Our Core Principles

The Company’s investment activities are guided by the following core principles:

Integrity. We conduct all investment activities with honesty, fairness, and transparency. We do not engage in deceptive, manipulative, or fraudulent practices in connection with the sourcing, evaluation, or management of any investment.

Responsibility. We recognize that our investment decisions have consequences beyond financial returns. We take responsibility for the environmental, social, and governance (“ESG”) impact of our portfolio and seek to allocate capital in a manner that contributes positively to society.

Accountability. We hold ourselves accountable to our investors, partners, and other stakeholders for the ethical standards reflected in this Code. We regularly review and assess our compliance with this Code and are committed to continuous improvement.

Transparency. We are committed to clear and honest communication regarding our investment practices, screening criteria, and portfolio composition. We believe that transparency fosters trust and enables our stakeholders to make informed decisions.

Political Neutrality. The Company does not take into account political opinions, affiliations, or ideologies in its investment activities. Investment decisions are made without regard to the political views or activities of the Company’s management, shareholders, or the management or stakeholders of prospective or existing portfolio companies. The Company’s investment process is driven solely by business, financial, technological and other due diligence considerations as set forth in this Code.

Proudly Israeli. We are proud Israelis. Our identity and values are rooted in Israel, and we seek to contribute meaningfully to Israel’s economy, innovation ecosystem, and society. Accordingly, as part of our investment strategy, we generally prioritize investments in companies and entrepreneurs with a meaningful connection to Israel, including Israeli-founded, Israeli-led, or Israel-based businesses, and initiatives that support Israeli innovation and talent.

Ethical Investment Screens

The Company applies a rigorous set of ethical screens to all prospective and existing investments. These screens are designed to ensure that the Company’s capital is not deployed in industries, sectors, or enterprises that conflict with our ethical values. The Company’s ethical investment screens are

organized into two categories: negative screens (exclusionary criteria) and positive screens (affirmative criteria).

Negative Screens (Exclusionary Criteria)

The Company will not knowingly invest in any company, fund, project, or other enterprise that derives a material portion of its revenue from, or is materially involved in, any of the following activities:

Tobacco and Nicotine Products. The production, marketing, or distribution of tobacco products, e-cigarettes, vaping devices and related technology, or other nicotine delivery systems.

Gambling. The operation of casinos, online gambling platforms, sports betting services, or other gambling enterprises, excluding investments in companies for which gambling revenue constitutes a de minimis portion of total revenue.

Adult Entertainment. The production or distribution of pornographic or adult entertainment content.

Predatory Lending and Financial Practices. The provision of payday loans, subprime lending products, or other financial products and services that are designed to exploit vulnerable consumers or that carry unconscionable terms.

Human Rights Violations. Any company or enterprise that has been credibly linked to forced labor, child labor, human trafficking, or other serious violations of internationally recognized human rights standards, including the principles set forth in the United Nations Universal Declaration of Human Rights.

Environmental Destruction. Any company or enterprise that engages in illegal deforestation, illegal dumping of hazardous waste, or other activities that cause severe and irreversible environmental harm.

Corruption and Bribery. Any company or enterprise that has been convicted of, or is under active investigation for, material violations of applicable anti-corruption or anti-bribery laws, including pursuant to the Israeli Criminal Code or the U.S. Foreign Corrupt Practices Act.

Positive Screens (Affirmative Criteria)

In addition to the exclusionary criteria set forth above, the Company actively seeks investment opportunities that demonstrate one or more of the following positive attributes:

Environmental Sustainability. Companies that develop, deploy, or promote renewable energy, clean technology, sustainable agriculture, water conservation, waste reduction, or other environmentally beneficial products, services, or practices.

Social Impact. Companies that contribute to improved health outcomes, expanded access to education, affordable housing, financial inclusion, or other measurable social benefits, particularly for underserved or marginalized communities.

Strong Governance. Companies that maintain robust corporate governance practices, including independent board oversight, transparent executive compensation practices, shareholder rights protections, and comprehensive anti-corruption and compliance programs.

Company Screening and Due Diligence

Before making any investment, the Company conducts a thorough due diligence process to evaluate the prospective investment against both financial and ethical criteria. The Company’s screening and due diligence process includes the following components:

Initial Screening. All prospective investments are subjected to an initial screening against the Company’s negative screens. Any investment that fails to meet the exclusionary criteria set forth above is removed from further consideration, unless the Company’s Investment Committee determines that exceptional circumstances warrant further review.

Reputational Risk Review. The Company conducts a reputational risk review of all prospective investments, including a review of publicly available information, media reports, regulatory filings, litigation history, and any allegations of misconduct or unethical behavior.

Beneficial Ownership and Sanctions Review. Before making an initial direct investment, the Company conducts appropriate know-your-customer and beneficial ownership reviews as reasonably necessary to ensure that the prospective investment does not involve sanctioned persons, entities, or jurisdictions. The Company screens all prospective investment targets against applicable sanctions lists maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the European Union, as applicable.

Ongoing Monitoring. After an initial investment is made, the Company may, in its discretion, consider ethical, legal, regulatory or sanctions-related issues in connection with follow-on investment decisions and periodic reviews of its existing portfolio companies. If the Company becomes aware that a portfolio company may be in material violation of the principles set forth in this Code, the Company may take such action as it deems appropriate under the circumstances.

Investment Cleanliness Standards

The Company is committed to ensuring that the terms and structure of each investment are fair, transparent, and consistent with sound ethical practices. The following standards apply to all investments made by or on behalf of the Company:

Fair Dealing. The Company negotiates all investment terms in good faith and on an arm’s-length basis. The Company does not seek to obtain unfair advantages through manipulation, concealment, misrepresentation, or any other unfair dealing practice.

Transparent Terms. All material terms and conditions of an investment are clearly documented in writing. The Company does not rely on undisclosed side letters, hidden fee arrangements, or other mechanisms that obscure the true economics or governance structure of an investment.

Conflicts of Interest. The Company maintains a comprehensive conflicts of interest policy and requires all personnel involved in investment decisions to disclose any actual or potential conflicts of interest. Where conflicts cannot be avoided, the Company implements appropriate safeguards, including recusal from decision-making, independent review, or enhanced disclosure.

Tax Compliance. The Company conducts its investment activities in compliance with all applicable tax laws and regulations. The Company does not engage in aggressive tax avoidance schemes that, while potentially legal, are inconsistent with the spirit and intent of the applicable tax law or that rely on arrangements lacking genuine economic substance.

Responsible Exit Practices. When divesting from a portfolio company, the Company considers the impact of the divestment on the portfolio company’s employees, customers, and communities. The Company endeavors to conduct exits in a manner that minimizes unnecessary disruption and harm.

Governance and Oversight

The Company’s investment decisions are made by an Investment Committee (the “Investment Committee”) comprised of seasoned professionals with relevant industry expertise and experience. The Investment Committee evaluates all prospective and existing investments based solely on business, financial, technological, and other due diligence criteria, as informed by the ethical screens and standards set forth in this Code. The Company’s shareholders, in their capacity as such, are not part of the investment process and do not partake in any investment decision-making. Shareholders do not direct, influence, or participate in the evaluation, selection, management, or disposition of any investment.

Reporting Concerns

The Company encourages any director, officer, employee, agent, or external stakeholder who becomes aware of a potential violation of this Code to report the concern promptly. The Company prohibits retaliation against any individual who makes a good-faith report of a potential violation of this Code.

Amendments and Waivers

This Code may be amended from time to time by the Company’s Board of Directors, upon the recommendation of the Investment Committee. Any waiver of the provisions of this Code must be approved by the Investment Committee and, where required, by the Board of Directors, and will be disclosed in accordance with applicable law and the Company’s governance policies.

Disclaimer

This Code reflects the Company’s current ethical investment principles and practices as of the date set forth above. While the Company is committed to adhering to the standards described herein, this Code does not create any legally binding obligations on the part of the Company to any third party, nor does it constitute investment advice or an offer or solicitation to purchase or sell any security or investment product. The Company reserves the right to modify or update this Code at any time.