Code of Ethics and Business Conduct

To All Employees:

XBP Europe is committed to the highest ethical principles and standards.

Our values – [EMPOWERMENT, COLLABORATION, TENACITY, CURIOSITY and TRUST] – are the foundation for our Code of Ethics and Business Conduct. It reflects our collective commitment to uphold these values in all that we do, and demonstrates their virtue in action.

This Code is our pledge to maintain ethical business practices and regulatory compliance. This Code and its underlying principles must guide our actions. It is broadly stated – it is not intended to be a complete listing of detailed instructions for every conceivable situation. Instead, this Code is here to help you make sound, informed business decisions and to act on them with integrity.

We trust you to act with integrity. If you are ever unsure of what is the right thing to do, never hesitate to ask your manager, the human resources department or the legal department, for guidance.

You are also empowered and encouraged to speak up if you see any behaviors that appear to breach this Code. Retaliation for bringing matters to our attention will not be tolerated. Your concerns will be investigated promptly and acted on appropriately.

All XBP Europe employees are responsible for understanding and complying with this Code.

Ultimately, our most valuable asset is our reputation. Complying with the principles and standards contained in this Code is the starting point for protecting and enhancing that reputation.

Thank you for your commitment!

Andrej Jonovic

CHIEF EXECUTIVE OFFICER