INTRODUCTION

Mount Everest Holdings (hereinafter to be called the “MEH”) is an ecommerce business set up in 2017 arising from the genius of its founder, Steve Ford, which continues to prosper today. All MEH activities must be carried out in observance of the law in the context of fair competition with honesty, integrity, propriety and good faith, respecting the legitimate interests of customers, employees, commercial and financial partners and the social context in which the MEH’s business activities are based. All those working in the MEH, without distinction or exception, must be committed to observing, or ensuring the observance, of these principles in the context of their own functions and responsibilities.

The belief that you are acting for the benefit of MEH can never justify the adoption of conduct in conflict with these principles. For these reasons and given the complexity of the situations in which MEH operates it is important to provide a clear definition of the values it recognizes, accepts and shares and the totality of responsibilities taken on by MEH both internally and externally. These are the reasons why this “Ethical Code” or “Code” has been drawn up, setting out a complex of principles and rules. The observance of such rules and principles by those for whom the Code is intended is thus of fundamental importance including for the prevention of the offences described in Legislative Decree no. 231 of 8 June 2000 and to ensure the proper functioning, the reliability and reputation of MEH.

The Ethical Code is a working resource in its own right and represents a reference point for all MEH stakeholders. The purpose of the Ethical Code is to ensure the application of propriety, fairness, integrity, honesty and professional discipline to the operations, conduct and manner of working used both in relations internal to MEH and in relations with external parties, ensuring that attention is always focused on compliance with the laws and regulations in the countries in which MEH operates in addition to compliance with the business procedures of MEH itself.

The Board of Directors of Mount Everest Holdings has been guided by the most advanced standards of corporate governance in the adoption of this Ethical Code in order to approve the above-cited principles of ethics and transparency and to reconcile the search for competitiveness with the requirements of a fair competitive environment.

Mount Everest Holdings will give high priority to the application of the Ethical Code, ensuring that there are sufficient resources available in terms of information, prevention and control as well as guaranteeing transparency in related operations and conduct and will not hesitate to intervene, where necessary, with corrective actions.