Code of Conduct for the Board of Directors of Festi hf.

1. Trust, professionalism and integrity

1.1. These rules apply to the Board of Directors and CEO of Festi hf.

1.2. We abide by the Code of Conduct of Festi hf. We work professionally, with care, and adopt good business practices and work practices that build trust.

1.3. We comply with the laws and regulations pertaining to the Company's operations and take care to conduct our work and actions in accordance with Festi's defined goals, purposes and policies, the Company's policy on social responsibility and its operating rules.

1.4. We treat stakeholders and colleagues with respect and promote good communication in our work.

1.5. The reputation of Festi and its subsidiaries is one of the Company's most valuable assets and a cornerstone of the Company's social strategy. Shares in Festi have been admitted to trading on Nasdaq's main market in Iceland, and the Company is also considered to be linked to the public interest in the sense of the law. This gives the Board of Directors an intense responsibility for quality work practices and to not do anything that is not compatible with their position at the Company, based on legal responsibility, the Company's policies, image and trust in it.

2. Conflicts of interest

2.1. We conduct our work in such a way as to reduce the risk of conflicts of interest arising.

2.2. We do not use information we receive in the course of our work for our own benefit or that of our family members, and we pay special attention to rules regarding insider information when performing our work.

2.3. We mind the reputation of the workplace in our relationships outside of work, according to our position within the Company.

2.4. We show a willingness to cooperate if our work or other actions are audited.

3. Follow up

3.1. These rules must be introduced to all new members of the Board of Directors. As members of the Board of Directors, we hereby confirm by signature that we have read these rules.

3.2. The Board of Directors is responsible for and supervises the enforcing of these rules. Should a member of the Board of Directors violate the rules or exhibit unacceptable behavior, the matter will be dealt with in accordance with Festi's rules on reputational risk and conflicts of interest.

4. Changes

4.1. Changes to this Code of Conduct for the Board of Directors must be put forth in writing and take effect when the Board of Directors of Festi has given approval. All changes to these rules must be announced to those affected as soon as they have taken effect.

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Approved by the Board of Directors on March 22, 2022

Thus amended at the Board of Directors’ meeting on June 9, 2022

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It is clear to us that the reputation of Festi and its subsidiaries is the most valuable asset of the company. In view of this, we have established the following regulations, which apply to all the activities of the company, all employees and its directors, as well as those contractors who carry out tasks for the company.

The community

We comply with all laws and regulations pertaining to the company's activities and strive to be trusted participants in the ice community.

The customers

We respect our customers and make every effort to provide them with excellent products and services at reasonable prices. In the same way, we respect our suppliers and value the merits of their role in the value chain.

The staff

We strive to ensure the safety and well-being of the company's staff with good facilities in the workplace, education and training. Adhere to recognized safety and health standards. We are tolerant, take into account different points of view and allow everyone's abilities to enjoy the benefits. We promote equality in the workplace and are considerate and fair in all our dealings. We do not feel bullying or other harassment.

The shareholders

We provide shareholders and other market participants with correct and conclusive information about the Company's operations as a qualified market partner. The company depends on the rules of the market and good governance.

Gifts and Interests

Invitations or gifts which may be intended to influence commercial decisions may not be accepted. The Company authorizes, however, that reasonable and appropriate gifts and entertainments are offered and accepted in connection with normal and legitimate business involving additional parties. Gifts and entertainments shall be notified to the Executive Director for approval. Cash is not allowed to be given or received. Under no circumstances may transaction-related decisions be based on donors and may not lead to conflicts of interest. This applies to gifts from suppliers, those who wish to do business with the company, or others who could benefit from the decisions of the staffing company. We avoid making decisions that may create conflicts of interest. We need to be vigilant and take an honest stand whenthe situation arises that our decision is accompanied by the personal benefit and the executive's search opinion in any doubt.

The environment

We show respect for the environment and strive to offer environmentally friendly products and services. We strive to cause the slightest damage to the environment through the activities of the company and adhere to recognized environmental, quality, safety and health standards.

Confidentiality

We respect the obligation of confidentiality regarding the confidential information we receive, and preferably the obligation of confidentiality in the event of retirement. We do not use confidential information for any benefit, neither for ourselves nor for others.

Adopted February 27, 2020

Thus modified in Kopavogi on 28 February 2022