Code of Conduct

1.1 Purpose. This Code sets the minimum standard of conduct required in all Erianux business activity. It exists so that the obligations the Company accepts are written down, owned by a named role, capable of being audited, and enforceable against the people who agree to them — rather than assumed.

1.2 Issuing entity. ERIANUX, LLC (the “Company”) is a limited liability company organised under the Wyoming Limited Liability Company Act, W.S. 17-29-101 et seq. The Company has no subsidiaries.

1.3 Persons covered. This Code binds (a) the Managing Member; (b) any employee, officer, intern or temporary worker; (c) any contractor, consultant or agency engaged to perform services for the Company; and (d) every affiliate, referrer or promotional partner acting under the Affiliate Program Terms. Categories (c) and (d) are together referred to as Associated Persons, a term used deliberately to match the language of the UK Bribery Act 2010 s.8 and the Economic Crime and Corporate Transparency Act 2023 s.199.

1.4 Activities covered. All Company activity, in every jurisdiction in which the Company sells or promotes, including: the licensing of Erianux charting, order-flow and drawing-tool software for the NinjaTrader 8 platform; subscription services; the Erianux Store; the Affiliate Program; supplier engagement; hiring; and all customer communication and marketing.

1.5 Status. This Code is a binding condition of engagement for every person within clause 1.3. Where a contract, statute or regulation imposes a stricter obligation than this Code, the stricter obligation prevails. Where this Code is stricter than local commercial custom, this Code prevails.

1.6 The residual test. This Code does not attempt to anticipate every situation. Where no clause squarely applies, the governing test is whether the decision and the reasoning behind it would withstand disclosure to a customer, a payment processor, a regulator or a court. If it would not, the decision is non-compliant irrespective of whether a specific rule addresses it.

In this Code: “Anything of Value” means any payment, gift, entertainment, discount, licence, service, employment offer, charitable or political contribution, or other benefit, whether or not it has a cash value; “Company Data” means any data the Company holds about a customer, affiliate, applicant or supplier, including account, order, payout and support records; “Conflict” means any interest, relationship or activity that could reasonably be seen to compromise the objectivity of a decision taken for the Company; “Performance Representation” means any statement, figure, chart, screenshot or implication concerning the trading results obtainable with an Erianux product; and “Report” means a concern raised under clause 13.

3.1 Ownership. The Managing Member owns this Code, approves it, and is accountable for its operation. The Company does not maintain a separate compliance department; concentrating the role in a single named office is stated openly rather than obscured behind a committee that does not exist.

3.2 Single intake channel. All conduct, compliance, legal and ethics matters are routed to legal@erianux.com. That mailbox is monitored by the Managing Member and is the channel of record for Reports, Conflict disclosures, gift and hospitality declarations, and supplier concerns. Product and account matters go to support@erianux.com.

3.3 Acknowledgement. Every person within clause 1.3 is required to read this Code at the point of engagement and to confirm acknowledgement in writing. Affiliates acknowledge it by accepting the Affiliate Program Terms, which incorporate this Code by reference.

3.4 Escalation of doubt. Any person who is uncertain whether a proposed course of action complies with this Code must ask before acting. A question asked in advance is never treated as an admission; proceeding without asking is treated as a decision.

4.1 Truthfulness. No person may misrepresent what an Erianux product does, what data it consumes, what platform or instruments it supports, or what results it can produce. A feature that does not function does not ship. A claim that cannot be substantiated from real market data is not published.

4.2 Substantiation. Every objective product claim must be capable of substantiation at the time it is made, consistent with Section 5 of the Federal Trade Commission Act (15 U.S.C. §45) prohibiting unfair or deceptive acts or practices. The burden of substantiation sits with the person publishing the claim.

4.3 Performance Representations. The Company does not guarantee, promise or imply trading profits. Where any simulated, backtested or hypothetical result is shown, it must be identified as such and accompanied by the hypothetical-performance disclaimer prescribed by CFTC Regulation 4.41(b) (17 C.F.R. §4.41) — hypothetical results have inherent limitations, do not represent actual trading, are designed with the benefit of hindsight, and no representation is made that any account will or is likely to achieve similar profits or losses. Under-emphasising that disclaimer relative to the result shown is itself a breach of this clause.

4.4 No investment advice. Erianux sells analytical software. No person acting for the Company may provide personalised trading or investment advice, manage a customer account, solicit funds for trading, or hold themselves out as a registered adviser, introducing broker, commodity trading advisor or pool operator.

4.5 Endorsements and testimonials. Customer testimonials must be genuine, unedited as to substance, and reflect typical rather than exceptional experience. Any material connection between the Company and an endorser — commission, free licence, discount or other consideration — must be disclosed clearly and conspicuously in the same medium as the endorsement, consistent with the FTC Endorsement Guides, 16 C.F.R. Part 255 as revised in 2023. The Company is expected to require disclosure contractually and to act when an affiliate omits it.

4.6 Reviews. The Company does not write, buy, incentivise, suppress or misattribute reviews of its own products, and does not procure the posting of negative reviews of a competitor.

5.1 Non-discrimination. Every person dealing with the Company — customer, applicant, supplier, affiliate or colleague — is treated with respect and without discrimination on the basis of race, colour, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, genetic information, veteran status, or any other characteristic protected by applicable law, including Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, and their equivalents in other jurisdictions in which the Company operates.

5.2 Harassment. Harassment, bullying, sexual harassment, threats and intimidation are prohibited, in any channel, including email, support tickets, social platforms and the Company’s Discord community.

5.3 Labour standards. The Company does not use, and will not knowingly benefit from, forced labour, bonded labour, involuntary prison labour or child labour. This obligation extends through the supply chain and is set out in full in the Modern Slavery Statement.

5.4 Non-retaliation. Retaliation against any person for making a Report in good faith, or for participating in an investigation, is a serious breach of this Code and is prohibited whether or not the underlying concern is substantiated.

6.1 Disclosure obligation. A Conflict must be disclosed in writing to legal@erianux.com before the relevant decision is taken. Disclosure, not abstinence, is the baseline requirement; the Company then decides whether the person concerned should withdraw from the decision.

6.2 Examples requiring disclosure. A financial interest in, or paid relationship with, a competitor, supplier, broker, prop firm or platform vendor; a family or close personal relationship with a counterparty; a side business selling trading tools or education; acceptance of Anything of Value from a party seeking a commercial decision; and the operation of an affiliate account by a person who also influences Company marketing decisions.

6.3 Register. Disclosures are recorded in a conflicts register maintained with the Company’s compliance records under clause 15.1.

7.1 Customer confidentiality. Company Data is used only to deliver and support the product the customer purchased. It is not sold, rented, traded, or discussed outside that purpose. Support conversations are not published, quoted or used in marketing without the customer’s consent.

7.2 Data protection. Personal data is processed only as described in the Privacy Policy, on a lawful basis, for the minimum period necessary. Because the Company sells into the United Kingdom and the European Union, requests made under the UK GDPR and Regulation (EU) 2016/679 — access, rectification, erasure, portability and objection — are honoured regardless of where the requester is located.

7.3 Incidents. Any suspected loss, unauthorised disclosure or compromise of Company Data must be reported to legal@erianux.com immediately and without exception. Attempting to contain an incident privately before reporting it is a breach of this Code.

8.1 Books and records. Orders, refunds, chargebacks, affiliate commissions, supplier invoices and tax records must record what actually occurred, in full, in the correct period. No off-book account, unrecorded fund, or mischaracterised entry may be created for any purpose.

8.2 Bribery and corruption. The Company prohibits the offering, promising, giving, requesting, agreeing to receive or accepting of Anything of Value to induce or reward the improper performance of a function, and prohibits facilitation payments. The full obligation, and the control framework supporting it, is set out in the Anti-Bribery & Corruption Policy (ERX-POL-002).

8.3 Money laundering. No person may accept, process or facilitate a payment they know or suspect represents the proceeds of crime, or accept payment structured to disguise its source. See the Anti-Money Laundering Policy (ERX-POL-003).

8.4 Sanctions and export control. The Company does not knowingly license, sell or ship to any person, entity or jurisdiction subject to sanctions administered by the U.S. Treasury’s Office of Foreign Assets Control, nor to any party on the Specially Designated Nationals and Blocked Persons List or an entity owned 50 per cent or more by such a party. Software is not supplied in breach of the Export Administration Regulations, 15 C.F.R. Parts 730–774. Sanctions obligations apply strictly and are not subject to a commercial-judgement exception.

9.1 Competing on merit. The Company competes on product quality, documentation and support. Disparagement of a competitor with unverified claims, misuse of a competitor’s trade marks, and the purchase of misleading look-alike domains or ad placements are prohibited.

9.2 No misappropriation. No person may decompile, copy or incorporate a third party’s code, indicator logic, artwork or documentation into an Erianux product, or use a competitor’s licensed software to derive its proprietary logic. Material obtained for legitimate comparison must be kept out of the development path entirely.

9.3 Third-party terms. Platform and vendor agreements — including those of NinjaTrader, ATAS, and the Company’s hosting, repository and payment providers — are complied with as written. Where a platform restricts redistribution, automation or data use, that restriction is treated as binding on the Company.

9.4 Company IP. The ERIANUX name and mark, the Company’s source code, licence keys and written materials are protected assets. Unlicensed distribution, key sharing and circumvention of licensing controls are pursued.

• 10.1 Use of assets. Code repositories, credentials, licensed tooling and Company accounts are for Company business. They are not used for personal ventures or side projects.
• 10.2 Credential hygiene. Credentials are not shared or reused. Multi-factor authentication is enabled wherever a provider supports it. Code-signing and licence-signing keys are held under the narrowest practicable access.
• 10.3 Least privilege. Access to customer records and payment dashboards is granted only where the role requires it and is removed when the engagement ends.
• 10.4 Accountable use of AI. Where generative tools assist in development, documentation or support, a named human remains accountable for the output. An AI-drafted product claim is subject to clause 4 in full; AI-assisted code must be understood by the person shipping it. Customer personal data and proprietary source code are not submitted to a third-party model that may retain or train on them.

11.1 Extension of the Code. Affiliates act for the Company in the eyes of a customer and of a regulator. This Code therefore applies to affiliate promotion in full, and the Affiliate Program Terms, §13 (Prohibited conduct), sets out the binding affiliate-specific detail — mandatory disclosure of paid promotion, no earnings claims, no unlicensed advice — and governs where the two overlap.

11.2 Prohibited promotional conduct. Fabricated or unattributed results; guaranteed-profit or income claims; undisclosed commission; cookie stuffing, typosquatting or trademark-bidding on Company or competitor marks; unsolicited bulk email; and promotion to persons in a sanctioned jurisdiction.

11.3 Consequence. Breach results in withholding of commission, removal from the programme, and — where a third party has been misled — correction of the published claim.

Four commitments are set out in full in their own documents rather than summarised here, and are incorporated into this Code by reference: the Modern Slavery Statement (forced labour and human rights in the supply chain), the Sustainable Procurement Policy (how suppliers are selected and held to standard), the Climate Statement (environmental position and the limits of what the Company claims), and the Accessibility Statement (access to the Company’s digital estate).

13.1 Channel. Reports go to legal@erianux.com. Anyone may report — customer, affiliate, supplier, applicant or member of the public. A Report may be made anonymously, with the caveat that anonymity may limit the Company’s ability to investigate.

13.2 Handling. The Company will acknowledge a Report that carries a return address, assess it, investigate proportionately to its seriousness, record the outcome, and take corrective action where the concern is substantiated. Where a Report concerns the Managing Member, the Company will engage external counsel or an external accountant to review it, because self-investigation is not a control.

13.3 Confidentiality. The identity of a reporter is disclosed only as necessary to investigate or as required by law.

13.4 Protected disclosure. Nothing in this Code, and nothing in any Company agreement, restricts any person from reporting a suspected violation of law to a government agency or regulator, or from responding to lawful process. No waiver, confidentiality clause or settlement is used to prevent such a report.

Breach of this Code may result, according to severity and depending on the relationship: in disciplinary action up to and including termination of employment; termination of a contract for services; suspension or termination of an affiliate account and forfeiture of unpaid commission; termination of a customer licence; termination of a supplier relationship; recovery of losses; referral to law enforcement or a regulator; and public correction of a misleading claim. Breaches in the categories of bribery, sanctions, data protection and Performance Representations are treated as presumptively serious.

15.1 Records kept. The Company retains acknowledgements of this Code, Conflict disclosures, gift and hospitality declarations, Reports and their outcomes, supplier due-diligence records, and the approval record for each version of this Code.

15.2 Retention. Compliance records are retained for not less than five years from the end of the relationship or the closure of the matter, unless a longer period is required by law, and are then securely destroyed.

15.3 Review. This Code is reviewed at least annually and additionally on any material change to the business — a first employee, a new product line, a new jurisdiction, a new payment or fulfilment partner, or a regulatory development affecting any clause. Each review is recorded in the version history below whether or not it results in a change.

Clauses 16–31

Part A binds every person who acts for the Company, including affiliates and suppliers. Part B governs the employment relationship specifically: it applies to any employee, officer, intern or temporary worker, and to contractors to the extent a clause is expressed to reach them. Part B does not create a contract of employment, does not alter the at-will character of employment described at clause 16.4, and does not confer any right to continued engagement.

16.1 Current position. The Company has no employees at the date of this version. Part B is written in advance of the first hire so that the standard is set before it is needed, and so that a candidate can read the terms of conduct before accepting a role rather than after.

16.2 Governing law of the relationship. The Company is organised in Wyoming. An employment relationship will be governed by the law of the state in which the employee performs work, together with applicable federal law. Where a clause of Part B conflicts with a mandatory statutory entitlement in that state, the statute prevails and the remainder of Part B continues in force.

16.3 Classification. Each engagement is classified honestly as employment or independent contracting on the substance of the arrangement — control, integration, economic dependence and the right to work for others — and not on the label that is administratively convenient. The Company does not engage a person as a contractor in order to avoid an obligation properly owed to an employee.

16.4 At-will employment. Employment in the United States is at will unless a written agreement signed by the Managing Member provides otherwise. Either party may end the relationship at any time, with or without cause or notice. Nothing in this Code, in any handbook, in any policy statement or in any performance discussion alters that, and no manager has authority to vary it orally.

16.5 Eligibility to work. Every employee must establish identity and authorisation to work as required by the Immigration Reform and Control Act, through completion of Form I-9 within the statutory period. The Company does not discriminate on the basis of citizenship status or national origin in that process, and does not request documents beyond those the form permits.

17.1 Equal opportunity. All employment decisions — recruitment, selection, compensation, assignment, development, promotion and termination — are made on merit and on the requirements of the role. The prohibited grounds are those set out at clause 5.1, and the commitment applies at every stage of the employment lifecycle, not only at hiring.

17.2 Reasonable accommodation — disability. The Company will provide reasonable accommodation to a qualified individual with a disability, consistent with the Americans with Disabilities Act as amended, unless doing so would impose an undue hardship. A request initiates an interactive process: the Company will discuss the limitation and the functions of the role, request only the medical information necessary to evaluate the request, consider alternatives, and respond in writing. Medical information obtained is held separately from the personnel file and disclosed only as the statute permits.

17.3 Reasonable accommodation — religion and pregnancy. The same interactive process applies to a request for religious accommodation under Title VII and to a request arising from pregnancy, childbirth or a related medical condition, including accommodation required under the Pregnant Workers Fairness Act and lactation-accommodation requirements under the PUMP Act.

17.4 Harassment defined. Prohibited harassment is unwelcome conduct based on a protected characteristic that is severe or pervasive enough to create an intimidating, hostile or offensive working environment, or that is made a condition of employment or of an employment decision. It includes slurs, derogatory remarks, mockery, display of offensive material, unwelcome physical contact, unwelcome sexual advances, and requests for sexual favours whether or not accompanied by a threat or a promise.

17.5 Channels and third parties. The prohibition applies in every channel the Company works through — email, ticketing, video calls, the Discord community, and any chat or repository — and in any work-related setting off Company premises. It applies equally to conduct by a customer, affiliate or supplier directed at a Company worker; the Company will act on such conduct, including by ending the relationship.

17.6 Bullying and abusive conduct. Conduct that is abusive, humiliating or persistently hostile is prohibited whether or not it is connected to a protected characteristic. The absence of a protected ground is not a defence under this Code.

17.7 Duty to report. Any person who witnesses conduct prohibited by this clause is expected to report it, and any person with supervisory responsibility who becomes aware of it must escalate it to legal@erianux.com immediately. Awareness without escalation is itself a breach.

18.1 How to complain. A complaint may be made orally or in writing to legal@erianux.com. No particular form is required, and a complainant is not required to raise the matter first with the person complained of. Where the complaint concerns the Managing Member, it will be referred to external counsel under clause 13.2.

18.2 Interim measures. Where necessary to protect a complainant or the integrity of an investigation, the Company may separate the people involved, suspend access, or place a person on paid leave pending outcome. An interim measure is not a finding and is not a sanction.

18.3 Investigation. The Company will acknowledge the complaint promptly; define its scope; interview the complainant, the respondent and any witness; collect relevant documents and records; keep a written record of the enquiry; reach a conclusion on the balance of probabilities; and communicate the outcome to the complainant and the respondent so far as confidentiality permits. Investigations are conducted without predetermination of outcome, and the respondent is told the substance of what is alleged and given an opportunity to answer it.

18.4 Outcome. Where a complaint is substantiated, the Company will take action proportionate to the conduct under clause 22, and will take steps to prevent recurrence. Where it is not substantiated, that is recorded without adverse consequence to a complainant who acted in good faith.

18.5 Non-retaliation. Retaliation against a complainant, a witness or an investigator is prohibited and is independently actionable under this Code. Retaliation includes dismissal, demotion, reduction of duties, exclusion from communication, withdrawal of opportunity, and informal hostility. A person who believes they have suffered retaliation should report it through the same channel; a retaliation complaint is investigated as a new matter, not as part of the original one.

18.6 Bad-faith complaints. A complaint that is knowingly false or made for an improper purpose is a breach of this Code. A complaint that is mistaken, or that cannot be proven, is not.

19.1 Remote by default. The Company is fully remote and maintains no office. A worker is responsible for a working environment that is safe, private enough to protect Company and customer data, and connected sufficiently to perform the role. The Company does not monitor a worker’s home, family or personal device beyond what security of Company systems requires, and does not require always-on camera or keystroke surveillance.

19.2 Hours and availability. Roles are defined by responsibility rather than by presence. Core overlap hours, if any, are agreed at engagement in writing. A worker is not expected to answer messages outside agreed working hours, and a manager may not treat out-of-hours responsiveness as a performance criterion.

19.3 Wage and hour compliance. Compensation complies with the Fair Labor Standards Act and applicable state law on minimum wage, overtime and meal and rest breaks. A non-exempt employee is paid overtime at the statutory rate for hours worked beyond the statutory threshold. Off-the-clock work is prohibited: a non-exempt employee must record all time worked and must not perform work without recording it, and a manager must not encourage or accept unrecorded work.

19.4 Timekeeping and expenses. Time and expense records must be accurate and submitted on time. Expenses are reimbursed where they are reasonable, necessary for the role, supported by a receipt and approved in advance where material. Inflating a claim, or submitting a personal cost as a business one, is treated as a financial-integrity breach under clause 8.1.

19.5 Pay transparency. Nothing in this Code or in any Company agreement prohibits an employee from discussing their own wages, hours or working conditions with colleagues or anyone else, consistent with s.7 of the National Labor Relations Act and applicable state pay-transparency law.

19.6 Deductions. The Company makes no deduction from wages other than those required or permitted by law and, where consent is required, authorised in writing.

20.1 Statutory leave. The Company honours the leave entitlements that apply to it, which may include family and medical leave under the Family and Medical Leave Act where the Company meets the employer-coverage test, military leave under USERRA, jury and witness service, voting leave, and state or local paid sick leave. Entitlement is determined by law rather than by discretion, and the Company will state in writing which entitlements apply at the point of engagement.

20.2 Notification. Absence should be notified as early as practicable to the person named in the engagement letter. The Company does not require a diagnosis, and asks only for the information needed to manage cover and to administer any entitlement.

20.3 Health and safety. The Company complies with the general duty clause of the Occupational Safety and Health Act, 29 U.S.C. §654(a)(1), and will address any work-related hazard reported to it, including ergonomic issues arising from remote work. A worker may report a safety concern to the Company or to OSHA without retaliation.

20.4 Substances. No person may perform work for the Company while impaired by alcohol or by a controlled substance. Lawfully prescribed medication is not a breach; if it affects capacity to work safely, the accommodation process at clause 17.2 applies. The Company does not conduct random testing.

21.1 Confidential information. Source code, unreleased product logic, licence and signing keys, customer and affiliate records, pricing models, supplier terms, roadmaps and financial information are confidential. The obligation applies during and after the engagement, and is not limited in time for trade secrets.

21.2 Permitted disclosure. Nothing in clause 21.1, in any confidentiality agreement, or in any separation agreement prevents a person from reporting a suspected violation of law to a government agency, from participating in an agency investigation, from discussing wages or working conditions, or from disclosing conduct they reasonably believe to be unlawful harassment or discrimination. Immunity for the confidential disclosure of a trade secret to an official or an attorney for the purpose of reporting a suspected violation of law, under the Defend Trade Secrets Act, 18 U.S.C. §1833(b), is expressly preserved.

21.3 Ownership of work. Work created within the scope of the engagement, and any invention, code, documentation, design or written material made using Company time, systems or confidential information, belongs to the Company, and the worker will execute the assignments and documents reasonably required to record that. Pre-existing personal work is excluded where it is identified in writing at the point of engagement.

21.4 Third-party rights. No worker may bring a former employer’s confidential information or code into the Company, or use it in Company work. Open-source components may be used only where the licence is compatible with the Company’s distribution model, and attribution and licence obligations are honoured.

21.5 Outside activity. Outside work, teaching, writing and open-source contribution are permitted, and are not the Company’s business, provided they do not compete with the Company, do not use Company time, systems or confidential information, and do not create a Conflict requiring disclosure under clause 6. Selling trading tools, indicators, signals or education to the same market is a Conflict and must be disclosed before it begins.

21.6 Personal trading. Workers may trade their own accounts. They may not represent themselves as trading on the Company’s behalf, publish results in a way that implies a Company endorsement, or use a customer’s data or a customer’s reported position for personal advantage.

22.1 Performance management. Expectations are set in writing at engagement and reviewed in an ordinary cadence. Where performance falls short, the worker is told specifically what is deficient, what the required standard is, and what support is available, before any consequence attaches.

22.2 Progressive discipline. Conduct matters are ordinarily addressed in escalating steps: informal discussion, documented verbal warning, written warning, final written warning, and termination. The Company is not obliged to follow every step and may move directly to termination for gross misconduct, consistent with the at-will position at clause 16.4.

22.3 Gross misconduct. Conduct that may warrant immediate termination includes dishonesty and falsification of records; theft or misappropriation; a bribery, sanctions or money-laundering breach; unauthorised disclosure of customer data or source code; publishing a Performance Representation that breaches clause 4.3; harassment or violence; working while impaired in a safety-relevant task; and deliberate circumvention of a security control.

22.4 Right to be heard. Before a disciplinary sanction is imposed, the worker is told the substance of the concern and given a fair opportunity to respond, and the response is recorded.

22.5 Grievance. A worker who is dissatisfied with a decision, a working condition or the conduct of another person may raise a grievance to legal@erianux.com. The Company will consider it, respond in writing, and — where the grievance concerns the person who took the original decision — arrange for it to be considered by someone else, including external counsel where no internal alternative exists.

23.1 Speaking for the Company. Only the Managing Member, or a person expressly authorised in writing, may make a public statement on behalf of the Company, respond to a press enquiry, or communicate with a regulator.

23.2 Personal social media. A worker’s personal accounts are their own. Where a worker’s connection to the Company is apparent and they discuss the Company’s products or market, they should make clear that they speak personally, must not disclose confidential information, and must not make a claim that would breach clause 4. Clause 19.5 preserves the right to discuss working conditions.

23.3 Customer and community channels. Support and community conduct is courteous and factual under pressure. A worker may not argue a customer into a purchase, imply a result the product cannot deliver, or answer a question about trading outcomes with anything other than the documented behaviour of the software.

23.4 Recording and monitoring. Company email, repositories and support systems are Company records and may be accessed for legitimate business, security or legal purposes. Calls are not recorded without notice to all participants.

24.1 Onboarding. Before access to customer data, payment dashboards or signing keys is granted, a worker acknowledges this Code in writing, receives the policies relevant to the role, and is briefed on the specific obligations attaching to that access. Access is provisioned to the least privilege the role requires.

24.2 Training. Any worker in a role touching marketing, supplier selection, payments or personal data is briefed on the corresponding policy — clause 4, the Sustainable Procurement Policy, the Anti-Money Laundering & Sanctions Policy, or the Privacy Policy — before assuming the responsibility, and the briefing is recorded under clause 15.1.

24.3 Departure. On the last working day, access is revoked, credentials are rotated, Company equipment and records are returned, and the worker confirms that no Company confidential information remains in a personal account or device. Final pay is issued within the period the applicable state law requires.

24.4 Continuing obligations. Confidentiality under clause 21.1, ownership under clause 21.3, and the permitted-disclosure protections under clause 21.2 survive the end of the engagement. The Company does not impose a post-employment non-compete on a worker where the applicable law prohibits or disfavours it, and will not use one to prevent a person earning a living in their field.

25.1 Contractors. Part A binds every contractor. From Part B, clauses 17, 18, 21, 23 and 24 apply to a contractor in respect of Company work; the employment-specific clauses do not. A contractor controls their own manner and means of working, carries their own insurance and tax obligations, and is not held out as an employee.

25.2 Interns. The Company will not operate an unpaid internship that displaces paid work or that fails the applicable primary-beneficiary test. An intern performing productive work is paid.

25.3 Community moderators. A volunteer moderator in the Company’s community acts under clauses 17 and 23, receives written guidance on what they may and may not say about products, and is not permitted to give trading advice or to make an earnings claim.

Personal data about a worker or an applicant is collected only where it is necessary for recruitment, employment administration, payroll, benefits, security or legal compliance; is accessible only to those who need it; is retained only for as long as the purpose or a statutory retention period requires; and is disclosed to a third party only where the purpose requires it or the law compels it. Medical and accommodation records are held separately under clause 17.2. A worker may ask what the Company holds about them and ask for a correction, and the Company will respond; where the worker is located in the United Kingdom or the European Union, the rights under the UK GDPR and Regulation (EU) 2016/679 apply in full.

27.1 Prohibited agreements. No person acting for the Company may agree, or appear to agree, with a competitor to fix or coordinate prices, discounts or promotional terms; to allocate customers, territories or product categories; to rig a bid; or to boycott a supplier, platform or reviewer. These prohibitions arise under the Sherman Act, 15 U.S.C. §§1–2, the Federal Trade Commission Act, and the equivalent competition law of the United Kingdom, the European Union and Canada. They are criminal in the United States and do not require a written agreement to be established — a conversation and a subsequent parallel course of conduct can suffice.

27.2 Contact with competitors. Competitor contact in this market is unavoidable: the same forums, the same platform ecosystems, the same conferences. Contact is permitted; the exchange of competitively sensitive information is not. Do not discuss future pricing, planned promotions, margin, unreleased roadmaps, or terms offered to a specific customer. If such a subject is raised, say clearly that it cannot be discussed, leave the conversation, and report it to legal@erianux.com the same day — the contemporaneous record of having objected and withdrawn is the protection.

27.3 Comparative claims. A published comparison against a named competitor must be accurate, current, like-for-like, and substantiated at the time of publication, consistent with clause 4.2. Benchmarks run on different data, timeframes or hardware are not a like-for-like comparison and may not be presented as one.

27.4 Resale and platform terms. Where the Company sells through a marketplace or a platform ecosystem, it complies with that platform's rules rather than working around them, and does not attempt to induce a platform to disadvantage a competitor.

28.1 Zero tolerance of violence and threats. Violence, threats of violence, intimidation, stalking and the brandishing of a weapon are prohibited in any Company context, including in writing and in online channels. A credible threat is treated as a matter for law enforcement first and for internal process second.

28.2 Threats from customers or third parties. A worker who receives a threat from a customer, affiliate or member of the community must not attempt to de-escalate it alone. Preserve the message, stop responding, and escalate to legal@erianux.com. The Company will suspend the account, report the conduct to the platform and, where warranted, to the police, and will not require the worker to continue dealing with that person.

28.3 Personal safety of remote workers. Because the Company is distributed, no worker is required to publish a home address, a personal telephone number or a personal social account in connection with Company work. Public-facing contact runs through Company channels only.

28.4 Emergency and continuity. In an emergency affecting a worker, the expectation is that they secure their own safety first and notify the Company when able. Where an incident affects Company systems, customer licensing or payment processing, the Managing Member directs the response, customers are told what is known and what is not, and no estimate of restoration is published unless it is genuinely believed.

29.1 Authorisation and cost. Travel is approved in advance, booked at a reasonable standard, and reimbursed under clause 19.4. Loyalty benefits accruing on Company travel may be retained personally; the choice of carrier or supplier may not be influenced by them.

29.2 Conduct at events. At a trade show, webinar, broker event or community meet-up, a worker is on duty and represents the Company. Clauses 4, 17, 23 and 27 apply in full, including the prohibition on earnings claims and on competitively sensitive discussion. Hospitality accepted at an event is subject to the thresholds in the Anti-Bribery & Corruption Policy.

29.3 Demonstrations. A live or recorded demonstration must show the product doing what it actually does, on data that is identified as live or historical. A simulated fill may not be presented as an executed trade, and a hypothetical result shown at an event carries the same disclaimer obligation as one published online.

29.4 International travel. Company devices taken across a border are subject to the data-minimisation and encryption expectations at clause 10, and no customer data is carried on a device that does not need it.

30.1 Internal route first, but never as a condition. The Company asks to be told first, because it can usually fix a problem faster than an external body can. It does not require it. No person is obliged to exhaust an internal process before contacting a regulator, and delaying an external report is never a disciplinary matter.

30.2 Protections relied on. Protections that may apply to a person reporting misconduct connected to the Company include those under the Sarbanes-Oxley and Dodd-Frank Acts, the anti-retaliation provisions enforced by the Occupational Safety and Health Administration, the anti-retaliation provisions of Title VII, the ADA and the FLSA, the Defend Trade Secrets Act immunity at clause 21.2, and, for a worker in the United Kingdom, the Public Interest Disclosure Act 1998. The Company will not argue that a confidentiality clause displaces any of them.

30.3 External routes. Depending on subject matter: the Equal Employment Opportunity Commission or a state fair-employment agency for discrimination and harassment; the Department of Labor for wage and hour matters; OSHA for safety and for retaliation complaints; the Federal Trade Commission for deceptive advertising; the Commodity Futures Trading Commission and the National Futures Association for conduct concerning trading representations; the Financial Crimes Enforcement Network for financial-crime concerns; and the relevant data-protection authority for personal-data concerns.

30.4 No interference. The Company will not require notice of an external report, will not seek to identify an anonymous reporter, and will not condition any payment, reference or settlement on a person refraining from making one.

31.1 Order of precedence. Where documents conflict: mandatory law prevails over all; then a signed written agreement between the Company and the individual; then this Code; then any other policy or guidance. Part A prevails over Part B where both address the same subject.

31.2 Severability. If any clause is unenforceable in a jurisdiction, it is read down to the extent necessary and the remainder continues in force.

31.3 No waiver. The Company’s failure to enforce a clause on one occasion is not a waiver of it on another.

To be completed by every employee, contractor and intern at engagement, and retained under clause 15.1.

I confirm that I have read the ERIANUX, LLC Code of Conduct (ERX-POL-001), that I have had the opportunity to ask questions about it, and that I agree to comply with it. I understand that this Code is not a contract of employment, that it does not alter the at-will nature of employment, and that the Company may amend it. I understand that I am expected to report conduct that falls short of it, that a good-faith report will not be held against me, and that nothing in this Code prevents me from reporting a suspected violation of law to a government agency.