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Purpose Statement

This Code of Conduct sets out the principles, values, and standards of behavior that guide every member of the Magnetic family — from our most senior executives to our newest team members, contractors, consultants, and business partners. It is the foundation of the trust we build with each other, our clients, our shareholders, and the broader communities in which we operate.

At Magnetic, we believe that lasting success is built on a culture of integrity. We hold ourselves to the highest ethical standards, not merely because the law requires it, but because it is the right way to conduct business. Every decision we make, every relationship we cultivate, and every action we take must reflect our core values: honesty, accountability, respect, and excellence.

This Code is not an exhaustive list of rules. Rather, it is a guide to help you make sound judgments when faced with difficult situations. When in doubt, ask yourself: "Would I be comfortable if my manager, a colleague, or the public could see exactly what I am doing and why?" If the answer is no, reconsider your course of action.

Compliance with this Code is a condition of employment at Magnetic. Violations may result in disciplinary action, up to and including termination of employment, as well as legal consequences where applicable. We encourage all employees to speak up if they witness conduct that appears to violate this Code or any applicable law.

Table of Contents

1 Purpose Statement

2. Our Core Values

3. Workplace Conduct & Respect

3.1. Equal Opportunity & Non-Discrimination

3.2. Anti-Harassment Policy

3.3. Workplace Safety

4 Conflicts of Interest

4.1. Outside Employment

4.2. Personal Relationships

4.3. Gifts & Entertainment

5 Confidentiality & Data Privacy

5.1. Protecting Company Information

5.2  Customer & Partner Data

6. Financial Integrity & Reporting

7. Use of Company Resources

8.  Social Media & Communications

9. Environmental & Social Responsibility

10. Reporting Violations & Non-Retaliation

11. Disciplinary Consequences

12. Acknowledgement & Agreement

Our Core Values

Integrity

We act honestly and transparently in all our interactions, holding ourselves accountable to the highest ethical standards even when no one is watching.

Respect

We treat every individual with dignity and fairness, embracing diversity of thought, background, and experience as a source of strength.

Excellence

We pursue the highest quality in our work, continuously learning and innovating to deliver outstanding results for our clients and stakeholders.

Accountability

We take ownership of our decisions and their outcomes, following through on our commitments and acknowledging mistakes when they occur.

Collaboration

We work as one team, sharing knowledge and supporting one another to achieve goals that none of us could accomplish alone.

Sustainability

We consider the long-term social, environmental, and economic impact of our decisions, building a business that endures for future generations.

Workplace Conduct & Respect

Magnetic is committed to maintaining a workplace that is safe, inclusive, and free from all forms of harassment, discrimination, and intimidation. Every employee has the right to work in an environment where they are valued and treated with dignity.

3.1     Equal Opportunity & Non-Discrimination

We are an equal opportunity employer. All employment decisions — including hiring, promotion, compensation, and termination — are made on the basis of qualifications, merit, and business needs, without regard to race, color, religion, gender, gender identity, national origin, age, disability, sexual orientation, marital status, or any other protected characteristic.

3.2     Anti-Harassment Policy

Harassment of any kind will not be tolerated. This includes verbal, physical, or visual conduct that creates an intimidating, hostile, or offensive work environment. Sexual harassment — including unwelcome advances, requests for favors, and other conduct of a sexual nature — is strictly prohibited.

Prohibited behaviors include, but are not limited to:

• Offensive jokes, slurs, or derogatory comments based on protected characteristics

• Unwanted physical contact or intimidation

• Display or distribution of offensive materials

• Retaliation against anyone who reports harassment in good faith

3.3     Workplace Safety

We are committed to providing a safe working environment. Employees must adhere to all safety policies and procedures, report unsafe conditions immediately, and never engage in violence or threatening behavior. The use of alcohol or illegal substances in the workplace or while conducting company business is strictly prohibited.

Conflicts of Interest

A conflict of interest arises when personal interests or relationships interfere — or appear to interfere — with your ability to act in the best interests of Magnetic. Employees must disclose any actual or potential conflict to their manager and the Ethics & Compliance team promptly.

4.1     Outside Employment

Employees may not accept outside employment or engage in business activities that compete with Magnetic, consume time or energy needed for your role, or create a conflict of interest without prior written approval from Human Resources.

4.2     Personal Relationships

Romantic or close personal relationships between employees in a direct reporting chain must be disclosed to HR. Managers may not be involved in employment decisions affecting a close personal associate, family member, or romantic partner.

4.3     Gifts & Entertainment

Employees must not offer or accept gifts, hospitality, or other benefits that could influence — or appear to influence — business decisions. Modest, infrequent gifts or meals of nominal value (<$50) in the ordinary course of business are generally acceptable. All gifts above this threshold must be reported. Cash gifts are never acceptable.

Confidentiality & Data Privacy

5.1     Protecting Company Information

Employees must protect confidential company information, including business strategies, financial data, intellectual property, personnel records, and technical know-how. Confidential information may not be shared outside the company without proper authorization. This obligation continues after employment ends.

5.2     Customer & Partner Data

We collect and use personal data responsibly, in compliance with all applicable privacy laws and regulations. Employees must access only the data necessary for their job, store it securely, and immediately report any suspected data breach to the Information Security team.

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Financial Integrity & Reporting

Magnetic is committed to accurate, complete, and transparent financial reporting. All financial records — including expense reports, invoices, contracts, and accounting entries — must be honest and prepared in accordance with applicable accounting standards and internal controls.

Employees must never falsify records, misrepresent financial data, or circumvent internal controls. Any concerns about accounting practices or financial reporting should be reported immediately to the Chief Financial Officer.

Employees with access to material non-public information about Magnetic or other companies must comply with all insider trading laws and company policies regarding securities transactions.

Use of Company Resources

Company resources — including equipment, technology systems, facilities, funds, and the company's name and reputation — are to be used for legitimate business purposes. Incidental personal use of company technology is permitted, provided it does not interfere with work or violate any policy.

• Do not use company resources for personal financial gain or any outside business.

• Do not store, transmit, or access illegal or inappropriate content on company systems.

• Safeguard all company property against theft, loss, and misuse.

• Report lost or stolen equipment immediately to IT Security.

08

Social Media & Communications

 Employees are personally responsible for their online activity. When posting about Magnetic — even on personal accounts — be professional, accurate, and respectful. Do not disclose confidential company information or make statements that could be construed as official company positions without authorization from Communications.

All external communications on behalf of Magnetic — including press releases, media inquiries, investor communications, and public statements — must be coordinated through the Corporate Communications or Investor Relations teams.

09

Environmental & Social Responsibility

Magnetic recognizes that our long-term success depends on the health of the communities and ecosystems in which we operate. We are committed to minimizing our environmental footprint, supporting the communities where we work, and conducting our business in a way that reflects our respect for human rights.

Employees are encouraged to embrace sustainable practices, participate in community initiatives, and surface ideas that advance our ESG commitments. We will not knowingly engage with suppliers or partners who violate human rights, employ child or forced labor, or engage in corrupt practices.

Reporting Violations & Non-Retaliation

If you see something, say something. Speaking up is not just permitted — it is expected.

Employees who become aware of a potential violation of this Code, company policy, or applicable law must report it promptly. You may report concerns to your manager, HR, or the Legal Department.

Magnetic strictly prohibits retaliation against anyone who makes a good-faith report of a potential violation or participates in an investigation. Any employee who retaliates against a reporting individual will be subject to disciplinary action, up to and including termination.

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Disciplinary Consequences

Violations of this Code will result in disciplinary action commensurate with the nature and severity of the misconduct. Consequences may include:

• Verbal or written warning

• Mandatory ethics training or counseling

• Suspension with or without pay

• Demotion or reassignment

• Termination of employment

• Civil litigation or referral to law enforcement authorities

The existence of this Code does not create a contract of employment. Magnetic reserves the right to modify, update, or rescind this Code at any time.

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Acknowledgement & Agreement

All employees and covered individuals are required to read this Code of Conduct in its entirety and sign the Acknowledgement Form confirming that they have read, understood, and agree to abide by its provisions. This form must be completed within 30 days of joining Magnetic and upon each annual renewal.

Employee Full Name

Job Title

Department

Date

Signature