1.Our Responsibilities

1.1. All MAGIC UMBRELLA LIMITED (hereinafter “Company” or “MAGIC UMBRELLA”) directors, officers and employees (“Company Personnel”), we live up to our responsibilities under our Code when we:

• Know and follow our Code, policies and the laws that apply to our job, and contribute to the culture of ethics and compliance.
• Ask questions when we are unsure of the right decisions or actions to take, and contact the relevant department and professionals within MAGIC UMBRELLA for assistance.
• Speak up when we observe or suspect misconduct.

1.2. Company Managers have additional responsibilities to:

• Act as a role model and lead the culture of ethics and compliance within their teams.
• Encourage employees to speak up without fear of retaliation.
• Listen to employees, take their concerns seriously and appropriately handle any issues raised.

1.3. All Company personnel must comply with our Code. Violation of the Code may result in disciplinary action, up to and including dismissal.

1.4. In addition, we expect suppliers, contractors, business partners and other third parties to meet the same standards we expect of ourselves.

2. Earn Trust

2.1. We earn trust for our brand through ethical and responsible conduct.

2.2. The Company’s brand is one of our most valuable assets.

2.3. We protect our brand when we conduct business in an honest, ethical and responsible manner.

2.4. Each of us must understand and follow the laws and policies that apply to our jobs.

3. Make Sound Business Decisions

3.1. In our daily work and operations, we make decisions that could impact our stakeholders and business.

3.2. Each of us must make these decisions on an informed basis and in the best interest of the Company.

3.3. Before making business decisions, we make sure all the following criteria are met:

• It will not violate any applicable law, this Code or any other policy.
• We have the authority to make the decision.
• It serves the best interests of the Company and does not involve personal volve personal interests or self-dealing.
• We have made a good faith, reasonable effort to become familiar with the relevant and available facts.

3.4. The Company is committed to structuring our business organisations in a manner to ensure appropriate checks and balances to help ensure sound decision making.

4. Speak Up

4.1. Speaking up is important for us to build an ethical work environment. If we think that someone has engaged in misconduct, we have a duty to promptly report our concerns. We participate in an investigation when asked.

4.2. How to Report Concerns

The Company has many ways for employees to raise questions or concerns about possible violations of Company policies or the law.

You can always report concerns to:

• Your line manager;
• Your HR department; or
• Your Legal Compliance Department.

Whichever resource you choose, reports are anonymous and the Company treats all information you share confidentially.

The Company only shares this information to the extent necessary to properly investigate, provide remediation, or as required by law. provide remediation, or as required by law.

4.3. No Retaliation

You will be treated fairly and respectfully if you make a report or participate in an investigation. The Company does not allow any form of retaliation against anyone for making a good faith report or for participating in an investigation. Proven retaliation is itself a violation of this Code. Those who engage in retaliation will be subject to disciplinary action, up to and including dismissal.

4.4. Examples of Retaliation

• Abuse
• Refusal to promote
• Exclusion
• Termination
• Reassignment
• Bullying
• Demotion
• Bad Review without grounds
• A pay cut

Empower & Respect People

5. Respect Human Rights

MAGIC UMBRELLA believes that all human beings should be treated with dignity and respect.

5.1. In MAGIC UMBRELLA we respect the internationally recognised human rights of all people throughout our value chain.

5.2. We strive to avoid any adverse human rights impacts from our business operations, products, services and/or business relationships, and to act diligently to help remediate any impacts that may occur.

6. Embrace Diversity of People & Foster Respect

MAGIC UMBRELLA is committed to a workplace culture based on diversity, respect and equity.

6.1. People are the driving force behind our Company’s creativity and success. People thrive in an environment where they feel valued, respected and included. That is why MAGIC UMBRELLA embraces diversity, equity and inclusion.

6.2. We aim to create an environment free from harassment or discrimination of any kind. Our Company’s employment decisions are based on legitimate business reasons including performance and merit.

7. Engage in Sound Labour & Employment Practices

MAGIC UMBRELLA respects workers’ rights to form and join trade unions of their own choosing or refrain from any of these activities.

7.1. MAGIC UMBRELLA respects workers’ rights to form and join trade unions of their own choosing or refrain from any of these activities.

7.2. MAGIC UMBRELLA will not use any form of involuntary labour where people are forced to work against their will.

7.3. This includes forced labour to work off a debt, prison labour, or human trafficking. MAGIC UMBRELLA will not use child labour.

8. Maintain a Healthy & Safe Work Environment

MAGIC UMBRELLA maintains a healthy, safe, and productive work environment.

8.1. MAGIC UMBRELLA prioritises the health, safety and well-being of our employees and business partners.

8.2. That is why we adhere to applicable health and safety laws and policies.

Collaborate Responsibly

9. Be Diverse & Competitive

MAGIC UMBRELLA embraces diversity as the foundation of our competitive advantage.

9.1. Diversity is in our Company’s DNA. Our businesses, people, and stakeholders are diverse.

9.2. This gives us strength and leads to our competitive advantage.

9.3. Working in this diverse world, we are mindful that conduct considered socially and professionally acceptable in one culture or region may not be acceptable in another. We keep this in mind when performing our duties.

10. Collaborate with Business Partners

MAGIC UMBRELLA engages third parties who share our commitment to ethics and compliance.

10.1. Our Company works with third parties to help us achieve our business goals. We must know who they are.

10.2. Knowing them helps us comply with applicable laws and reduces the risk of misconduct such as bribery, fraud or money laundering.

11. Source Responsibly

MAGIC UMBRELLA sources fairly and responsibly from trusted suppliers and contractors.

11.1. Suppliers and contractors are critical to our continued success. We build mutual trust and collaborate with our suppliers and contractors.

11.2. We expect them to know and follow our Company’s ethical values, applicable policies and legal requirements.

11.3. Our Company is committed to fair procurement based on objective conditions, such as competitive price, quality, technology and delivery.

12. Compete Fairly

MAGIC UMBRELLA competes vigorously, fairly and complies with all applicable antitrust and competition laws.

12.1. Antitrust and competition laws support market competition, which allows companies providing superior products, services and entertainment under better terms to be successful.

12.2. Competition laws prohibit agreements or practices that impede or destroy fair competition.

12.3. We must obtain advice from our legal department prior to exchanging information with competitors. We must know and comply with applicable competition laws wherever we do business.

13. Market Honestly

MAGIC UMBRELLA markets and advertises its products, services and entertainment honestly.

13.1. Our customers rely on us to be honest when we communicate about our products, services and entertainment. This enables them to make informed decisions.

13.2. We do not engage in false or misleading advertising and marketing.

14. Respect Privacy

MAGIC UMBRELLA respects the privacy of individuals and safeguards personal information.

14.1. Our people and stakeholders trust us to protect any personal information we collect while doing business.

14.2. To earn that trust, our Company has established policies to safeguard and ensure ethical handling of personal information.

14.3. We must follow these policies when we collect, maintain, use, disclose or dispose of personal information.

15. Maintain Information Security

MAGIC UMBRELLA protects its information assets and information systems.

15.1. Our Company recognises the importance of information security both in achieving financial success and maintaining the trust of our stakeholders.

15.2. We must all protect our information and systems by following our Company’s information security policies and procedures.

16. No Corruption

MAGIC UMBRELLA prohibits corruption in any form, in both the government and commercial sectors.

16.1. Corruption has a negative effect on the communities and economies where we do business. We never give gifts, entertainment or other amenities to obtain an improper business advantage.

16.2. We comply with all applicable anti-corruption laws. We take care when dealing with government officials.

16.3. We do not offer, promise, or give anything of value to government officials, directly or indirectly, to seek favourable arrangements or actions by such officials.

16.4. Points to be noted:

• It is strictly prohibited to bribe government officials.
• All payments to or on behalf of government officials, must be recorded accurately.
• We must seek prior approvals regarding any payments to government officials in accordance with internal policies.
• Government officials include those who work for a local, state/provincial or national government, or a public international organisation, an entity owned, controlled and/or funded by the government such as school, hospital and public broadcast companies, and those who are members of a royal family. If you have any concerns, please contact your legal or ethics and compliance department.

17. Follow Tax Laws

MAGIC UMBRELLA follows applicable tax laws and regulations wherever we conduct business as well as the common rules and guidance regarding international taxation.

17.1. As a responsible corporate citizen conducting business around the world, our Company understands its obligation to pay taxes, where applicable.

17.2. While sound fiscal management requires managing our tax burdens, we only do so through legal means. We comply with all such applicable laws and regulations.

18. Communicate Responsibly

We communicate with the media and others by providing clear and accurate information following prior approval.

18.1. What we say about MAGIC UMBRELLA can impact our reputation. To provide clear and accurate information to the public, only designated departments, such as the Corporate Communications, communicate with the media, securities analysts and others.

18.2. When communicating with the press on behalf of MAGIC UMBRELLA, all Company personnel will obtain the Company’s prior approval through appropriate means, such as by consulting Corporate Communications department.

18.3. When privately using social media, we must adhere to our Company’s policies, so that we do not give the appearance that we are speaking on behalf of MAGIC UMBRELLA.

Last modified: January 2025