Kvanted Oy (“Kvanted”)

Updated: August 2026

PURPOSE AND APPLICABILITY

The purpose of Kvanted Oy (“Kvanted”) Code of Conduct (“the Code”) is to outline the key principles of ethical behavior expected from Kvanted’s employees, partners, and other individuals acting on behalf of Kvanted (“Kvanted Representatives”). The Code includes Kvanted’s standards of integrity and promotes just and equitable principles. It also provides a framework for addressing and resolving lapses in professional conduct. Cases of non-compliance are handled by Kvanted’s Board of Directors.

SCOPE

Each Kvanted Representative is personally responsible and accountable for adhering to the Code. Kvanted management is expected to model the importance of compliance through their own actions and provide guidance on interpreting the Code, as relevant. Compliance with the Code is expected in all relevant contexts related to Kvanted and representing Kvanted, including, for example, board work at Kvanted and at portfolio companies, office work, business trips, work events, social outings, social media, email and other communications. Kvanted provides guidance on the Code to new team members, as relevant.

Kvanted investment committee members, advisors, portfolio company founders, and other Kvanted stakeholders are encouraged to reflect on the same standards of integrity, fairness, and professionalism in all board and portfolio company work.

KVANTED VALUES

The Code is based on Kvanted’s core values:

• Cutting-edge: Our job is to take risks in a way that is bold and smart at the same time.

• Grounded: We meet every founder with an open mind. Our job is to encourage – to create a safe ground for taking risks, innovating and growing.

• Resolute: We do not fall in love easily. We talk to true believers and reluctant skeptics, and have a clear, honest conversation before taking resolute action.

PRINCIPLES OF PROFESSIONAL STANDARDS

Kvanted’s principles on professional standards should drive all decision-making, actions, and responsibilities:

• Act with integrity

• Disclose conflicts of interest

• Act with fairness

• Maintain confidentiality

• Do no harm to the ecosystem

KVANTED ATTITUDE

We show up with relentless optimism and ambition. We lead with empathy and demand high standards.

This is the shared attitude we expect everyone at Kvanted to bring to work and to represent in every interaction: high ambition, genuine care for the people around us, and the honesty to say when something falls short.

COMPLIANCE WITH LAWS AND INDUSTRY STANDARDS

Kvanted Representatives are expected to operate in compliance with applicable laws and regulations in all countries where we do business. We are committed to upholding and promoting industry standards through our active participation in relevant industry associations, including the Finnish Venture Capital Association (FVCA).

CONFLICT OF INTEREST

While we strive to avoid conflicts of interest, they may occasionally arise. In such situations, we ensure full disclosure to relevant parties, including Kvanted management. Kvanted Representatives are prohibited from engaging in external activities that could compromise their ability to perform their duties or undermine trust and confidence in Kvanted. They must also not misuse, or deal based on, inside or non-public information obtained through their work, and must comply with applicable market-abuse and insider-dealing rules.

SUSTAINABILITY COMMITMENTS

Kvanted promotes environmental, social and governance (ESG) characteristics by incorporating sustainability considerations into each investment phase, from sourcing and due diligence to the ownership period. Potential investments are screened against Kvanted’s exclusion list, including fossil fuels, weapons, tobacco, alcohol, gambling, and adult entertainment, as well as illegal activities. Kvanted’s disclosures related to Sustainable Finance Disclosure Regulation (“SFDR”) and sustainability strategy are set out in Kvanted’s Guidance for Sustainable Investment and Regulatory Disclosure.

Kvanted seeks to minimize its own environmental footprint and maintain a safe and healthy working environment. In its investment activities, Kvanted promotes climate action (SDG 13) and decent work including health and safety (SDG 8) as core sustainability themes, tracking carbon footprint, lost time accidents, and board gender diversity as annual indicators across the portfolio.

DIVERSITY, INCLUSION AND EQUAL TREATMENT

Kvanted is committed to building a diverse, equitable, and inclusive working environment where Kvanted representatives feel respected and able to contribute fully. We believe diversity of background, experience, and perspective strengthens decision-making and reflects the kind of ecosystem we seek to support. In practice, this means:

• Recruiting and evaluating candidates based on merit, competence, and potential, free from bias related to gender, age, ethnicity, nationality, sexual orientation, disability, or any other protected characteristic.

• Fostering an inclusive culture and periodically reviewing team composition with diversity in mind as the firm grows.

• In its investment activity, tracking the gender ratio of portfolio company board members as an annual sustainability indicator and encouraging portfolio companies to adopt inclusive hiring and governance practices.

In line with our commitment to safe and inclusive workplace, unacceptable behaviors include, but are not limited to:

• Discrimination: Any form of discrimination, comments, or slurs based on gender, age, sexual orientation, race, religious faith, marital status, pregnancy, gender identity or expression, disability, political affiliation, national or ethnic origin, or any other protected characteristic.

• Harassment: Any actions that violate a person’s dignity or involve degrading, humiliating, or offensive behavior, including unwelcome touching or flirting, bullying, sexually suggestive comments, or other insulting remarks.

• Other unacceptable behavior: Intentionally acting in a way that contradicts the spirit or the intent of the Code.

ANTI-BRIBERY AND ANTI-CORRUPTION

Kvanted prohibits bribery and corruption in any form. No employee, team member, or party acting on behalf of Kvanted may offer, give, request, or accept any bribe, kickback, or improper payment or benefit intended to influence a business decision or gain an unfair advantage.

Employees must not make facilitation payments of any kind. Gifts, entertainment, and hospitality must be reasonable, transparent, and never offered or accepted with the intent or expectation of influencing a business decision. Any concerns about potential bribery or corruption should be reported immediately via Kvanted’s whistleblowing channel or directly to management.

PRIVACY AND DATA SECURITY

We handle personal data in compliance with applicable data protection laws and regulations and are committed to maintaining high standards in data management and cybersecurity. Please refer to Kvanted’s Privacy Policy and IT, Cybersecurity & AI Policy for further details.

 WHISTLEBLOWING

Kvanted fosters an open and transparent culture where employees are encouraged to voice concerns to their manager or any relevant person within the organization. Accordingly, Kvanted has a whistleblowing channel that enables confidential and anonymous reporting of suspected misconduct, accessible via the company website. Kvanted’s whistleblowing arrangements are aligned with the EU Whistleblowing Directive (2019/1937) and the Finnish Whistleblower Protection Act (1171/2022). Both employees and external stakeholders may report violations or suspected breaches of laws, the Code, or internal policies. Retaliation against anyone who reports a concern is strictly prohibited. All reports are treated confidentially and undergo thorough review and remediation, as relevant.

MONITORING AND REVIEW

The Code and the process for addressing any misconduct is regularly reviewed by Kvanted’s management and Board of Directors. The Code is reviewed annually and updated as relevant to reflect material changes in Kvanted’s operations, regulatory requirements, or sustainability commitments.

REPORTING AND OVERSIGHT

Any concerns or breaches of the Code should be reported immediately to Kvanted management. All reported incidents will be thoroughly reviewed, and material concerns are escalated to the Board of Directors.  Cases are evaluated individually, and follow-up actions are determined on a case-by-case basis, which may include no action, a verbal or written warning, reassignment of responsibilities, termination, or actions involving third parties.

Maria Wasastjerna,

Managing Partner maria@kvanted.com

Jenni Suhonen,

Finance and Operations Manager jenni@kvanted.com

Kvanted Fund I Ky 4

Bulevardi 2-4 A

00120 Helsinki

www.kvanted.com