Code of Ethics

At Nymbus Capital Inc. (“Nymbus”), we recognize that the integrity and professionalism of our employees are essential to maintaining our reputation and the trust of our clients. This Code of Ethics outlines the principles and standards that guide the conduct of all employees, ensuring we act with fairness, honesty, and respect in everything we do.

1. Overview and General Principles

Nymbus, its executives, employees, and directors conduct their activities according to the highest standards of ethics and integrity. All employees adhere to the principles in this Code of Ethics from the moment they are hired to preserve the company’s reputation and ensure consistent professional conduct. This Code applies to all employees, including part-time, temporary, contract workers, interns, contractual service providers, and advisors, including subsidiaries of Nymbus.

2. Professionalism

Employees act with integrity, competence, diligence, respect, and ethical behavior toward clients, potential clients, employers, colleagues, and other market participants. All employees read, understand, and follow this Code. Failure to comply may result in disciplinary actions, including termination. Employees are encouraged to raise any concerns or issues with their supervisors.

3. Compliance with Laws, Policies, and Procedures

3.1. Compliance with Laws and Regulations

• Nymbus and its employees comply with all applicable laws, regulations, and professional standards.

• In conflicts between rules, the strictest standard applies.

• Employees do not knowingly participate in or assist violations.

• Nymbus policies reflect legal requirements and govern company activities.

• Additional policies may apply to certain roles.

• Employees certify upon hiring and annually that they understand and comply with policies and the Code of Ethics.

• Employees act honestly, with integrity and respect, avoiding suspicious activities.

3.2. Reporting Violations

• Employees report violations or suspected violations to the Chief Compliance Officer (CCO).

• If the CCO is involved, reports go to the Designated Privacy Representative (DPR).

• Reporting is encouraged and protected.

3.3. Consequences of Non-Compliance

• Violations risk company reputation and may cause legal, financial, or regulatory penalties.

• Disciplinary measures range from warnings to termination depending on severity.

• Executives and officers are also accountable.

• Full cooperation with investigations is mandatory.

4. Exceptions to Policies

• Employees request exceptions in writing to the CCO with justification.

• Exceptions are granted only in writing and must comply with laws.

5. Employee Authority

• Employees cannot bind Nymbus contractually or speak on its behalf beyond their duties.

6. Loyalty and Non-Solicitation

• Clients belong exclusively to Nymbus; employees may not take or use client information.

• Upon leaving, employees must not copy or use client information.

• Soliciting or recruiting employees, advisors, representatives, or clients during employment and for two years after termination is prohibited.

7. Respect for Clients and Nymbus

• Employees maintain professionalism and trust in client interactions.

• Confidentiality of company and client information is strictly observed.

• Employees protect Nymbus’s reputation and assets.

8. Supervision and Delegation

• Nymbus supervises employee compliance and risk mitigation.

• Supervisors may delegate tasks but retain responsibility.

• Delegations comply with laws and policies and require qualified personnel.

• Supervisors review delegated tasks regularly, especially for executives and officers.

9. Inquiries and Public Communication

• Employees direct all inquiries from the public, clients, or media regarding Nymbus’s policies, practices, or services to the appropriate department or designated spokesperson.

• Employees must not provide unauthorized information or make statements on behalf of Nymbus without prior approval.

• All communication with external parties reflects the standards and values outlined in this Code of Ethics, ensuring professionalism, transparency, and respect.

• Employees are encouraged to seek guidance from their supervisors or the Compliance Department when uncertain about handling external inquiries.

For any public inquiries or questions related to Nymbus’s Code of Ethics, please contact:

Nymbus Capital Inc.

ATTN: Chief Compliance Officer
1002 Sherbrooke Street West, Suite 1900
Montreal, Quebec H3A 3L6
514‑985‑1138 or 1‑833‑227‑2656 (toll‑free)

compliance@nymbus.ca

Effective as of August 1, 2025