Skip to Content

Code of Ethics

ZINAI Code of Ethics(Deemed approved as of 20 Oct 2026)General PrinciplesPreambleEthical BaselineCompliance with LawSanctions & Proceeds of CrimeAnti-Bribery & Anti-CorruptionData, Privacy & IPData & PrivacyTrade Secrets & Intellectual PropertyFairnessConflicts of InterestFair Dealing & RespectDecencyDiversity, Equity & InclusionRespectful Workplace, Anti-Discrimination & Anti-harassmentCommunicationPublic CommunicationsSpeak-up & Non-retaliationConsequencesEscalationConsequence of BreachIncorporation & Binding Effect

ZINAI Code of Ethics
(Deemed approved as of 20 Oct 2026)

General Principles

Preamble

ZINAI Limited (the "Company") builds products that touch people's health, wellness & privacy. This Code of Ethics sets out the ethical baseline that binds every person acting for or on behalf of the Company, & is incorporated by reference into all key documents, & every counter-party contract executed by the Company..

Ethical Baseline

We are inclusive & act with honesty & integrity toward everyone. We do not deceive customers, regulators, investors, colleagues, counter-parties, or the general-public. We do not create records to misstate what happened. Falsification or destruction of records is grounds for termination & is prosecutable.

Compliance with Law

We comply with the laws of every jurisdiction in which we operate. Where laws conflict, we escalate.

Sanctions & Proceeds of Crime

We comply with all sanctions regimes applicable to us & do not knowingly transact with parties designated under those regimes. Where sanctions regimes conflict, we escalate rather than choose in silence. Concerns are escalated internally without delay & without tipping off the counter-party..

Anti-Bribery & Anti-Corruption

We do not offer, give, solicit or accept bribes, kickbacks or improper inducements. Gifts & hospitality above nominal value are pre-cleared. Facilitation payments are prohibited.

Data, Privacy & IP

Data & Privacy

We treat personal, health & clinical data as a trust, not an asset. We collect only what we need, protect it as our own most sensitive information, & respect data-subject rights.

Trade Secrets & Intellectual Property

We protect the Company's Trade Secrets & we respect those of others. We do not use another party's confidential information or intellectual property without licence.

Fairness

Conflicts of Interest

We disclose actual & potential conflicts of interest to the Head of IT & Compliance without delay. We do not use Company position for personal gain.

Fair Dealing & Respect

We deal fairly with customers, suppliers, competitors, colleagues, & every person we encounter in the course of our work. We do not exploit information asymmetries, coercive positions, market power, or vulnerability, mistake or ignorance to secure unfair advantage. We compete on the merits of our products & services.


Decency

Diversity, Equity & Inclusion

We recruit, develop, promote & compensate based on merit, capability, contribution & potential. We build a workforce that reflects diverse backgrounds, experiences & perspectives, because doing so makes us better at our work & more useful to the people we serve. We provide reasonable accommodations for persons with disabilities & for the differing needs of colleagues in different life circumstances.

Respectful Workplace, Anti-Discrimination & Anti-harassment

We are committed to a workplace in which every person is treated with dignity & respect. We do not tolerate discrimination, harassment, bullying or any form of adverse treatment based on sex, gender identity, gender expression, sexual orientation, marital or family status, pregnancy, race, ethnicity, national origin, religion, age, disability, or any other protected or personal characteristic.
Sexual harassment is expressly prohibited. Sexual harassment includes unwelcome sexual advances, requests for sexual favours, & any other unwelcome verbal, non-verbal, visual or physical conduct of a sexual nature, whether by a colleague, a person in authority, a subordinate, a counterparty, a customer, a supplier, or any other person in the course of Company work.
Harassment & discrimination may occur in person, in writing, over messaging, on video calls, at Company events (including social events), on business travel, & in any other setting connected to Company work.

Every person acting for the Company has an affirmative duty to report harassment, discrimination or bullying they experience or witness, through the Whistleblower/Speak-Up channels. Managers, aware of such conduct, have a duty to escalate immediately. Retaliation against anyone who reports in good faith is itself a breach of this Code. The Company will investigate reports proportionately, protect the reporter's confidentiality to the extent possible, & take appropriate action - up to & including termination, contract termination, referral to authorities, & civil or criminal proceeding.

Communication

Public Communications

Only personnel on the Board-approved Approved-Speakers register may speak publicly for the Company. In the absence of an available Approved Speaker such matters must be escalated to the CEO or their office.

Speak-up & Non-retaliation

Any person who in good faith reports a concern under this Code is protected from retaliation. Retaliation is itself a serious breach of this Code. The reporting channel is set out in the Whistleblower / Speak-Up Policy.

Consequences

Escalation

Concerns under this Code are escalated to the Head of IT & Compliance or, where the concern relates to the Head of IT & Compliance or the executive team, to the Chair of the Board.

Consequence of Breach

Breach of this Code is a matter for the Board & may result in termination, contract termination, referral to authorities & civil or criminal liability.

Incorporation & Binding Effect

This Code binds: (a) every director, officer, key personnel, employee & consultant of the Company, by execution of the PIIA or engagement letter; & (b) every counter-party of the Company, by contractual incorporation.