The Sports Gaming Global Ventures, LLC Code of Business Conduct (“Code”) embodies the core values of Sports Gaming Global Ventures, LLC Gaming, Inc. (“Sports Gaming Global Ventures, LLC,” the “Company,” “we,” “us,” “our,” or “ours”). This Code ensures that everything we do is held to the highest standards of ethical business conduct. We set these high standards not just for practical reasons but also to inspire excellence. Upholding these standards helps us attract and retain top talent, deliver exceptional fan engagement solutions, and foster loyalty among customers and business partners. Respect for our users, opportunities, and one another is crucial to our success and something we must uphold daily.

Please familiarize yourself with Sports Gaming Global Ventures, LLC’s Code of Business Conduct and our values. Follow them both in spirit and letter, always remembering that each of us has a personal responsibility to incorporate these principles into our work. If you have any questions or believe that a colleague or the Company may not be meeting these commitments, please speak up. Your input is vital.

Who Must Follow Our Code?

We expect all our employees and Board members to understand and adhere to the Business Code. Any failure to comply can lead to disciplinary actions, including termination of employment. Although the Business Code is specifically written for Sports Gaming Global Ventures, LLC employees and Board members, we also require our extended workforce—such as independent contractors, consultants, vendors, and temporary staff—and others temporarily assigned to perform work for Sports Gaming Global Ventures, LLC to follow the Business Code. Non-compliance by any member of our extended workforce or other covered service provider may result in the termination of their relationship with Sports Gaming Global Ventures, LLC.

What If I Have a Code-Related Question or Concern?

If you have a question or concern, take action. You can submit a question or raise a concern regarding a suspected violation of our Code or any Sports Gaming Global Ventures, LLC policy by contacting your manager or our compliance officer and Chief Financial Officer. Should you believe a violation of law has occurred, you can also report it through the compliance officer or directly to a government agency.

For misconduct concerns about the CEO or a direct report to the CEO, you may notify the Audit Committee of Sports Gaming Global Ventures, LLC’s Board of Directors. To notify the Audit Committee, please mail your concern to:

Sports Gaming Global Ventures, LLC

Attention: Workplace Concern

304 S Jones Blvd #4336

Las Vegas, Nevada 89107

You can report your concerns to the Audit Committee anonymously. However, the Audit Committee encourages you to provide your name and contact information so they can reach out to you directly if needed.

No Retaliation

Sports Gaming Global Ventures, LLC strictly prohibits retaliation against any employee who reports or participates in an investigation of a potential violation of our Business Code, policies, or laws. If you believe you are experiencing retaliation, please promptly contact and inform our Audit Committee.

Serve Our Users

Our customers and business partners (collectively, our “users”) value Sports Gaming Global Ventures, LLC not only for our exceptional products and services but also because we maintain the highest standards in our interactions and operations. By adhering to the following principles, we can continue to uphold this high standard:

Integrity

Our reputation as a trusted company is our most valued asset. It is everyone’s responsibility to ensure that we continually earn and maintain this trust. All communications and interactions with our users should reinforce their trust in us.

Usefulness

Our products and services should enhance the utility of Sports Gaming Global Ventures, LLC for all our users. Whether serving individuals or large businesses, we must always ask ourselves: “Is what we are offering useful?”

Privacy, Security, and Freedom of Expression

We ask our users to trust us with their personal information, and it is critical that we honor and protect that trust. This means respecting and safeguarding the privacy and security of their data. Our security procedures strictly limit access to and use of users’ personal information, and everyone must take necessary measures to prevent unauthorized access. Be aware of your responsibilities under these procedures and handle user information in compliance with our privacy policies and applicable data protection laws.

By keeping these principles in mind, we can ensure that Sports Gaming Global Ventures, LLC continues to be a company that our users can rely on and trust.

Sports Gaming Global Ventures, LLC is dedicated to promoting privacy and freedom of expression for our users globally. In situations where these rights face government challenges, we strive to apply internationally recognized standards that respect these rights. This commitment guides us as we develop products, conduct business in diverse markets, and handle government requests to access user information or remove user content. If you have any questions about implementing these standards in your role, please reach out to Sports Gaming Global Ventures, LLC’s compliance officer.

Responsiveness

Being useful and honest means being responsive. We acknowledge relevant user feedback when we see it and act. We take pride in addressing communications from our users, whether they have questions, encounter problems, or offer compliments. If something is broken, we make sure to fix it promptly.

Act

If you ever feel that our users are not being well served, speak up. Let someone in the Company know about it. Improving our products and services is a collective effort, and we take pride in championing our users. We are proactive in stepping forward when our users’ interests are at stake.

Support and Respect Each Other

Our principles

At Sports Gaming Global Ventures, LLC, we share an unwavering commitment to prohibiting and effectively addressing harassment, discrimination, misconduct, abusive conduct, and retaliation. To uphold this commitment, Sports Gaming Global Ventures, LLC adheres to the following Guiding Principles:

Commitment

Sports Gaming Global Ventures, LLC establishes a top-down commitment to fostering a respectful, safe, and inclusive working environment for all employees and members of our extended workforce.

Care

Sports Gaming Global Ventures, LLC fosters an environment that emphasizes respect for everyone across all levels of our organization. This includes aiding and showing empathy to employees and members of our extended workforce throughout and after the complaint process.

Transparency

Sports Gaming Global Ventures, LLC maintains a policy of openness and transparency concerning the frequency of complaints related to harassment, discrimination, misconduct, abusive conduct, and retaliation. The Company is committed to being clear about its approach to investigating and addressing these allegations.

Fairness and Consistency

Sports Gaming Global Ventures, LLC is committed to treating all individuals with respect, fairness, and compassion in every interaction. Our policies, procedures, and outcomes are applied consistently, regardless of who is involved.

Accountability

Sports Gaming Global Ventures, LLC holds each individual accountable for their actions and ensures that, when necessary, those individuals also hold others accountable.

Our Practice

Aligned with our Principles, Sports Gaming Global Ventures, LLC expects its employees and extended workforce to make every effort to foster a supportive work environment. This environment should enable everyone to reach their fullest potential and be free from harassment, intimidation, bias, and unlawful discrimination.

Equal Opportunity Employment

Employment at Sports Gaming Global Ventures, LLC is determined solely by individual merit and qualifications directly related to professional competence. We strictly prohibit any form of unlawful discrimination or harassment based on race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. Additionally, we make all reasonable accommodations to fulfill our obligations under laws protecting the rights of individuals with disabilities.

Harassment, Discrimination, and Bullying

Sports Gaming Global Ventures, LLC strictly prohibits discrimination, harassment, and bullying in any form—whether verbal, physical, or visual. If you believe you have been subjected to bullying, harassment, or discrimination by anyone at Sports Gaming Global Ventures, LLC, or by one of our partners or vendors, we strongly encourage you to report the incident to your manager immediately. Managers who become aware of such incidents should promptly report them to the Compliance Officer, who will thoroughly investigate any complaints and take appropriate action.

Drugs and Alcohol

Our stance on substance abuse is clear: It is incompatible with the health and safety of our employees, and we do not permit it. While alcohol consumption is not banned at our offices, it is important to use good judgment. Never drink in a way that impairs performance, leads to inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs are strictly prohibited in our offices and at sponsored events. If a manager has reasonable suspicion that an employee’s use of drugs or alcohol may negatively impact job performance or workplace safety, the manager may request an alcohol and/or drug screening. Reasonable suspicion can be based on objective symptoms such as the employee’s appearance, behavior, or speech.

Safe and Healthy Workplace

                We are dedicated to maintaining a safe, healthy, and violence-free work environment. Any behavior that endangers the safety, health, or security of our employees, extended workforce, or visitors is strictly prohibited. If you become aware of such a risk, report it to your manager immediately. In the event of a life-threatening situation or emergency, contact your local police, fire department, or other emergency responders first, then inform your manager or the Compliance Officer.

Avoid Conflicts of Interest

When you find yourself in a situation where competing loyalties might lead you to seek a personal benefit for yourself, your friends, or your family at the expense of Sports Gaming Global Ventures, LLC or our users, you could be facing a conflict of interest. It is essential for all of us to avoid conflicts of interest and situations that may reasonably arise as such. When deciding on a course of action, consider whether it could create an incentive for you, or seem to others like it might, to benefit yourself, your friends or family, or an associated business at the expense of Sports Gaming Global Ventures, LLC. If the answer is “yes,” you should avoid that action to prevent a conflict of interest.

Environmental Responsibility

We are dedicated to operating and providing products and services in an environmentally responsible and sustainable manner. We adhere to all applicable environmental laws and regulations. We strive to follow best practices and minimize our environmental impact in ways that are relevant to our business and meaningful to the communities we serve.

Community Support

We engage in activities that enhance our communities as places to live, work, and grow. We strengthen our communities by providing good jobs, volunteering our time and talents, supporting underserved populations, and promoting educational programs that foster economic opportunities.

Integrity of Financial Records and Public Disclosure

Our financial records are fundamental to managing our business and fulfilling our responsibilities to shareholders, employees, and other stakeholders. Maintaining the integrity of these records is crucial for complying with accounting, tax, public disclosure laws, and other regulatory requirements.

We are dedicated to maintaining accurate and complete financial records and ensuring full, fair, accurate, timely, and understandable disclosure in reports and documents filed with the U.S. Securities and Exchange Commission and other regulatory bodies, as well as those made publicly available. Each of us is responsible for recording clear, accurate, and honest information in all Company records we produce, including expense reports, financial statements, and public disclosure documents. If you have concerns about questionable accounting or audit matters, immediately contact our Compliance Offices or Audit Committee. You may submit concerns anonymously where permitted by law. It is crucial for the Company to be informed about possible accounting or audit issues so they can be promptly investigated. When in doubt, speak up. The Company does not tolerate any acts of retaliation for good faith reports of accounting or audit concerns.

Insider Trading

During business, you may come across confidential information about the Company or other publicly traded companies that is not available to the public. Do not share material nonpublic information with anyone, including coworkers (unless it is essential for Company-related business), friends, or family. Buying or selling the stock of a publicly traded company while aware of material nonpublic information or sharing such information with others who then buy or sell the stock (“tipping”), is prohibited by various laws. Even casual conversations could be considered illegal “tipping” of inside information.

Material information is any information that a reasonable investor would consider when deciding whether to buy, sell, or hold a stock. Examples of material information about a company include:

  • Acquisitions, joint ventures, and other major transactions
  • The gain or loss of a significant distributor or the renewal of a significant distribution agreement
  • Development of a significant new program or product
  • A significant expansion or reduction in operations
  • Changes in strategic direction, such as entering new markets
  • Senior personnel or management changes
  • A major lawsuit

Certain employees may be subject to blackout periods during which they are prohibited from buying or selling Company stock. If a blackout restriction applies to you, you will be notified. For more details, please refer to Sports Gaming Global Ventures, LLC’s Insider Trading Policy.

Misuse of Funds and Fraud

We are each personally responsible for safeguarding Sports Gaming Global Ventures, LLC’s assets and ensuring that Company resources are used responsibly and appropriately. Do not use Company resources for activities such as fraud, theft, embezzlement, misappropriation, money laundering, tax evasion, or any other actions that violate laws and regulations. Such activities undermine our integrity, damage our reputation, and expose both the Company and individuals involved to severe penalties. Additionally, use facilities, materials, and equipment solely for authorized purposes related to your job, and report any suspicious financial transactions or activities to your manager, our Compliance Officer, or the Audit Committee.

Anti-Bribery & Anti-Corruption

Sports Gaming Global Ventures, LLC is fully committed to complying with all applicable anti-corruption laws. We have a zero-tolerance policy against giving, offering, authorizing, or accepting bribes in any form. This prohibition extends to bribery of both private individuals and government officials. Such actions are not only unethical and illegal but also strictly forbidden.

The laws of the U.S. and many other countries explicitly prohibit making corrupt payments or offering bribes to government officials to secure a business advantage. Violations of these laws carry severe consequences for both the Company and any employee found in breach. The Company can also be held accountable for the actions of its business partners acting on its behalf, including agents, consultants, partners, joint ventures, and other entities with which the Company has an ownership interest. Therefore, it is crucial to choose and monitor third parties diligently and ensure they act in accordance with these standards. Never request someone to perform an action that you are prohibited from doing yourself.

Fair Competition

Sports Gaming Global Ventures, LLC is committed to free and open competition. We avoid any improper practices that might limit competition or seek competitive advantages through unethical or illegal means.

  • Avoid discussing: hiring or soliciting new employees, setting prices, bidding for rights, negotiating with partners in common, or dividing up customers, suppliers, or markets with competitors.
  • Focus on competition: Compete aggressively to provide the best products and services at the best prices, without aiming solely to drive competitors out of business.

Be cautious and report any of the following activities if you see or suspect them:

  1. Sharing our Company’s competitively sensitive information, or that of our partners or other third parties, with a competitor.
  2. Obtaining or attempting to obtain nonpublic information about competitors, including from new hires or candidates for employment.
  3. Accepting information about competitors without being certain if it is protected by a confidentiality agreement, policy, or as a trade secret.

Communicating with the Public

Sports Gaming Global Ventures, LLC is dedicated to maintaining honest, professional, and lawful internal and public communications. We recognize the importance of a consistent voice when issuing statements about the Company or providing information to the public. Therefore, only authorized individuals are permitted to speak on behalf of Sports Gaming Global Ventures, LLC to media personnel, investors, stock analysts, and other members of the financial community.

As a public company, we are committed to full, fair, and timely disclosure in all reports and documents describing our business, financial results, and other public communications. Please keep the following in mind:

  • Do not speak publicly (e.g., on a panel) about the Company or write articles about your work at Sports Gaming Global Ventures, LLC for professional journals without prior approval from the Chief Executive Officer or Compliance Officer.
  • Do not speak “off the record” to journalists or analysts seeking information about the Company or our business partners without prior approval from the Chief Executive Officer or Compliance Officer.

Political Activity

Sports Gaming Global Ventures, LLC’s employees and extended workforce have the right to voluntarily participate in the political process, including making personal political contributions and engaging in personal volunteer political activities. However, it is essential to always clarify that your personal views and actions do not represent those of Sports Gaming Global Ventures, LLC. Additionally, you must not use Company funds or resources for any political purpose without proper authorization.

Company Resources

Each of us relies on Sports Gaming Global Ventures, LLC’s resources to do our jobs, and we are personally responsible for safeguarding them and protecting them from theft, fraud, waste, and misuse. These resources include funds, facilities, equipment, networks, information systems (including email and voicemail), and supplies. Personal use of these resources is discouraged, but where permitted, should be kept to a minimum and have no adverse effect on productivity and the work environment.

  • Never use Company resources for activities that are improper or illegal.
  • Use your corporate credit card only for permitted purposes.
  • Be a good steward of our equipment, networks, and information systems.
  • Do not use them to create, store, or send pirated content or content that others might find offensive.
  • Do not share passwords or allow other people, including friends and family, to use them.
  • Be careful when clicking on hyperlinks or responding to requests from external or unknown third parties.
  • Do not leave devices storing Company information unattended, and do not access sensitive Company information when on an unsecured connection.

Conclusion

Sports Gaming Global Ventures, LLC strives to be a distinctive kind of company. While it’s impossible to anticipate every ethical scenario we might face, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Sports Gaming Global Ventures, LLC employees and members of our extended workforce to be guided by both the letter and the spirit of this Business Code.