Code of Business Conduct & Ethics
Last Updated: June 2026
Introduction
At Berkshire Griffin Capital AG (“Berkshire Griffin†or the “Companyâ€), integrity, professionalism and responsible business conduct are fundamental to the way we conduct our business.
This Code of Business Conduct & Ethics (the “Codeâ€) sets out the principles and standards that guide our business activities and relationships.
The Code reflects our commitment to conducting business ethically, responsibly and in accordance with applicable laws and regulations.
This Code applies to our directors, officers, employees and, where appropriate, consultants, advisors and business partners acting on behalf of Berkshire Griffin.
1. Our Values
We are committed to:
- Integrity
- Professionalism
- Transparency
- Accountability
- Respect
- Fairness
- Responsibility
- Long-term value creation
These values guide every business decision we make.
2. Compliance with Laws
We expect everyone acting on behalf of Berkshire Griffin to comply with all applicable laws, regulations and professional obligations relevant to their activities.
Where local laws differ from the principles contained in this Code, the higher ethical standard should be followed whenever legally permissible.
3. Integrity in Business
Business shall always be conducted honestly, fairly and ethically.
We expect decisions to be made objectively and in the best interests of the Company while respecting the legitimate interests of investors, business partners and other stakeholders.
4. Respect and Professional Conduct
Every individual should be treated with dignity, fairness and respect.
We strive to maintain a professional working environment that encourages collaboration, diversity, inclusion and mutual respect.
Harassment, discrimination, intimidation or abusive behaviour are inconsistent with our values.
5. Conflicts of Interest
Individuals should avoid situations in which personal interests could conflict, or appear to conflict, with the interests of Berkshire Griffin.
Potential conflicts should be disclosed promptly through the Company’s appropriate internal processes so they can be assessed and managed.
6. Anti-Bribery and Anti-Corruption
Berkshire Griffin maintains a zero-tolerance approach to bribery and corruption.
No person acting on behalf of the Company may offer, promise, request, authorise or accept improper payments, gifts or other advantages intended to influence business decisions unlawfully.
Reasonable business hospitality and customary business courtesies may be acceptable where lawful, proportionate and consistent with good business practice.
7. Anti-Money Laundering and Financial Crime
We support efforts to prevent money laundering, terrorist financing, fraud and other forms of financial crime.
Where appropriate, risk-based due diligence may be undertaken before entering into certain business relationships.
Suspicious activities should be reported through appropriate internal channels.
8. Sanctions Compliance
Business activities should be conducted in accordance with applicable economic sanctions and trade restrictions.
Where appropriate, counterparties and transactions may be reviewed against applicable sanctions requirements.
9. Confidential Information
Confidential information entrusted to Berkshire Griffin shall be protected and used only for legitimate business purposes.
Confidential information includes, among other things:
- investor information;
- business plans;
- financial information;
- commercial negotiations;
- project documentation;
- proprietary information;
- technical information.
Confidential information should not be disclosed without proper authorisation unless required by law.
10. Data Protection
We respect the privacy of individuals and seek to process personal data responsibly and in accordance with applicable data protection laws.
Personal information should only be accessed and processed where necessary for legitimate business purposes.
11. Accurate Records
Business records should be complete, accurate and maintained in accordance with applicable legal and regulatory requirements.
No false, misleading or intentionally incomplete records should be created.
12. Responsible Communications
All public communications made on behalf of Berkshire Griffin should be accurate, professional and consistent.
Only authorised persons should communicate externally on matters relating to the Company.
13. Fair Competition
We are committed to competing fairly and lawfully.
We do not engage in anti-competitive practices or conduct that could undermine fair and open markets.
14. Human Rights
We support internationally recognised human rights and expect business relationships to be conducted with respect for human dignity.
We oppose forced labour, child labour, human trafficking and unlawful discrimination.
15. Environmental Responsibility
We recognise the importance of responsible environmental stewardship.
Where appropriate, environmental considerations form part of our long-term business strategy and decision-making processes.
16. Gifts and Hospitality
Business gifts and hospitality should:
- be reasonable;
- be transparent;
- comply with applicable laws;
- never improperly influence business decisions.
Improper gifts, payments or benefits must not be offered or accepted.
17. Protection of Company Assets
Company assets—including financial resources, intellectual property, confidential information, equipment and technology—should be protected against misuse, loss, theft or unauthorised disclosure.
They should be used responsibly and solely for legitimate business purposes.
18. Speaking Up
We encourage individuals to raise concerns in good faith regarding suspected misconduct, unethical behaviour or possible violations of applicable laws or this Code.
Reports should be made promptly through appropriate channels.
Berkshire Griffin does not tolerate retaliation against individuals who report concerns honestly and in good faith.
19. Responsibility
Everyone acting on behalf of Berkshire Griffin shares responsibility for maintaining the highest standards of integrity and ethical conduct.
Compliance with this Code is an important element of maintaining the confidence of investors, financial institutions, regulators and business partners.
20. Review of this Code
This Code may be reviewed and updated periodically to reflect changes in legal requirements, regulatory expectations, business practices and corporate governance standards.
The latest version will be published on our website.
Contact
For questions regarding this Code or related compliance matters, please contact:
Berkshire Griffin Capital AG Bahnhofstrasse 10 CH-6300 Zug Switzerland Tel.: +41 41 544 3692 Email: contact@berkshire-griffin.com