Code of Conduct

The Board of Primex ehf. (“the Company”) considers it essential that the Company's operations and business be conducted with integrity and that the reputation of stakeholders and the Company be safeguarded. The Board also considers it important to have a Code of Conduct in force to guide ethical and social responsibility, both within the Board and the Company and in external dealings.

The Code provides guidance and helps us assess the diverse issues we encounter in our daily work while supporting sound decision‑making. These rules are our compass and are intended to support the Primex employees and any party acting on behalf of the Company where conflicts of interest or ethical questions arise.

1. Scope
This Code applies to:
• The Board and its subcommittees.
• Management.
• All employees of the Company.

The Board and all managers are responsible for leading the implementation and monitoring of the Code and for acting as role models. Everyone covered by the Code must comply with it and adopt it in their day‑to‑day work.

2. Objectives
The objective of this Code is to ensure that the Company's business is conducted with integrity and that the reputation of the Company and its stakeholders is protected. We achieve this by each of us taking responsibility for ensuring that honesty, fairness, and respect characterize our interactions and work within Primex and externally. We undertake to know, understand, and comply with all laws, regulations, policies, procedures, and codes applicable to our work, and to seek guidance where our understanding is insufficient or where we suspect that laws or the Code have been breached.

The Board and all managers are responsible for supervising and responding to any reports concerning breaches of laws or this Code and for ensuring such matters are handled appropriately.

3. Stakeholders
We emphasize that all stakeholders are considered in applying the Code. The Code shall be enforced and interpreted in line with the objectives stated above and the interests of the Company's stakeholders as applicable.

4. Social Responsibility, Human Rights, Environment, and Sustainability
Social responsibility, human rights, environmental matters, and sustainability are key components of Primex's strategy. We set high standards for ourselves and our suppliers regarding these areas and have adopted clear policies and objectives.

We respect human rights in all respects and aim to maintain positive relations within the communities where the Company operates and to have a positive impact on them.

We comply at all times with applicable environmental laws and are committed to minimizing our environmental footprint.

We place strong emphasis on ensuring the long‑term sustainability of the resources on which the Company's operations depend.

5. People
We commit to respecting employment‑related rights in accordance with statutory rights and place a strong emphasis on employee health and safety by providing a good working environment, training, and education in line with the Company's safety policy. We promote equality in the workplace and maintain fair and professional conduct in all interactions. Bullying or harassment of any kind will not be tolerated.

6. Integrity in Business
We emphasize professionalism, honesty, and fairness in business, comply with laws and regulations and generally accepted ethical standards, and expect the same from those with whom Primex does business. We are unequivocal in upholding good business practices and do not push the boundaries of what is legally or ethically acceptable.

All transactions of Primex ehf. are conducted on an arm's‑length basis. We do not tolerate bribery, corruption, conflicts of interest, or any improper advantage—whether offered by us or to us. We do not accept gifts or any other benefits that could diminish our credibility or that of the Company, or that could influence decision‑making or judgment, including adherence to the arm's‑length principle. When in doubt about accepting gifts or other benefits, we seek guidance from our immediate supervisor.

All Company transactions shall be recorded in the Company's books in accordance with recognized practices and are subject to audit.

Primex does not participate in any unlawful activities, including money laundering or bribery.

7. Conflicts of Interest
A conflict of interest arises when personal or non‑work‑related interests influence, or appear to influence, our work‑related decisions. Personal interests must not affect our professional decisions. We do not take part in decisions where we or related parties stand to benefit personally, nor do we hold roles that could create conflicts with the Company.

8. Competition
We support free competition and commit to fair and lawful competition in accordance with applicable legislation. We do not hinder lawful competition by others and we respect competition rules and practices. Agreements or actions that restrict competition will not be tolerated.

9. Profitability through Efficiency
One of the Company's roles is to generate returns for its shareholders in accordance with decisions of shareholders' meetings and the Board.

Profitability is also a prerequisite for operations and the jobs the Company sustains. We commit to working diligently to achieve profitability through efficient and economical operations, taking account of all stakeholders.

10. Confidentiality and Data Protection
All confidential and/or personal information held by Primex is handled with the utmost care and always in accordance with applicable laws and procedures. We do not use confidential information for personal gain, whether for ourselves or others. The duty of confidentiality continues after employment ends. We use information technology and communication channels responsibly.

11. Protection of Assets and Data
The Company's assets may be financial, tangible, or intangible—for example, real estate, equipment, funds, software, know‑how, intellectual property, trade secrets, and data generated by the Company.

We treat the Company's assets and data with respect and ensure their secure preservation. We use assets and data only for the benefit of the Company and not for personal use or gain.

Special care shall be taken with electronic data, which must be handled and stored responsibly and appropriately.

We are all representatives of the Company both during and outside working hours—including on social media—and we refrain from any behavior that could harm or diminish the Company's reputation, its trademarks, or related brands.

12. Communication and Disclosure
We treat one another with respect and communicate openly with colleagues and stakeholders.

We are committed to ensuring that the Company's disclosures to stakeholders are accurate, concise, and correct at all times. We always observe our authorization to speak on behalf of the Company. We otherwise place strong emphasis on transparency for stakeholders in relation to the Company's governance. Stakeholder communications are highly valued, and we aim to listen to their views on the Company's strategy and operations.

13. Reporting of Breaches
We are determined not to allow improper business practices to occur. It is the duty of each of us to ensure that no legal violations, breaches of this Code, or breaches of other policies, rules, or practices occur within Primex.

If employees have a well‑founded suspicion of such breaches, they must report them to one of the following:
1. Their immediate supervisor.
2. The next level supervisor
3. The CEO of Primex ehf.
4. The Chair of the Board (if the CEO is concerned).
5. The Vice‑Chair of the Board (if the Chair is concerned).

All reports will be taken seriously and investigated. Employees will not be subject to reprisals, whether direct or indirect, if they in good faith report a well‑founded suspicion of a breach under this section. The reporter's anonymity will be preserved in handling such cases.

14. Sanctions
Breaches of this Code may result in disciplinary action, including warning or dismissal, in accordance with applicable employment legislation.