Policy On Internal Code Of Business Conduct And Ethics For All Directors And Employees And Policy On Trading In The Company’s Listed Securities

1.1. This policy outlines the principles that govern the behavior of directors, employees and the agents appointed by CF relating to Company’s expectation of highest standard of personal conduct and the business practices of the Company, in alignment with Company’s values, applicable laws, regulations and ethical standards.
1.2. The Board of Directors of the Company shall ensure that the Company conducts its business in accordance with the ethical standards, to earn and maintain the confidence and trust of all its stakeholders in integrity of the Company.
1.3. The Company shall set guidelines on trading in the Company’s listed securities and listed securities of Group entities to assist directors and employees to safely trade in shares within the parameters of the applicable law.

2.1. Uphold CF’s Corporate Values.
2.2. Abide by applicable laws, rules and regulations and policies and procedures of the Company.
2.3. Comply with the Financial Consumer Protection Regulation No 01 of 2023 and Customer Protection Policy of the Company.
2.4. Conduct of business within ethical standards and acceptable business practices.
2.5. Exercise professionalism and integrity when carrying out duties.
2.6. Refrain from any activity, business interest or relationship that could reasonably perceived as conflict of interest.
2.7. Non-disclosure of any confidential or sensitive information learnt through Company workplace without authorization.
2.8. Safeguard Company assets from any loss or damage.

Guideline on Trading in Shares extensively deals with how “Restricted Persons” should comply with their legal and regulatory obligations relating to securities trading, particularly while they are in possession of price sensitive unpublished information when dealing in shares or securities of the Company or those entities within the CF Group.

All “Restricted Persons” and their “Closely Connected Persons” are prohibited from trading in shares during the Non-Trading/Compulsory Blackout Periods specified in the “Guideline on Trading in Listed Shares of Group entities” which is in compliance with Section 8.6 Trading by Connected Parties of the CSE Listing Rules.

The employees including Directors shall acquaint themselves with guidelines and procedures of this policy as outlined in the “Code of Conduct for Employees”, as well as in the “Guideline on Trading in Listed Shares of Group entities” and familiarize themselves of their responsibilities.

All employees are required to affirm that they have read, understood, and agree to abide by the “Code of Conduct for Employees” by signing a declaration.
Employees are encouraged to seek clarification from the General Manager – Human Resources if they have questions or concerns regarding the understanding or interpretation of the “Code of Code for Employees” and Managing Director, Director-Legal, Chief Financial Officer or Company Secretary for avoidance of doubt on “Guideline on Trading in Listed Shares of Group entities”.

The violation of the “Code of Conduct for Employees” will result in disciplinary actions, depending on the severity and the frequency of the misconduct. The contravention of the “Guideline on Trading in Listed Shares of Group entities” will be investigated by the Company and would be considered misconduct, a violation of the employment contract and fiduciary duty thereby giving the company the right to take disciplinary action against the employee. Such violations would also trigger legal action/prosecutions from Securities and Exchange Commission. These consequences could be in the form of both criminal and civil liability.

This policy will be subject to review periodically as and when required by the CF Board.

The Contact Person for any inquiry with regard to “Policy on Internal Code of Business Conduct and Ethics for all Directors and employees, and policy on trading in the Company’s listed securities”;

Ms. A.R.L Gurusinghe
Company Secretary
No. 270, Vauxhall Street, Colombo 02
Telephone: 001- 2315065