Entity: ITHOLDINGS SERVICES LLC (a Wyoming limited liability company)

ITHOLDINGS SERVICES LLC (the “Company”) is committed to conducting all its business activities ethically, lawfully, and with full respect for human rights. This Code of Conduct sets out the principles that govern the Company and that bind its sole member, manager, and any employees, contractors, agents, or representatives engaged by the Company, in all jurisdictions where the Company operates. Compliance with this Code is mandatory and is a condition of any working relationship with the Company.

The Company respects and supports the protection of internationally recognized human rights. The Company treats every person it works with, including any personnel, contractors, and agents, with dignity and respect, and does not tolerate any form of physical, sexual, or psychological abuse, harassment, intimidation, exploitation, or coercion.

The Company strictly prohibits the use of forced, bonded, indentured, or involuntary prison labor, and any labor obtained through threat, coercion, or deception. The Company does not engage in, facilitate, or tolerate human trafficking or modern slavery in any form, and requires the same standard of any party with whom it does business. No person is required to surrender, and every person is permitted to freely hold and access their personal identity and immigration documents.

The Company does not employ or engage any person below the age of sixteen (16) years, or below the applicable legal minimum working age where higher. The Company will not knowingly do business with any party that uses child labor.

Any employee, contractor, agent, or other interested party may report, in good faith, a known or suspected violation of this Code — including any concern relating to forced labor, child labor, prison labor, or human trafficking — directly to the Sole Member and Manager of the Company. Reports may be made confidentially and, where permitted, anonymously, by email to the contact address below. The Company prohibits any form of retaliation against any person who raises concern in good faith or who participates in the review of such a concern. All reports are reviewed promptly and addressed with appropriate corrective action.

Effective date: January 1, 2025