Code of Ethics

MCC is committed to acting with the utmost integrity, in a fair and professional manner in all its business dealings and relationships wherever they operate, implementing and enforcing effective systems to follow the law.

MCC is committed to fostering an inclusive environment where all employees are treated with respect, fairness, and empathy.

MCC ensures a diverse, safe, healthy, and professional working environment. Across its companies and associations, employees understand there is zero tolerance at MCC for any type of modern slavery, human/child rights abuse or human trafficking.

MCC believes in personal responsibility at all levels of the organization. All complaints regarding harassment, discrimination, misconduct, abusive conduct, and/or retaliation will be fully investigated, resulting in legal action to be taken if warranted, and including but not limited to dismissal.

The Company encourages its employees to communicate, raise concerns or questions and report any potential violations they may be aware of. MCC absolutely opposes retaliation of any kind. Reporting can be done directly with HR or Compliance.

The Company must keep accurate and detailed records of all transactions. False or artificial entries shall not be made in the books and records of the company for any reason.

Without limitation, the Company has developed a specific policy that covers, among others: a. Money laundering, bribery, and corruption; b. Political and charitable contributions; c. Gifts, hospitality, and entertainment; and d. Due diligence as it relates to consultants, agents, sanctions, and trade restrictions.

Beyond any applicable Confidentiality Agreements, employees may not disclose any proprietary or confidential information that is made available to them during their time of employment, unless legally required to do so or expressly authorized by the Company, and such obligation shall continue beyond the time of their employment at MCC.

Employees must steer clear of engaging in any activities or investments that put their interests in direct conflict with the Company’s interests. Any potential conflict must be disclosed in advance of any engagement and approved by Management if necessary.

Each employee is expected to comply with applicable legal requirements and regulations, whether in their home country or any country where MCC transacts business.