Code of Ethics and Conduct

Version 1.0 · May 2026.

I. Preamble

Mark One Properties Asset Management (herein-after “OneMark) is a Portuguese real estate development company founded in 2026, headquartered in Lisbon, operating across the Signature Living, Curated Living, KO-DA Smart Living Lofts segments and OPUS Buildings Reborn. The nature of its activity — long-duration real estate development, with clients, suppliers, public authorities, and communities across multiple geographies — requires a clear ethical framework, known by all those who work with the company and applied consistently.

This Code of Ethics and Conduct sets out the founding principles, rules of behavior, and mechanisms of enforcement that govern the activity of OneMark Properties. It applies to all directors, employees, consultants, and service providers of the company, without exception and regardless of hierarchical level or contractual arrangement.

The Code is not a marketing document. It is a management instrument. It is also the public promise that the company will live up to what is set out herein — and the commitment that it will act accordingly when anyone, inside or outside the organization, identifies a deviation.

II. Founding Principles

Integrity. OneMark Properties acts with honesty in all its relationships — with clients, partners, public authorities, suppliers, communities where it operates, and among its own employees. Integrity is not negotiable in light of circumstances, opportunities, or commercial pressures.

Transparency. All institutional, contractual, and financial communication by the company is marked by clarity, completeness, and the absence of concealment. What OneMark states in public is consistent with what it practices in private.

Respect for the Individual. The dignity of every person who comes into contact with the company — employees, clients, suppliers, residents, neighbors — is the starting point of any decision. OneMark does not tolerate discrimination, harassment, or any form of symbolic or material violence.

Excellence in Execution. The company delivers what it commits to deliver, at the quality promised and within the agreed timeframes. When something goes wrong, it communicates this honestly to those affected and implements the necessary corrections.

Long-Term Responsibility. OneMark designs its projects for generations, not for cycles. This temporal perspective informs its treatment of commercial relationships, its selection of materials and suppliers, and the environmental and social impact of its works.

III. Business Conduct

Fair Competition. OneMark competes in the market on the quality of its products, the competence of its team, and the coherence of its brand. It rejects anti-competitive practices — price-fixing agreements, market-sharing, abuse of dominant position — and rigorously complies with Portuguese and European competition law.

Anti-Corruption and Prohibition of Influence Peddling. The company does not offer, promise, authorize, or accept undue payments, gifts, or benefits intended to influence decisions — whether public (permitting, public procurement) or private (relationships with clients, suppliers, intermediaries). This rule applies in any geography in which OneMark operates, even where local practices may make it appear ordinary.

Gifts and Hospitality. Employees may offer and accept symbolic gifts and gestures of commercial courtesy within the limits of what is socially reasonable and professionally neutral. Above two hundred and fifty euros per event or three hundred and fifty euros in cumulative annual value per counterparty, any gift or hospitality must be reported to management and recorded. Invitations to events with overnight stays, sponsored travel, or benefits extended to family members are subject to prior approval.

Conflicts of Interest. Employees and directors shall report to the company, as early as possible, any situation that may constitute a conflict between their personal or family interests and those of OneMark — including holdings in competing, partner, or supplier companies; close personal relationships with counterparties in material transactions; and business opportunities discovered in the course of their function at the company. Failure to report is, in itself, a violation of the Code.

Anti-Money Laundering and Counter-Terrorist Financing. OneMark verifies the origin of the funds it receives and the identity of its counterparties — particularly in real estate transactions, where the sector is especially exposed. The company complies in full with Portuguese and European legislation on the prevention of money laundering and terrorist financing, maintains up-to-date Know Your Customer (KYC) procedures, and refuses any transaction whose origin it cannot validate.

International Sanctions. The company does not conduct business — directly or indirectly — with persons, companies, or entities subject to sanctions by the European Union, the United Nations, the United Kingdom, or the United States of America.

IV. People

Equal Opportunity and Non-Discrimination. OneMark is an equal opportunity employer. It does not discriminate, in recruitment, promotion, compensation, or any other aspect of the employment relationship, on the basis of gender, age, race, ethnicity, nationality, sexual orientation, gender identity, religion, political belief, disability, marital status, or family condition.

Anti-Harassment. The company does not tolerate moral or sexual harassment in any of its forms. It maintains specific procedures for the receipt, investigation, and handling of complaints in this matter, in line with the provisions of Portuguese labor legislation.

Workplace Health and Safety. OneMark provides safe and healthy working conditions to all its employees, and requires the same standards to be met by its service providers, particularly on construction sites. Every workplace incident is investigated, and lessons are drawn from it for the entire company.

Training and Development. The company invests in the ongoing training of its employees and seeks to create the conditions for each person to grow professionally within the organization.

Work-Life Balance. OneMark recognizes that the individual sustainability of its employees depends on a reasonable balance between working time and personal life. The company strives, wherever possible, to organize professional demands in a manner compatible with this principle.

V. Clients and Suppliers

Client Relationship. OneMark treats each client with the attention and transparency it would itself wish to receive. The company does not promise what it cannot deliver, communicates honestly any changes that affect the contracted product, and maintains open channels of communication throughout the relationship — before, during, and after the sale. Complaints are addressed in a reasonable timeframe and with seriousness.

Advertising and Commercial Materials. All commercial communication by OneMark — brochures, advertisements, digital content, press materials — faithfully reflects the characteristics of its projects. The company does not use images, descriptions, or data that may mislead the client.

Supplier Selection. OneMark selects its suppliers based on objective criteria of technical competence, quality, reliability, commercial terms, and ethical alignment. Wherever possible, it favors suppliers who share the principles of this Code.

Payments to Suppliers. The company honors the payment terms agreed with its suppliers. It does not use its negotiating power to impose unreasonable terms on smaller suppliers, nor does it delay payments as an instrument of pressure.

VI. Community and Environment

Integration into the Community. OneMark recognizes that each of its projects intervenes in a pre-existing urban and social fabric. The company seeks to understand that fabric before intervening, engages with the local community where relevant, and considers the impact of construction on the daily life of those who live or work in the vicinity.

Built Heritage. The company treats architectural heritage — whether listed or not — with the care it is due. It favors rehabilitation approaches over demolition where both are technically feasible, and collaborates with the competent heritage authorities.

Environment and Sustainability. OneMark integrates environmental sustainability into project decisions, into the selection of materials and technologies, and into the management of its construction sites — energy efficiency, waste management, indoor air quality, emissions reduction, and reduction of water footprint. This integration is led by the company's Scientific Advisor and follows the state of the art in sustainable engineering.

Culture and Art. The company understands architecture and editorial and artistic curation as dimensions of the common good, and not merely as elements of commercial valorization of its projects. Each development integrates art and editorial programs with independent curation, managed by OneMark's editorial and curation direction.

VII. Information and Security

Confidentiality. Employees and partners of OneMark maintain strict confidentiality regarding the company's affairs — particularly concerning clients, suppliers, ongoing projects, negotiations, financial data, and any information whose disclosure could harm the company or third parties.

Personal Data Protection. The company complies with the General Data Protection Regulation (GDPR) and applicable national legislation. It processes the personal data it collects — from clients, employees, suppliers, or other third parties — for declared purposes, on an appropriate legal basis, for a proportionate retention period, and with due security measures. Data subjects may exercise their rights of access, rectification, erasure, objection, and portability under the terms provided in the GDPR.

Cybersecurity. OneMark maintains technical and organizational measures appropriate to the protection of its information systems and the data they handle. Employees are trained in basic information-security practices and in the detection of fraud, social engineering, and cyber-attack attempts.

Use of Artificial Intelligence. When the company uses artificial intelligence systems — for document analysis, contract management, information processing, or other purposes — it does so under human supervision, validates the results before basing final decisions on them, and complies with the applicable European regulatory framework.

VIII. Communication and Public Representation

Employees who communicate publicly on behalf of OneMark do so with the factual consistency, institutional tone, and care appropriate to the company's reputation. Employees who communicate in a personal capacity — including on social media — clearly distinguish their personal opinions from the official positions of OneMark, and respect the confidentiality of the company's affairs.

OneMark does not constrain the legitimate personal expression of its employees. The company reserves, however, the right to request reflection and adjustment where personal communications may harm the company, third parties, or trust among colleagues.

IX. Whistleblower Channel and Handling of Violations

Duty to Report. Any person who has knowledge or well-founded suspicion of a violation of this Code — employee, director, supplier, client, or third party — has the moral duty, and in some cases the legal duty, to report it to the company.

Whistleblower Channel. OneMark maintains an internal whistleblower channel, accessible by email at etica@onemark.pt or by letter addressed to the company's Ethics Committee, in a sealed envelope, sent to the Lisbon headquarters. The channel is available for internal and external complaints and may be used on an identified or anonymous basis.

Whistleblower Protection. OneMark complies in full with Portugal's Whistleblower Protection Act (Law No. 93/2021), guaranteeing the confidentiality of the whistleblower's identity, the absence of direct or indirect retaliation, and protection against any form of reprisal — including dismissal, disciplinary sanction, change of duties, reduction in compensation, or professional detriment. These guarantees extend to those who assist the whistleblower.

Handling of Complaints. Complaints received are handled by an Ethics Committee independent of operational hierarchy, composed of two non-executive directors and one independent external member. Complaints are addressed within a reasonable timeframe — as a rule, initial assessment within fifteen working days and final decision within ninety days — and the conclusions are communicated to the whistleblower, while preserving the confidentiality of third parties.

Bad-Faith Complaints. Manifestly false complaints, filed with persecutory intent or in violation of the rights of third parties, may give rise to disciplinary proceedings against those who filed them. This rule does not apply to good-faith complaints that turn out to be unfounded — those are fully protected.

X. Consequences of Non-Compliance

Violation of this Code by employees or directors is subject to internal disciplinary proceedings and may give rise to sanctions proportional to the gravity of the infraction, including, in the most serious cases, termination of the employment contract for cause, under applicable law.

Violation by suppliers or service providers is subject to the applicable contractual mechanisms, including the possibility of contract termination.

OneMark cooperates fully with the competent public authorities in the investigation of any facts that may constitute a criminal offense or administrative violation.

XI. Effective Date, Review, and Governance of the Code

This Code enters into force on the date of its approval by the management of OneMark Properties and is subject to regular review, at minimum every three years or whenever relevant circumstances justify it — legislative changes, new market practices, new areas of activity, or lessons drawn from concrete cases.

The updated version of the Code is at all times available on the company's website and is delivered to all employees at the beginning of the employment relationship. The management of OneMark Properties bears ultimate responsibility for the enforcement of the Code and for the coherence between its content and the actual practice of the company.

Mark One Properties — Asset Management, Lda.

Lisbon · May 2026