CODE OF CONDUCT

INTRODUCTION
Ethics can be defined as a collection of moral principles or guidelines that direct behaviour, helping us differentiate between what is considered “right” and “wrong.” These principles are not strictly linked to legal obligations; instead, they resonate with an individual’s intrinsic sense of justice and what is perceived as “right” in various contexts. Upholding these principles demands strong character, especially when faced with pressure to choose otherwise. The companies within the FuneralCar Group (“FuneralCar”) are committed to maintaining the highest moral, legal, and ethical standards, striving for integrity in all their dealings. This Code of Ethics (“our Code”) has been formally adopted by the Company’s Board of Directors and is communicated to all stakeholders to ensure their dedication. The Board places great emphasis on our Code and will enforce a “zero tolerance” policy towards actions that contradict it. Employees who fail to adhere to the Code will encounter appropriate disciplinary or legal repercussions.

SCOPE & OBJECTIVE
All full-time and part-time employees, contractors, consultants, and representatives acting on behalf of the Company (“Applicable Persons”) must follow the principles outlined in our Code. Our Code embodies a clear, conscious, and personal commitment to doing what is right, holding all employees accountable for the performance and reputation of FuneralCar.

POLICY DETAILS
FuneralCar places a high value on ethical conduct and is dedicated to achieving the highest ethical standards. Although “doing the right thing” may not always be straightforward, this code serves as a guiding reference for our stakeholders, ensuring their actions align with socially accepted principles such as honesty, integrity, accountability, fairness, non-discrimination, and human dignity. At FuneralCar:

This Code also empowers employees to make informed choices, act responsibly, and challenge unethical behaviour.

ETHICS PRINCIPLES
Leadership through Diversity
Acknowledging the diversity within teams including demographic variations and differing thinking and working styles—enhances value through the inclusion of various perspectives. We are committed to creating an environment of mutual trust and respect, free from discrimination based on gender, race, nationality, ethnicity, age, religion, marital status, sexual orientation, or disability, while respecting human rights and ensuring equal opportunities. This environment also prohibits all forms of sexual harassment. Maintaining trust requires the confidentiality of sensitive information related to Applicable Persons. Discriminatory practices that violate this principle will not be tolerated.

Operate to the Highest Standards of Service and Productivity
FuneralCar operates in a high-performance environment that values exceptional service and productivity, executed with urgency. To succeed, it is essential that Applicable Persons take responsibility for their actions and collaborate to find optimal solutions for the Group and its stakeholders. Applicable Persons are expected to conduct themselves professionally and courteously while consistently striving to improve our products and create sustainable value for all stakeholders.

Recruitment and Selection
The recruitment and selection processes must remain free from manipulation and bias while addressing the company’s transformation needs. Applicable Persons involved in recruiting friends, family, or close associates must disclose this before inviting them to participate in the recruitment process or as soon as reasonably possible. Prospective employees must also disclose any personal connections with FuneralCar employees. Integrity is fundamental in the recruitment and advancement of staff.

Supply Products of the Highest Quality
FuneralCar is committed to delivering safe, high-quality products that consumers can trust. All manufacturing facilities adhere to best practices and comply with all applicable laws.

Contribute Meaningfully to Our Communities
By responsibly managing a successful business that provides quality products and job opportunities in a positive work environment, FuneralCar contributes significantly to societal and community development.

Minimise Our Environmental Impact
FuneralCar recognises that environmental protection is crucial for long-term business sustainability. The Group is committed to reducing negative environmental impacts and seeking opportunities for improvement.

Establish Ethical Long-term Relationships
FuneralCar encourages customers, suppliers, and business partners to uphold the ethical principles we value. The company will not engage with individuals or entities involved in activities such as terrorism, money laundering, drug trafficking, child labour, or other illegal actions. Building ethical relationships is essential, and employees should remain independent, both in fact and appearance, from any entity with contractual ties to the Group that could suggest undue business advantage or influence decisions. All customers, suppliers, and business partners should be treated with dignity and respect, with business conducted fairly, legally, and consistently, honouring commitments made.

Gifts and Hospitality
We should never give or accept cash or vouchers as gifts. Non-cash gifts should only be exchanged if they do not create the impression of securing an improper business advantage or influencing decisions, including gifts provided indirectly to family members. Generally acceptable instances include:

• Business entertainment, such as occasional lunches or dinners.
• Personal invitations to local events or theatres on rare occasions.
• Advertising materials of limited commercial value.

The CEO will determine thresholds for gifts requiring approval from the appropriate Executive Committee member. The Company Secretary will record all gifts exceeding the CEO’s threshold. The FuneralCar Gifts, Entertainment, and Hospitality Policy must be followed when dealing with gifts.

Contributions to Political Parties
FuneralCar respects individuals’ rights to freedom of expression and association, allowing them to contribute to and be members of political organisations in their personal capacities. The company is not affiliated with any political entity and does not contribute to candidates or campaigns. Applicable Persons must ensure their personal affiliations are not misinterpreted as those of the Company.

Compliance with Laws and Regulations
FuneralCar mandates compliance with both the letter and spirit of applicable laws. Non-compliance could result in significant commercial and reputational damage. All Group policies are designed to ensure legal adherence.

Zero Tolerance for Bribery, Corruption, or Dishonesty
FuneralCar does not condone any form of bribery, corruption, or dishonest behavior. Employees must not offer or accept any personal or improper benefits to gain business advantages. Any incidents of theft, bribery, or corruption should be reported immediately. The FuneralCar Anti-Bribery and Anti-Corruption Policy must be read alongside this Code.

Insider Trading
Applicable Persons are expected to act honestly and in the Group’s best interests, avoiding personal gain through the misuse of confidential information. Activities that conflict with the Group’s best interests, such as inappropriate trading in FuneralCar shares, are strictly prohibited.

Maintain a Healthy and Safe Working Environment
FuneralCar is dedicated to ensuring a safe and secure workplace. The use of illegal drugs and dangerous weapons is strictly forbidden, and alcohol consumption is only permitted for approved business entertainment. Any threats of violence or intimidation will not be tolerated. Compliance with relevant health, safety, and environmental legislation is expected from all Group companies and employees.

Fair Competition
FuneralCar is committed to conducting business fairly, ethically, and in accordance with applicable competition laws.

Communicate Transparently
While recognising legal and competitive constraints, all communications to stakeholders should remain truthful, open, and transparent. FuneralCar’s products must be marketed responsibly and accurately.

Enforcement of the Code of Ethics
Any violation of this Code by an employee will result in disciplinary action.

Guidelines for Making Ethical Decisions
Utilise FuneralCar’s values and ethical principles:

• Are you acting with integrity regarding your proposed action?
• Does your proposed action align with FuneralCar’s values?
• Does it feel “right”?
• Would your line manager support this action?
• Would you be comfortable if your decision was made public?

Trust your judgment.

Follow the rules:

• Does your action comply with the law?
• Does it align with FuneralCar’s policies?
• Have you reviewed best practices?
• Consider the impact on stakeholders:
  • Will it positively affect shareholders, customers, suppliers, or employees?
  • Is it beneficial only to an individual or group?

Act responsibly:

• Do you have all the necessary information for your decision?
• Have you verified the facts?
• Who is accountable?
• Have you involved the necessary parties?
• Have potential issues been addressed?
• Is communication open and honest?

REPORTING BREACHES OF THE CODE OF ETHICS
Applicable Persons must report any suspected or potential breaches of this Code the Group Compliance Officer, the Chief Executive Officer, or anonymously through the FuneralCar Ethics Line at +27 63 407 4362 or via email at ethicsline@funeralcar.co.za.

ENQUIRIES
For inquiries regarding this policy, please contact the Group Compliance Manager.

ROLES & RESPONSIBILITIES

• All Applicable Persons must be aware of, adhere to, and fully comply with this Policy.
• The FuneralCar legal department is responsible for maintaining the Policy and providing guidance on its implementation.
• Business unit managers are responsible for enacting the Policy within their areas and ensuring staff compliance.
• Employees who fail to comply with the provisions or amendments may face disciplinary or legal action.
• FuneralCar’s policies comply with legal, regulatory, and statutory requirements.
• This policy may be amended at FuneralCar’s sole discretion.

Effective Date
This Ethics Policy was last updated on 23 March 2026.