Lion Energy Code of Conduct

Document Reference: LE-CC-001
Effective Date: January 2025
Approved By: Executive Leadership Team
Applies To: All Lion Energy employees, officers, contractors, vendors, and partners

1. Purpose and Principles

   This Code of Conduct (“Code”) outlines Lion Energy’s commitment to ethical behavior, integrity, and accountability in all aspects of our business. It establishes the standards that guide our actions and decisions.

   Related Policies:

• LE-HR-101: Equal Employment Opportunity Policy
• LE-EHS-001: Environmental Health and Safety Policy
• LE-SEC-003: Data Protection and Cybersecurity Policy
• LE-GOV-010: Whistleblower and Ethics Reporting Policy

2. Core Values

   We live by five guiding principles that define the Lion Energy way:

   1. Integrity & Honesty — Always act truthfully and own your decisions.
   2. Safety & Sustainability — Protect people and the planet in every action.
   3. Respect & Inclusion — Value every person and voice.
   4. Accountability — Do what you say and follow through.
   5. Customer Focus — Power people’s lives with trust and care.

   Reference: ISO 26000 (Social Responsibility); UN Global Compact Principles 1–6

3. Legal and Ethical Compliance

   We operate in accordance with all applicable laws and regulations governing our industry and markets, including but not limited to:

   • U.S. Department of Energy Regulations
   • Federal Trade Commission (FTC) guidelines on advertising and claims
   • Occupational Safety and Health Administration (OSHA) standards
   • Environmental Protection Agency (EPA) compliance requirements
   • General Data Protection Regulation (GDPR) (where applicable)
   • California Consumer Privacy Act (CCPA)
   1. Compliance Obligation — Employees must know and follow applicable laws, this Code, and company policies.
   2. Records Accuracy — Maintain complete and truthful documentation at all times.

4. Conflicts of Interest

   1. Avoidance — Avoid personal, financial, or other interests that may conflict with Lion Energy’s business.
   2. Disclosure — Report any potential or perceived conflicts to your supervisor or Compliance Officer.
   3. Gifts and Entertainment — Do not offer or accept items of value intended to influence business outcomes.

   Reference: LE-ETH-004 Conflict of Interest Policy; U.S. FCPA (Foreign Corrupt Practices Act)

5. Fair Dealing and Business Integrity

   1. Fair Competition — Compete honestly and avoid anti-competitive behavior.
   2. Anti-Bribery — Never engage in bribery or improper inducements (FCPA, UK Bribery Act).
   3. Supplier Conduct — Expect suppliers to adhere to the Lion Energy Supplier Code of Conduct (LE-SCC-002).

   Reference: ISO 37001 Anti-Bribery Management Systems

6. Protection of Company Assets

   1. Responsible Use — Use company resources for legitimate business purposes only.
   2. Confidentiality — Protect proprietary and non-public information.
   3. Cybersecurity — Follow IT security protocols and report suspected data breaches immediately.

   Reference: LE-SEC-003 Data Protection & Cybersecurity Policy; NIST SP 800-53

7. Workplace Conduct and Safety

   1. Respectful Workplace — Zero tolerance for discrimination, harassment, or bullying.
   2. Health and Safety — Comply with all OSHA and internal safety standards.
   3. Substance-Free Environment — Alcohol or illegal drug use on duty is prohibited.

   Reference: OSHA 29 CFR 1904; LE-EHS-001 Environmental Health & Safety Policy

8. Environmental Stewardship

   1. Sustainability Commitment — Operate responsibly to reduce environmental impact.
   2. Product Responsibility — Ensure safety and recyclability of all Lion Energy products.
   3. Continuous Improvement — Pursue eco-innovation in design and manufacturing.

   Reference: ISO 14001 Environmental Management Systems; LE-EHS-003 Sustainability Policy

9. Reporting and Whistleblower Protection

   1. Reporting Channels — Employees may report concerns confidentially through:
      • Supervisor or HR representative
      • Compliance Officer
      • Ethics Hotline: hr@lionenergy.com
   2. Non-Retaliation — Retaliation against whistleblowers is strictly prohibited.
   3. Investigation — All reports will be reviewed promptly and fairly.

   Reference: LE-GOV-010 Whistleblower and Ethics Reporting Policy; Sarbanes-Oxley Act §806

10. Accountability and Disciplinary Action

    Violations of this Code may result in corrective measures, up to termination of employment or contract, and potential legal action. Managers are responsible for ensuring compliance within their teams.

11. Acknowledgment

    All employees must review, understand, and certify compliance with this Code upon hire and annually thereafter.

    Document Control:

    • Revision: 1.0
    • Reviewed by: Compliance & Legal Department
    • Next Review: January 2026

12. Our Commitment

    At Lion Energy, we don’t just power devices — we empower people.

    By living our values and honoring this Code, we strengthen our integrity, protect our community, and drive a cleaner, brighter future.

    YOUR LIFE. YOUR POWER. YOUR WAY.