Principles

. Prohibition of Bribery: No employee or representative may offer, give, request, or accept bribes or facilitation payments.

. Gifts and Hospitality: Modest and reasonable gifts or hospitality may be accepted if they are transparent, lawful, and never intended to influence a decision.

. Third Parties: Business partners, suppliers, and agents must comply with this policy and undergo due diligence when appropriate.

. Political and Charitable Contributions: Must never be used to gain improper business advantages.

. Books and Records: All transactions must be recorded accurately and transparently.

Training: Employees will receive guidance and training to understand and comply with anti-corruption obligations.

5. Reporting Concerns

Destinycloud encourages all individuals to report any suspected violations of this manual or any unethical behavior. Reports may be submitted confidentially to compliance@destinycloud.pt

The company will investigate all reports promptly and fairly. Retaliation against anyone who reports concerns in good faith is strictly prohibited.

6. Enforcement and Review

Failure to comply with this manual may result in disciplinary action, including termination of employment or contract. Destinycloud may also report violations to relevant authorities when required by law.

This manual will be reviewed annually to ensure it remains up to date with legal and ethical standards.