CODE OF ETHICS

In executing their responsibilities for KIC Ventures ("KIC"), every member of the team is expected to uphold the utmost standards of integrity and ethical behavior in all interactions with colleagues, clients, vendors, and other external parties, including auditors and regulatory bodies.

It's crucial that team members avoid any real or perceived conflicts of interest between their personal interests and their professional obligations. In the event of a potential conflict of interest, it is mandatory for the individual to report the situation to their supervisor or any compliance officer without delay. All team members are also required to take necessary steps to safeguard the confidentiality of proprietary information about KIC Ventures.

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Any questions regarding the interpretation of this Code of Ethics, as well as any dealings with Healthcare Professionals (HCPs) not explicitly mentioned herein, should be approached with the core principle in mind: KIC Ventures is committed to ethical business practices and fostering socially responsible conduct. KIC employees and representatives are prohibited from engaging in any unlawful activities to promote, sell, or arrange for the sale of KIC's products and services. Furthermore, KIC Ventures has embraced the MedTech Code of Ethical Business Practice ("MedTech Code") as an integral part of its corporate policy. Thus, all employees and agents are obligated to adhere to the guidelines set forth in the MedTech Code.

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KIC Ventures' financial records and reports must be kept accurately and honestly, in compliance with all relevant laws and accepted accounting standards. The company's Corporate Compliance Program is designed to monitor, audit, and assess adherence to KIC's compliance policies and procedures. This includes overseeing the conduct of its sales team in the field. Moreover, every employee is expected to take appropriate measures to ensure compliance with all applicable laws, regulations, and rules, both within the United States and in international markets.