MDA Space — Governance Information 2024

Jun 26, 2024

Code of Ethics and Business Conduct

RESTRICTION ON USE, PUBLICATION, OR DISCLOSURE OF PROPRIETARY INFORMATION

This document contains information proprietary to MDA Space Ltd. ("MDA Space"), its subsidiaries, affiliates or to a third party to whom MDA Space may have a legal obligation to protect such information from unauthorized disclosure, transfer, export, use, reproduction or duplication. Any disclosure, transfer, export, use, reproduction or duplication of this document, or of any of the information or images contained herein, other than for the specific purpose for which it was disclosed is expressly prohibited, except as MDA Space or such appropriate third party may expressly agree to in writing.

MDA-HR-001 Rev. C
Page 1 of 8

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MDA SPACE

Code of Ethics and Business Conduct

Table of Contents

1. PURPOSE ... 3
2. SCOPE ... 3
3. POLICY ... 3
   3.1 We Always Act with Integrity ... 3
   3.1.1 Company Personnel Responsibilities Under the Code ... 3
   3.1.2 Manager's Additional Responsibilities ... 4
   3.1.3 We Make Ethical Decisions ... 4
   3.1.4 We Respect Human Rights ... 4
   3.2 We Always Act with Integrity in All Business Dealings ... 4
   3.2.1 Fair Dealing ... 4
   3.2.2 Prevention of Fraud ... 4
   3.3 We Comply with Laws and Regulations ... 5
   3.4 We Properly Use Company Resources ... 5
   3.4.1 We Protect Confidential Information ... 5
   3.5 We Avoid Conflicts of Interest and Disclose Potential Conflicts ... 6
   3.5.1 Conflicts of Interest ... 6
   3.5.2 Bribes and Kickbacks ... 6
   3.5.3 Business Courtesies, Gifts and Entertainment ... 6
   3.5.4 Outside Activities ... 7
   3.5.5 Corporate Opportunities ... 7
   3.6 We Ensure Integrity in our Books and Records ... 7
   3.7 We Promptly Report Violations and Acts of Misconduct ... 7
   3.8 We will Annually Acknowledge Our Commitment To the Code ... 8
   3.9 Waivers of the Code ... 8
   3.10 Amendments ... 8
4. COMPLIANCE ... 8

MDA-HR-001 Rev. C

Use or disclosure of information contained herein is subject to the restriction on the title/cover page

Printed copies are not controlled

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MDA SPACE

Code of Ethics and Business Conduct

1. PURPOSE

MDA Space Ltd. ("MDA Space") has adopted the Code of Ethics & Business Conduct (the "Code") in order to:

• Promote integrity and honest and ethical conduct, including the ethical handling of actual or potential conflicts of interest;
• Promote compliance with applicable governmental laws, rules and regulations;
• Promote the protection of MDA Space and its subsidiaries, affiliates, partnerships and ventures ("Company") assets, including corporate opportunities, intellectual property and confidential information;
• Promote fair dealing practices;
• Deter wrongdoing; and
• Ensure accountability for adherence to the Code.

MDA Space expects all Board members, directors, officers, employees (including full-time, part-time, temporary and student employees), contractors, agents, and consultants of MDA Space and its subsidiaries (collectively, "Company Personnel") to operate with high standards of integrity by conducting Company affairs honestly and ethically. The purpose of this Code is to guide Company Personnel on how to carry out their duties in an honest and ethical manner.

2. SCOPE

The Code applies to all Company Personnel of the Company. All officers and managers of the Company are responsible for communicating and implementing the Code within their specific areas of responsibility.

3. POLICY

3.1 We Always Act with Integrity

It is the responsibility of all Company Personnel to ensure that their behaviour and activity is consistent with the Code, Company policies, and all applicable federal, provincial, and local laws and regulations. All Company Personnel must have confidence that they can freely report concerns about compliance with or violations of legal or ethical standards, whether or not based in the Code. All Company Personnel must have confidence that their concerns will be reviewed by MDA Space General Counsel and objectively investigated by the appropriate internal department and/or outside specialists, if necessary, with appropriate individual and remedial action, and without fear or favour.

The Code contains information, resources and support necessary to help us each fulfill our obligation to act honestly, with integrity and in compliance at all times with the law, regulations, and policies that affect our business.

3.1.1 Company Personnel Responsibilities Under the Code

All Company Personnel, regardless of location, are expected to:

• Be familiar with this Code and follow its requirements at all times;
• Comply with all applicable governmental laws, rules and regulations when engaging in any activity on behalf of the Company;
• Be aware of and avoid any situation that could lead to inappropriate business conduct or even the appearance of inappropriate conduct;
• Comply with all Company policies and agreements; and

MDA-HR-001 Rev. C

Use or disclosure of information contained herein is subject to the restriction on the title/cover page

Printed copies are not controlled

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MDA SPACE

Code of Ethics and Business Conduct

• At all times conduct Company business with the highest standards of ethics and integrity.

3.1.2 Manager's Additional Responsibilities

As leaders, managers take on an added level of responsibility. Our managers are expected to create and maintain a comfortable, open work environment where everyone is safe to voice their opinions and concerns. Managers are also responsible for promptly escalating reports of suspected violations of the Code and other Company policies to the Legal or Human Resources Departments.

3.1.3 We Make Ethical Decisions

All Company Personnel have a personal responsibility to act ethically and comply with the law, the Code, and Company policies and procedures at all times, which will guide Company Personnel in ethical decision-making. We recognize that not all ethical dilemmas are easy to resolve, and it is impossible to address in this Code every situation that could possibly arise. Most situations, however, can be resolved by common sense and good judgment. Where difficult situations arise that do not have a clear resolution, Company Personnel should ask a manager or supervisor, a Company leader, or the Human Resources or Legal Departments.

3.1.4 We Respect Human Rights

The Company is committed to providing a workplace free of harassment, violence and discrimination. All Company Personnel are expected to foster a respectful work environment that adheres to the requirements of applicable human rights law and related workplace legislation, as well as the Company's policies and guidelines with respect to human rights, harassment, sexual harassment and violence in the workplace, and occupational health and safety. The Company will not tolerate acts of discrimination based on age, ancestry, colour, race, citizenship, ethnic origin, creed, disability, family status, marital status, gender, sex, sexual orientation or any other ground of discrimination protected by law.

Every Company Personnel holding leadership responsibilities shall treat all other Company Personnel in a fair and equal manner and shall not allow any personal relationship to compromise this principle.

3.2 We Always Act with Integrity in All Business Dealings

At MDA Space, we frequently collaborate with our government and commercial business partners in various aspects of our operations. We earn their trust and business through the same hard work and integrity we apply to all our relationships and activities. We never seek to gain advantages through unfair, unethical or illegal business practices.

3.2.1 Fair Dealing

All Company Personnel must deal fairly with MDA Space's customers, suppliers, competitors, employees, and anyone else with whom they have contact within the course of performing the duties of their job. No Company Personnel may take unfair advantage of anyone through manipulation, concealment, abuse, or privileged information, misrepresentation of facts or any other unfair dealing practice.

3.2.2 Prevention of Fraud

All Company Personnel must prevent fraud. Fraud is an intentional deception, falsification, or misrepresentation made for personal gain, or to damage or create loss for MDA Space, its customers, suppliers or Company Personnel. This can include the misuse or misapplication of MDA Space's resources or assets to conduct internal fraud. As Company Personnel, we will not engage, directly or indirectly, in account falsification, false claims, time fraud or any other fraudulent business practice. Fraudulent actions are not only unethical, but are also a violation of applicable law in the jurisdictions in which the Company operates.

MDA-HR-001 Rev. C

Use or disclosure of information contained herein is subject to the restriction on the title/cover page

Printed copies are not controlled

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MDA SPACE

Code of Ethics and Business Conduct

3.3 We Comply with Laws and Regulations

All Company Personnel must comply, both in letter and spirit, with all applicable laws, rules and regulations in the jurisdictions in which the Company operates. MDA Space will not condone the activities of any Company Personnel who violates the law or engages in unethical business practices, even if those activities yield results. No activity may be carried on that will not stand the closest possible public scrutiny. All Company Personnel are responsible for understanding the applicable rules, and must work with their supervisor, who will then work with the Legal Department and/or Human Resources Department, to ensure compliance; ignorance of legal obligations is never an excuse or defence to misconduct.

Violations of the law can result in significant harm to the Company, including financial penalties, denial of government contracts, imprisonment for criminal misconduct, and damage to the Company's business relationships and reputation. Any questions about legal obligations or compliance should be directed to the Legal Department.

3.4 We Properly Use Company Resources

Proper and efficient use of Company resources, including our physical assets, systems, and intellectual property, is critical to Company operations and reputational integrity. All Company assets are to be used for Company business only, although incidental personal use is permitted. Company resources are not to be used for any personal benefit or the personal benefit of anyone else, or for an improper purpose (such as sharing messages that could be construed as harassment, discrimination or disparagement of others). Any suspected incident of fraud, theft or other irregularity should be reported immediately to your supervisor or the Legal Department.

Subject to applicable local law, the Company reserves the right to access, inspect, and disclose at any time, all aspects of those systems and networks, including, but not limited to, messages transmitted via its email, collaboration tools, cellular phones, text messages and/or voice mail system regardless of content. Where necessary to protect its employees, assets and business interests, the Company may request to search the personal property of Company Personnel located on or being removed from Company locations. Company Personnel are expected to cooperate with such requests.

3.4.1 We Protect Confidential Information

All Company Personnel share responsibility to safeguard the Company's confidential information, including proprietary information, intellectual property rights, and goodwill. We share confidential information only with authorized Company Personnel having a legitimate need to know or with third parties subject to prior approval and appropriate safeguards, such as non-disclosure agreements. To protect the Company from harm, and to maintain the value of our confidential information, it is critical that all Company Personnel follow Company policies and guidelines, and the terms and conditions of their employment-related agreements, with respect to confidential information. You should exercise particular care when using electronic technology (computer files, e-mail, and social media) and follow procedures and guidelines for the protection of Company information.

Computers and all portable media devices used to record business related information should be afforded a high level of security. Since the information stored in this way is not visible it is easy to forget that it is vulnerable. All storage, maintenance and backup procedures must be carefully followed. Use of free third party online storage sites to store or transmit business data is strictly prohibited, unless approved by the Company. Your obligation and legal responsibility to protect and not divulge MDA Space's confidential information continues even after you leave the Company's employment.

All inventions, trade secrets, patents, industrial designs, copyrights, manufacturing process innovations,

MDA-HR-001 Rev. C

Use or disclosure of information contained herein is subject to the restriction on the title/cover page

Printed copies are not controlled

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MDA
S P A C E
Code of Ethics and Business Conduct

management innovations and all other registered or unregistered intellectual property arising from employment or engagement with the Company, which are made or conceived in the course of your employment or engagement, are the exclusive property of MDA Space and in accordance with MDA Space’s Intellectual Property Policy. You assign and agree to assign (to the extent not automatically vesting in MDA Space as a matter of local law) any right, title and interest therein to MDA Space and waive any moral rights therein. Company Personnel have an obligation to maintain accurate records of, and promptly and fully disclose all such intellectual property when developed. Sharing or transferring of such intellectual property is prohibited without express written permission of MDA Space.

3.5 We Avoid Conflicts of Interest and Disclose Potential Conflicts

3.5.1 Conflicts of Interest

All Company Personnel have an obligations to act in the best interest of the Company. Company Personnel are expected to avoid any activity or situation that creates, or appears to create, a conflict between their personal interests and the interests of the Company. Business decisions must be based on the best interests of the Company, and cannot be motivated by personal desires or relationships.

Conflicts of interest can occur if your activities or interests influence, or appear to influence, your job performance or business decisions. Company Personnel are responsible for disclosing any material transaction or relationship that could reasonably be expected to give rise to a conflict of interest to their supervisor.

If there is any doubt as to whether a conflict of interest or a potential conflict of interest exists, or whether there may be an appearance of such a conflict of interest, you must consult with your supervisor or the Legal Department as soon as possible.

3.5.2 Bribes and Kickbacks

Company Personnel, and their respective family members, are prohibited from, whether directly or indirectly, offering, giving, soliciting or receiving any form of bribe or kickback, notwithstanding that they might further MDA Space’s business interests. If you or your family stand to gain personally though a Company transaction, this is prohibited, unethical, and may be illegal. The restrictions in this section apply to all Company business activities and operations around the world, even where such practices may be locally considered to be a way of "doing business" or necessary in a particular country in question.

In addition, Company Personnel must comply with the Corruption of Foreign Public Officials Act (Canada), the Bribery Act of the United Kingdom and The Foreign Corrupt Practices Act (U.S.) as well as local anti-corruption laws in the countries in which MDA Space operates (collectively, the "Anti-Corruption Laws"), in accordance with MDA Space’s Anti-Corruption Policy.

3.5.3 Business Courtesies, Gifts and Entertainment

Company Personnel or members of their family, are not permitted to give or receive gifts, payments or other business courtesies to or from potential or current customers, resellers, agents, consultants, distributors, vendors, or any other person with the intent to influence or appear to influence any business decision.

Giving and receiving gifts or entertainment can build strong working relationships and goodwill between the Company and those with whom we do business. Any such gifts or entertainment must be reasonable, infrequent, transparent, and not given or received in consideration or expectation of any action by the recipient. All business courtesies, gifts and entertainment (whether given or received) must be recorded accurately in our books and records. It is NEVER acceptable to give or receive cash.

MDA-HR-001 Rev. C
Use or disclosure of information contained herein is subject to the restriction on the title/cover page
Printed copies are not controlled

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MDA SPACE

Code of Ethics and Business Conduct

Any business courtesies, gifts or entertainment over $100 in value must be immediately reported to an employee’s supervisor or the Company’s Legal or Human Resources Department, who will determine whether such business courtesy, gift or entertainment may be accepted by the recipient.

3.5.4 Outside Activities

Outside employment, whether for another company or for yourself, can create a perceived conflict of interest. It is strongly discouraged at every level and will be prohibited under the following circumstances:

• If it interferes in any way with the performance of your duties.
• If it is connected in any way with a company that has any business relations with the Company.
• If it is a business competitor.
• If it calls upon the primary professional skills for which you are employed at the Company and could result in a potential or perceived conflict of interest.

Directorships are dealt with on a case-by-case basis. In certain circumstances, they can benefit both the employee and MDA Space. In others, they can be viewed as a conflict of interest or a hindrance to one’s primary duties. If you are at all unsure as to whether your outside employment or directorship violates the above rules, you should check with your supervisor and ensure that the conclusion is documented with the Legal Department.

MDA Space encourages employees to engage in volunteer community activities. However, these should be disclosed to your supervisor if they might appear to compete for your time and attention to your responsibilities.

3.5.5 Corporate Opportunities

Company Personnel are prohibited from taking for themselves personally opportunities that are discovered through the use of corporate property, information or positions and from using corporate property, information, or position for improper personal gain. No Company Personnel may compete with the Company directly or indirectly. Company Personnel owe a duty to the Company to advance its legitimate interests, before their own, when the opportunity to do so arises.

3.6 We Ensure Integrity in our Books and Records

MDA Space has established procedures for the maintenance of books, transactions, and records —good and bad—to ensure the integrity of MDA Space’s accounting and business records. All record-keeping documents, whether paper or electronic, are to be properly maintained to facilitate the preparation of accurate financial statements, asset management records. Everyone who makes business decisions is accountable for those decisions and is required to report the results promptly. The integrity of all records thus determines the quality of business decisions made by MDA Space and the health of the business. Any deviation from accounting or record-keeping procedures, whatever the motivation, is damaging to the interests of MDA Space and will be regarded as grounds for dismissal.

3.7 We Promptly Report Violations and Acts of Misconduct

If you have any reason to believe that a violation of this policy has occurred, please report those concerns either directly to your supervisor, manager or Human Resources Business Partner, or confidentially and anonymously through our independently administered, third party hotline service, as follows and provided by the Company’s Whistleblower Policy:

• By telephone: 1-866-771-6674 (Canada and USA) or 0330 808 4790 (UK)
• Online: http://www.clearviewconnects.com/

MDA-HR-001 Rev. C

Use or disclosure of information contained herein is subject to the restriction on the title/cover page

Printed copies are not controlled

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MDA
S P A C E
Code of Ethics and Business Conduct

• In writing: ClearView Connects
  P.O. Box 11017
  Toronto, Ontario
  M1E 1N0

Every report will be handled promptly, discreetly, and professionally. The Company does not tolerate acts of retaliation, including demotion, discharge, discipline, discrimination, harassment, suspension or threats, against any Company Personnel who makes a good faith report of a violation or perceived violation of this Code, or any other acts of misconduct.

3.8 We will Annually Acknowledge Our Commitment to the Code

After carefully reviewing this Code, you must sign the acknowledgement attached hereto at Annex I, indicating that you have received, read, understood, and agree to comply with the Code. The acknowledgement must be returned either electronically in a manner provided for by the Company within thirty (30) calendar days of your receipt of the Code, and otherwise as required by the Company. All Company Personnel are required to annually certify compliance with the Code. The failure to certify compliance, or any false certification, even if directed by a supervisor, is grounds for disciplinary action by the Company.

3.9 Waivers of the Code

Only the Board of Directors of any Committee of the Board may, in its discretion, waive any provision of this Code for a Board Member or an executive officer. Any waiver of the Code for a Board Member or an executive officer shall be promptly disclosed as required by law. For all other waivers of the Code, the General Counsel & Vice President Legal should be consulted.

3.10 Amendments

The Company reserves the right to, from time to time, amend the Code, at its sole discretion.

4. COMPLIANCE

All Company Personnel are required to comply with the Code, and are expected to:

1. Read and understand the Code and its application to the performance of the their business responsibilities; and
2. Behave in accordance with the Code and seek to avoid even the appearance of wrongdoing or improper behaviour.

Those who violate the standards in this Code will be subject to disciplinary action, up to and including termination of employment, and where applicable and required, reporting violations to the appropriate regulatory or criminal authorities. Any Company Personnel who observes or otherwise becomes aware of conduct that violates, or could violate the Code, must promptly report such violation or potential violation to the Company. Any Company Personnel who fails to immediately report a Code violation, or perceived violation, or who violates any aspect of the Code may be subject to disciplinary action, up to and including termination of employment.

MDA-HR-001 Rev. C
Use or disclosure of information contained herein is subject to the restriction on the title/cover page
Printed copies are not controlled