Code of Conduct

Preface

At Frequency Holdings (FRQN), integrity and clarity guide every decision we make. Our Code of Conduct is not only a compliance requirement. It is the standard that allows us to build trust with shareholders, employees, customers, and partners.

We expect all directors, officers, employees, contractors, and partners to know and follow this Code. Violations can result in corrective action, including termination of employment or engagement. Any waivers of this Code for directors or executive officers must be approved by our Board.

No one at Frequency is ever permitted to retaliate against anyone who reports or participates in an investigation of a potential violation.

I. Avoid Conflicts of Interest

Conflicts of interest occur when personal, financial, or family considerations interfere with independent judgment or the best interests of the Company. Even the appearance of a conflict can damage trust.

Ask yourself: Could this decision benefit me or someone close to me at the expense of Frequency or its stakeholders? If the answer may be “yes,” disclose it immediately and remove yourself from the decision.

II. Ensure Financial Integrity and Responsibility

Our financial records must always be accurate, complete, and transparent. All transactions must be recorded properly, and no employee may falsify or misstate records.

• If your role involves financial reporting, you are responsible for understanding and applying all relevant policies.
• Never interfere with auditing or internal controls.
• If you see any irregularity—no matter how small—report it immediately.

III. Obey the Law

Every employee and director must comply with all applicable laws and regulations. This includes, but is not limited to:

1. Trade Compliance
   Follow all trade, import, and export laws that govern where we can deliver services or share technology.
2. Competition Laws
   Do not engage in practices that restrict fair competition or mislead customers. Always compete honestly and within the law.
3. Insider Trading
   Never use material, non-public information to buy or sell securities, or share it with others. Doing so may constitute insider trading, which is illegal.
4. Anti-Bribery and Anti-Corruption
   Never offer, promise, or accept a bribe in any form. Business courtesies such as meals or small gifts must be modest, infrequent, and never intended to influence decision-making. Dealings with government officials must be handled with the highest level of care and transparency.

IV. Promote a Respectful and Inclusive Workplace

Frequency is committed to a safe, respectful, and inclusive environment. Harassment, discrimination, or abusive conduct are not tolerated.

Our approach is guided by:

• Commitment: Setting a clear tone of respect and inclusion from the top.
• Care: Treating each employee and partner with dignity, especially when concerns are raised.
• Transparency: Being open about our processes and our commitment to addressing issues.
• Fairness: Applying policies consistently and without favoritism.
• Accountability: Holding ourselves and one another responsible for actions and outcomes.

V. Confidentiality and Data Protection

Every member of the Frequency team is responsible for safeguarding proprietary information, shareholder data, and customer privacy.

• Do not disclose confidential information without authorization.
• Protect personal and sensitive information in accordance with applicable laws and company policies.
• Report any data breach or suspected loss of information immediately.

VI. Reporting Concerns

If you suspect a violation of this Code, raise it promptly. Reports can be made confidentially, and retaliation is not permitted.

Concerns regarding accounting, internal controls, auditing, compliance, or workplace matters can be directed to IR@frequencyhold.com or to the Board’s Audit and Compliance Committee.

Anonymous reporting is permitted, but including your name and contact information allows us to investigate thoroughly and follow up if needed.

Conclusion

We rely on each other’s judgment to maintain the integrity of Frequency Holdings. This Code is a living commitment: to do the right thing, to stay accountable, and to operate with clarity and trust in everything we build.