This Code of Ethics applies to all Semis Capital SPC (Semis) directors, officers and employees, as well as to directors, officers and employees of each subsidiary of Semis. Such directors, officers and employees are referred to herein collectively as the “Covered Parties”, Semis and its subsidiaries are referred to herein collectively as “Semis”. Semis has and will continue to uphold highest levels of business ethics in all types of transactions. With this Code of Ethics we aim to emphasize the our commitment to ethics and compliance with the law, document the basic standards of ethical and legal behavior, help prevent and detect wrongdoing and provide reporting tools for suspected ethical or legal violations. This Code of Ethics serves only as a rough guide due to the complexity of ethical questions that arise in the course of business.


A conflict of interest exists when a person’s private interest interferes in any way directly or not with the interests of Semis. As conflicts of interest may not always be obvious, it is advised in case of questions to consult a supervisor or the legal department. Every Covered Party should bring to the attention of the legal department or a supervisor any knowledge of a conflict or potential conflict.


Covered Parties are prohibited from taking for themselves opportunities that are discovered through the use of corporate property, corporate resources or information without the consent of the legal department of Semis.


Covered Parties shall always act in good faith, with due care, and shall engage only in fair and open competition, by treating ethically competitors, suppliers, customers, and colleagues. No gift should ever be offered or accepted by a Covered Party or any family member of a Covered Party unless it is consistent with customary business practices, is not excessive in value, cannot be construed as a bribe or payoff and does not violate any laws or regulations. The offer or acceptance of cash gifts by any Covered Party is prohibited.


Covered Parties who have access to confidential information are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of the Semis’s business. All non-public information about Semis should be considered confidential information.


Covered Parties have to maintain the confidentiality of confidential information, except when disclosure is authorized by the legal department of Semis or required by law. The obligation to preserve confidential information continues even after employment ends.


All Covered Parties should endeavor to protect Semis´s assets. Any suspected incident of fraud or theft should be immediately reported for investigation.


Obeying the law, is the foundation on which Semis´s ethical standards are built.

In conducting the business of Semis, the Covered Parties shall comply with applicable governmental laws, rules and regulations at all levels of government in the Cayman Islands and in any other jurisdiction in which Semis does business.


Covered Parties should report to supervisors, managers or other appropriate personnel about known or suspected illegal or unethical behavior.

No retaliatory action of any kind will be permitted against anyone making such a report in good faith.