Our Quality Policy is a clear statement of commitment to quality, endorsement by senior management, and a commitment to communicate the policy throughout the organization, emphasizing the importance of quality in the firm’s operations.

Statement of Commitment to Quality

The Solomon Brokerage Firm is unwavering in its commitment to delivering the highest standards of quality in wholesale trading and commodity trading. We understand that quality is not just a goal but a fundamental principle that drives our operations. We are dedicated to providing exceptional value to our clients, upholding ethical trading practices, and continuously improving our services.

Endorsement by Senior Management

This Quality Policy is fully endorsed by our senior management team, including our Chief Executive Officer, Chief Operating Officer, and other key leaders. They are committed to fostering a culture of quality throughout the organization, ensuring the implementation of quality management practices, and providing the necessary resources to achieve our quality objectives.

Communication Throughout the Organization

To instill a sense of responsibility and ownership of quality in every team member, we communicate this policy extensively throughout the organization. This includes regular training, awareness programs, and discussions on the importance of quality in achieving our mission and vision. Every employee is encouraged to understand, embrace, and uphold this policy in their daily work.

Responsibility for Policy Implementation

We have designated a Quality Management Team responsible for implementing and monitoring this policy. Their role includes ensuring compliance with quality standards, conducting regular audits, and fostering a culture of continuous improvement. At The Solomon Brokerage Firm, quality is not just a process; it’s our way of doing business. Our commitment to quality guides our decisions and actions, ensuring that we remain a trusted partner in the wholesale and commodity trading industry.

The Solomon Brokerage Firm is committed to conducting its business with the highest level of ethics and integrity. This Ethics and Code of Conduct Policy outlines the company’s core values, standards of behavior, and expectations for employees, contractors, partners, and all individuals associated with our organization.

Policy Statement

The Solomon Brokerage Firm is dedicated to the following principles:

• Integrity: We are committed to conducting all business activities with honesty, transparency, and the highest moral and ethical standards. We do not compromise our principles for personal gain or professional advancement.
• Respect: We treat all individuals with respect, dignity, and fairness, regardless of their background, beliefs, or affiliations. Discrimination, harassment, and unethical behavior are not tolerated.
• Confidentiality: We respect the privacy and confidentiality of information entrusted to us by clients, colleagues, and partners. Sensitive and confidential information is handled with the utmost care.
• Accountability: We take responsibility for our actions and decisions, and we are transparent in our communications. We adhere to laws and regulations and are accountable for the consequences of our actions.
• Professionalism: We maintain a high standard of professionalism in all interactions, both within the company and with external stakeholders.
• Conflict of Interest: We avoid conflicts of interest that could compromise the best interests of the company and its clients. When conflicts arise, they are promptly disclosed and addressed.

Standards of Behavior

a. Honesty and Integrity

1. We are truthful and honest in all our interactions, both internal and external to the company.
2. We do not engage in fraudulent, deceptive, or unethical practices.
3. We disclose any actual or potential conflicts of interest.

b. Respect and Fairness

1. We treat all individuals with respect, regardless of their race, nationality, religion, gender, sexual orientation, age, or any other characteristic.
2. Discriminatory language or behavior, including harassment, is strictly prohibited.
3. We maintain a workplace free from discrimination and harassment.

c. Confidentiality

1. We safeguard sensitive and confidential information and data from unauthorized access or disclosure.
2. We respect the confidentiality of client and partner information.
3. We do not use or disclose confidential information for personal gain.

d. Accountability

1. We take responsibility for our actions and decisions.
2. We promptly report unethical behavior or violations of this policy.
3. We adhere to all laws, regulations, and company policies.

e. Professionalism

1. We maintain a professional demeanor in all interactions.
2. We are respectful and considerate in our communication with colleagues and clients.
3. We do not engage in behavior that could harm the reputation of the company.

Compliance
The Solomon Brokerage Firm is committed to complying with all relevant laws and regulations, including but not limited to financial regulations and laws governing ethical business conduct.

Review and Improvement

This Ethics and Code of Conduct Policy will be reviewed annually or as needed to ensure its effectiveness and relevance. We are committed to continuous improvement in our ethical practices to maintain the highest standards of conduct.

Enforcement

Non-compliance with this policy may result in disciplinary action, up to and including termination for employees or contract termination for external parties, as appropriate.

Our Document Control Policy outlines the procedures and guidelines for the management, creation, revision, distribution, and retention of documents at our organization. Its purpose is to ensure the efficient and effective control of company documents to maintain accuracy, consistency, and compliance with legal and regulatory requirements.

Policy Statement

At The Solomon Brokerage Firm, we are committed to maintaining a systematic and organized approach to document control to:

• Ensure that all documents are accurate, up-to-date, and reliable.
• Safeguard sensitive and confidential information.
• Facilitate efficient document retrieval and distribution.
• Comply with relevant laws and regulations.
• Enhance accountability and responsibility for document management.

Scope

This policy applies to all employees, contractors, and other personnel involved in the creation, distribution, revision, and management of documents at The Solomon Brokerage Firm.

Document Types

Documents covered by this policy include, but are not limited to:

• Business reports
• Contracts and agreements
• Policies and procedures
• Financial statements
• Marketing materials
• Correspondence
• Training materials

Any other written or electronic records created, received, or maintained by the organization.

At The Solomon Brokerage Firm, we recognize the profound impact of our operations on the environment. Our commitment to environmental responsibility is unwavering, and we pledge to conduct our business in a manner that minimizes our ecological footprint and promotes sustainability.

Our Commitment

We are dedicated to:

• Compliance: Strictly adhering to all environmental laws and regulations, ensuring that our operations meet or exceed the required standards.
• Sustainability: Promoting sustainable practices throughout our supply chain, from responsible sourcing to efficient resource utilization.
• Continuous Improvement: Striving for ongoing improvement in environmental performance by regularly reviewing and updating our environmental strategies.
• Transparency: Maintaining transparent communication with stakeholders about our environmental initiatives, progress, and challenges.

Principles and Values Guiding Environmental Efforts

Our environmental efforts are guided by the following principles and values:

• Stewardship: We view ourselves as stewards of the environment, responsible for protecting and preserving it for future generations.
• Ethical Conduct: We conduct our business with the utmost ethical integrity, ensuring that our environmental practices align with our core values.
• Innovation: We embrace innovation and seek out environmentally friendly technologies and practices that reduce our environmental impact.
• Collaboration: We actively collaborate with our partners, suppliers, and industry stakeholders to collectively address environmental challenges.
• Responsibility: We take responsibility for our actions and their environmental consequences, acknowledging that environmental responsibility is a shared duty.
• Accountability: We hold ourselves accountable for meeting our environmental goals and commitments, regularly monitoring and reporting our progress.
• Community Engagement: We engage with the communities where we operate, striving to make positive contributions to their environmental well-being.
• Adaptability: We remain adaptable and responsive to changing environmental conditions and challenges, ensuring our strategies remain effective.

The Solomon Brokerage Firm is committed to ensuring the highest level of data security to protect the confidentiality, integrity, and availability of user data and information. Our Security Policy outlines our commitment to safeguarding data and the measures in place to achieve this goal.

Policy Statement

The Solomon Brokerage Firm is dedicated to maintaining the highest standards of data security. We are committed to:

• Protecting user data from unauthorized access, disclosure, alteration, and destruction.
• Complying with all relevant data protection laws and regulations.
• Continuously improving our security practices to address emerging threats.

Data Classification

We recognize the importance of classifying data to apply appropriate security measures. Data at The Solomon Brokerage Firm is classified into three categories:

• Confidential Data: Confidential data includes sensitive information such as user financial data, personally identifiable information (PII), and proprietary business information. The highest level of security is applied to this data.
• Internal Data: Internal data includes non-public, non-confidential information related to the company’s operations, strategies, and non-sensitive customer data.
• Public Data: Public data includes information that is publicly available and does not require special security measures.

Security Measures

a. Access Control

• User Authentication: Access to systems and data is granted only to authorized personnel. User authentication is enforced using strong, unique passwords, two-factor authentication, or other secure methods.
• Role-Based Access: Access permissions are granted on a need-to-know basis, and roles and responsibilities are clearly defined.
• Account Lockout: Accounts are locked after a specified number of failed login attempts to prevent unauthorized access.

b. Data Encryption

• Data in Transit: All data transmitted over the network, especially sensitive data, is encrypted using secure protocols (e.g., HTTPS, TLS).
• Data at Rest: Sensitive data stored on servers or in databases is encrypted to protect against unauthorized access in the event of physical theft.

c. Regular Security Audits and Vulnerability Assessments

Regular security audits and vulnerability assessments are conducted to identify and remediate potential security weaknesses.

d. Employee Training

All employees and contractors receive security awareness training to ensure they understand and comply with security policies and best practices.

e. Incident Response Plan

The company maintains an incident response plan to address security breaches or data incidents promptly, minimizing potential damage.

f. Backup and Recovery

Regular data backups are performed to ensure data recovery in the event of data loss, system failures, or disasters.

Compliance

The Solomon Brokerage Firm is committed to complying with all relevant data security laws and regulations, including but not limited to the General Data Protection Regulation (GDPR), the Estonian Data Protection Act, and any other applicable laws.

Review and Improvement

This Security Policy will be reviewed annually or as needed to ensure its effectiveness and relevance. We are committed to continuous improvement in our security practices to address evolving threats.

Enforcement

Non-compliance with this policy may result in disciplinary action for employees or contract termination for external parties, as appropriate.

This Supplier Code of Conduct outlines the expectations and requirements for our suppliers to ensure a mutually beneficial and sustainable business relationship. By adhering to this code, suppliers align with our values and principles, fostering a harmonious partnership that enhances the overall quality and ethical standards of our operations.

Our Commitment

We believe that responsible and ethical business practices are not just a choice but a fundamental requirement for sustainable success. Through this code, we aim to create an environment where our suppliers, like us, prioritize ethical conduct, environmental responsibility, labor and human rights, quality, and data security. Together, we can build a stronger, more responsible, and mutually rewarding business ecosystem.

By upholding these shared principles, we strengthen our position as a responsible global business entity and contribute positively to the communities and industries we serve.

Key Expectations

The Supplier Code of Conduct for The Solomon Brokerage Firm outlines essential expectations for our suppliers, emphasizing compliance with laws and regulations, ethical business practices, environmental responsibility, labor and human rights, product quality and safety, data security and privacy, and reporting and compliance. These expectations are fundamental to our commitment to responsible and ethical business conduct.

These key expectations form the foundation of our Supplier Code of Conduct, reflecting our commitment to ethical, responsible, and sustainable business practices. We believe that by working together with our suppliers to uphold these standards, we can build a more transparent, responsible, and mutually beneficial business relationship.

Our Supplier Code of Conduct outlines the following key expectations for our suppliers, which are essential to maintaining our commitment to responsible and ethical business practices:

1. Compliance with Laws and Regulations

The Supplier Code of Conduct for The Solomon Brokerage Firm mandates that suppliers comply with various laws and regulations governing their operations. These include trade regulations, environmental regulations, labor laws, and ethical standards. Compliance with these regulations is essential to ensuring responsible and ethical business practices.

1.1 Trade Regulations

Suppliers engaged with The Solomon Brokerage Firm are required to diligently comply with all pertinent trade regulations governing their operations. This encompasses adherence to local, national, and international trade laws and treaties. These regulations may include import and export restrictions, customs requirements, and trade embargoes. Compliance with trade regulations is vital to ensuring the lawful and ethical conduct of business operations.

1.2 Environmental Regulations

Environmental responsibility is a fundamental expectation from our suppliers. This entails full compliance with environmental regulations that govern their activities. Suppliers must demonstrate a commitment to sustainable practices, including waste management, pollution control, resource conservation, and adherence to emissions standards. Upholding environmental regulations contributes to the preservation of the environment and the well-being of communities.

1.3 Labor Laws

The Solomon Brokerage Firm places a strong emphasis on labor laws and worker rights. Suppliers are obliged to adhere to local and international labor laws and standards. This includes providing fair wages, ensuring safe working conditions, and respecting the rights of workers, such as the freedom of association and collective bargaining. Compliance with labor laws supports fair and ethical labor practices.

1.4 Ethical Standards

Suppliers must operate in alignment with the highest ethical standards. This entails avoiding any actions that could compromise ethical integrity, including conflicts of interest, bribery, corruption, and any other unethical behavior. Upholding ethical standards fosters trust, integrity, and transparency in all business interactions.

Compliance with these laws and regulations is not only a legal obligation but also a moral imperative. The Solomon Brokerage Firm expects its suppliers to uphold the highest standards of integrity and responsibility, contributing to a business environment that is both lawful and ethically sound.

2. Ethical Business Practices

The Supplier Code of Conduct for The Solomon Brokerage Firm emphasizes the importance of ethical business practices. Suppliers are expected to uphold the highest ethical standards, including transparency and honesty, the avoidance of conflicts of interest, and the prohibition of bribery, corruption, and unethical practices. These principles are essential to maintaining trust and integrity in our business relationships.

2.1 Transparency and Honesty

At The Solomon Brokerage Firm, we hold our suppliers to the highest ethical standards.

Transparency and honesty in all business dealings are paramount. Suppliers are expected to provide accurate and truthful information in their interactions with us. This includes transparent reporting of financial information, pricing, and product specifications. Open and honest communication fosters trust and integrity in our business relationships.

2.2 Avoidance of Conflicts of Interest

Maintaining the integrity of our business relationships requires the avoidance of conflicts of interest. Suppliers must act in a manner that prevents personal, financial, or other interests from conflicting with the best interests of The Solomon Brokerage Firm. Any potential conflicts of interest should be promptly disclosed to ensure transparency and appropriate resolution.

2.3 Prohibition of Bribery, Corruption, and Unethical Practices

We have a zero-tolerance policy for bribery, corruption, and unethical practices. Suppliers are strictly prohibited from engaging in any form of bribery, kickbacks, or corrupt activities. Unethical practices that compromise the integrity of our business dealings are unacceptable. Suppliers must adhere to all applicable anti-corruption laws and regulations.

Maintaining the highest ethical standards is not only a legal requirement but also a fundamental aspect of our commitment to responsible and ethical business practices. Suppliers who uphold these principles contribute to a business environment built on trust, integrity, and mutual respect.

3. Environmental Responsibility and Responsible Sourcing

The Supplier Code of Conduct for The Solomon Brokerage Firm emphasizes the importance of environmental responsibility and responsible sourcing. Suppliers are expected to minimize their environmental impact by reducing waste and conserving resources. Additionally, they should engage in responsible sourcing practices and collaborate with partners who share a commitment to sustainability.

3.1 Minimizing Environmental Impact

The Solomon Brokerage Firm places a strong emphasis on environmental responsibility. We expect our suppliers to actively minimize their environmental impact by adopting sustainable practices. This includes reducing waste generation, conserving natural resources, and implementing energy-efficient measures in their operations. Suppliers should aim to reduce their carbon footprint and contribute to the preservation of the environment.

3.2 Responsible Sourcing Practices

Responsible sourcing is a crucial aspect of our Supplier Code of Conduct. Suppliers are required to engage in responsible sourcing practices when procuring materials and products. This involves considering the environmental and social impact of the sources they utilize. Suppliers should prioritize partners and suppliers who share our commitment to sustainability, ethical labor practices, and responsible resource management.

By adhering to these principles, we aim to create a supply chain that promotes environmental conservation and responsible sourcing throughout the entire production process. The joint efforts of The Solomon Brokerage Firm and its suppliers can contribute to a more sustainable and environmentally conscious business ecosystem.

4. Labor and Human Rights

The Supplier Code of Conduct for The Solomon Brokerage Firm underscores the importance of labor and human rights. Suppliers are obligated to ensure fair wages and safe working conditions while prohibiting child labor, forced labor, and workplace discrimination.

4.1 Fair Wages and Safe Working Conditions

At The Solomon Brokerage Firm, we prioritize the well-being of workers throughout our supply chain. To uphold labor and human rights, suppliers are required to provide fair wages and ensure safe working conditions for their employees. This includes:

• Fair Compensation: Suppliers must offer wages that are fair, competitive, and in accordance with local labor laws and industry standards.
• Safe Working Conditions: Suppliers must maintain a workplace that is safe, clean, and free from hazards, ensuring the health and safety of all employees.

4.2 Prohibition of Child Labor, Forced Labor, and Discrimination

We strongly condemn practices that violate human rights, and therefore, suppliers must adhere to the following principles:

• Child Labor: Suppliers must not employ individuals below the legal working age defined by local laws and international conventions.
• Forced Labor: Suppliers are strictly prohibited from using forced or involuntary labor practices.
• Non-Discrimination: Discrimination in any form, including race, gender, religion, age, or disability, is not tolerated in the workplace.

By enforcing these standards, The Solomon Brokerage Firm aims to create a supply chain that respects the dignity and rights of all workers, promoting a fair and ethical working environment.

5. Quality and Product Safety

The Supplier Code of Conduct for The Solomon Brokerage Firm highlights the importance of quality and product safety. Suppliers are expected to deliver products and services that meet agreed-upon quality standards and comply with all applicable safety regulations.

5.1 Meeting Agreed-Upon Quality Standards

At The Solomon Brokerage Firm, we are committed to providing high-quality products and services to our clients. Therefore, we expect our suppliers to uphold these standards by delivering products and services that meet the agreed-upon quality specifications. This includes:

• Product Quality: Suppliers must ensure that the products they provide are of the specified quality, free from defects, and meet the agreed-upon standards and specifications.
• Service Excellence: For service-oriented suppliers, the services offered should consistently meet the quality levels defined in the contract, ensuring client satisfaction.

5.2 Compliance with Safety Regulations

Product safety is of paramount importance to us. Suppliers must adhere to all safety regulations applicable to their products to guarantee the safety of consumers. This includes:

• Safety Standards: Suppliers must ensure that their products comply with all relevant safety standards and regulations in the regions where they are sold or used.
• Safety Documentation: Suppliers should provide adequate documentation demonstrating compliance with safety regulations, including certifications, testing reports, and safety data sheets.

By emphasizing quality and product safety, The Solomon Brokerage Firm aims to deliver reliable and safe products and services to our clients and maintain a reputation for excellence.

6. Data Security and Privacy

The Supplier Code of Conduct for The Solomon Brokerage Firm emphasizes the importance of data security and privacy. Suppliers handling sensitive data are required to ensure its security and confidentiality and adhere to all applicable data protection laws and regulations.

6.1 Ensuring Data Security and Confidentiality

The Solomon Brokerage Firm recognizes the importance of safeguarding sensitive data. Suppliers entrusted with handling such data are required to prioritize its security and confidentiality. This includes:

• Secure Storage: Suppliers must store sensitive data in secure environments, ensuring it is protected from unauthorized access, theft, or breaches.
• Access Control: Access to sensitive data should be restricted only to authorized personnel who require it for their designated tasks.
• Data Encryption: Sensitive data should be transmitted and stored using encryption methods to prevent unauthorized interception or access.

6.2 Adherence to Data Protection Laws and Regulations

To uphold the highest standards of data security and privacy, suppliers must comply with all relevant data protection laws and regulations applicable to their operations. This includes:

• Legal Compliance: Suppliers should familiarize themselves with and adhere to data protection laws in the regions where they operate, ensuring full legal compliance.
• Data Handling Practices: Suppliers should adopt best practices for data handling, including data minimization, consent management, and secure disposal when data is no longer needed.

By adhering to stringent data security and privacy standards, The Solomon Brokerage Firm and its suppliers can maintain the trust of clients and partners while ensuring the integrity and confidentiality of sensitive information.

7. Reporting and Compliance

The Supplier Code of Conduct for The Solomon Brokerage Firm emphasizes the importance of reporting violations promptly and cooperating fully with investigations and audits related to compliance with the code.

7.1 Reporting Violations

Suppliers engaged with The Solomon Brokerage Firm are expected to promptly report any violations of this Supplier Code of Conduct. Transparency and accountability are essential in upholding the highest ethical and operational standards. Reporting violations allows for timely resolution and ensures continuous improvement in our business practices.

7.2 Cooperation with Investigations and Audits

In the interest of compliance and maintaining ethical standards, suppliers are required to fully cooperate with investigations and audits related to compliance with this Supplier Code of Conduct. The Solomon Brokerage Firm may conduct audits and investigations to verify adherence to the code’s principles and standards. Supplier cooperation is crucial to ensure the effectiveness of these processes.

By adhering to these reporting and compliance requirements, The Solomon Brokerage Firm and its suppliers jointly contribute to a culture of integrity, accountability, and ethical business conduct.

Failure of Compliance

Failure to comply with The Solomon Brokerage Firm’s Supplier Code of Conduct may lead to the termination of the supplier relationship, emphasizing the importance of ethical and responsible business practices. We are committed to collaborating with suppliers who share our commitment to integrity and accountability.

Consequences of Non-Compliance

The Solomon Brokerage Firm places a strong emphasis on ethical and responsible business practices. Therefore, failure to comply with this Supplier Code of Conduct is taken seriously. Suppliers are expected to adhere to the principles and standards outlined in this code to maintain a collaborative and ethical partnership.

Failure to comply with the Supplier Code of Conduct may result in the termination of the supplier relationship with The Solomon Brokerage Firm. We believe that upholding the highest standards of integrity and ethical conduct is crucial to our business success and reputation.

Our Commitment to Ethical Partnerships

We are committed to collaborating with suppliers who share our dedication to ethical and responsible business practices. By working together with like-minded partners, we aim to create a sustainable and mutually beneficial business environment.

At The Solomon Brokerage Firm, we value transparency, integrity, and accountability. We encourage our suppliers to join us in upholding these values, fostering a culture of compliance and ethical conduct throughout our business relationships.

We understand that compliance may sometimes require support and guidance, and we are here to assist our suppliers in meeting the expectations outlined in this Supplier Code of Conduct. Together, we can build a strong, ethical foundation for our business partnerships.