Code of Business Conduct and Ethics

1. Purpose and scope

This Code establishes the minimum ethical standards for directors, officers, employees, contractors, consultants, agents, and controlled subsidiaries of Bridgehampton International Inc. Covered persons must act honestly, lawfully, fairly, safely, and in the Company's best interests. Third parties are expected to follow equivalent standards when acting for the Company.

2. Core expectations

• Act with integrity and exercise sound judgment.
• Comply with applicable law, permits, contracts, and Company policy.
• Speak up promptly about suspected misconduct or unsafe conditions.
• Protect people, communities, the environment, information, and Company assets.
• Maintain accurate records and cooperate with audits and investigations.

3. Conflicts of interest

Covered persons must avoid or promptly disclose actual, potential, and apparent conflicts. Examples include ownership in a supplier or counterparty, outside employment, gifts that may influence judgment, use of Company opportunity for personal benefit, related-party hiring or contracting, personal loans, and relationships affecting supervision or procurement. Directors and officers must disclose material interests to the Board or an authorized committee before action. Transactions will be handled under DGCL Section 144, the Certificate of Incorporation, Bylaws, and Board procedures.

4. Corporate opportunities and assets

No covered person may take for personal benefit an opportunity discovered through Company position, property, or information unless the opportunity is fully disclosed and the Board or authorized disinterested decision maker declines it. Company funds, equipment, intellectual property, confidential information, aircraft, vehicles, systems, and personnel may be used only for legitimate business or approved incidental use.

5. Gifts, hospitality, and political activity

Never give or receive cash or cash equivalents, improper benefits, or anything intended to influence a decision. Reasonable business courtesies must be lawful, infrequent, transparent, proportionate, and accurately recorded. Gifts or hospitality involving a government official require advance Legal approval. Company political contributions require Board or specifically delegated approval and full legal compliance. Personal political activity must not imply Company endorsement.

6. Anti-bribery, sanctions, and financial crime

The Company prohibits bribery, kickbacks, facilitation payments, secret commissions, money laundering, sanctions evasion, and false records. Covered persons must follow due-diligence, screening, approval, contracting, and monitoring requirements for agents, government-facing intermediaries, joint ventures, suppliers, customers, and high-risk payments.

7. Fair dealing and competition

Deal fairly with customers, suppliers, partners, competitors, and employees. Do not manipulate, conceal, misuse confidential information, misrepresent facts, collude on price or market allocation, improperly exchange competitive information, or obstruct legitimate procurement.

8. Books, records, and controls

Records must accurately and completely reflect transactions and operational events. No undisclosed account, off-book fund, false invoice, misleading reserve or production record, improper expense, side letter, or concealed payment is permitted. Retain and dispose of records under applicable holds and schedules. Never alter, destroy, or conceal evidence relevant to an investigation, audit, dispute, or government inquiry.

9. Confidentiality, privacy, and cybersecurity

Protect Company, personal, technical, geological, commercial, customer, and counterparty information. Share it only for authorized business need and under appropriate safeguards. Follow access controls, device security, incident-reporting, data-transfer, privacy, and cybersecurity requirements. Confidentiality obligations continue after service ends.

10. Securities and material nonpublic information

Do not trade in securities, or recommend or tip another person to trade, while aware of material nonpublic information obtained through Company service. This applies to securities of customers, suppliers, partners, competitors, financing sources, acquisition targets, and any future Company securities. Follow the Insider Trading Policy.

11. Health, safety, environment, and communities

No commercial objective justifies unsafe work, illegal environmental conduct, concealment of an incident, or disrespect for community and human rights. Exercise stop-work authority where there is an imminent or uncontrolled risk. Report spills, releases, injuries, well-control events, threats, and cultural-heritage concerns immediately.

12. Respectful and inclusive workplace

The Company prohibits discrimination, harassment, bullying, retaliation, violence, and threats. Employment decisions will be based on lawful, job-related criteria. Reasonable accommodations and protected leave will be provided where required.

13. Reporting and non-retaliation

Raise questions or concerns to a supervisor, Legal, Human Resources, Internal Audit, the Audit and Risk Committee Chair, or an approved reporting channel. Reports may be made confidentially and, where available, anonymously. Retaliation against a person who raises a good-faith concern, seeks advice, refuses unlawful conduct, or participates in an investigation is prohibited.

14. Investigations, discipline, and waivers

The Company will investigate concerns impartially and proportionately, protect confidentiality to the extent practical, and preserve rights to report directly to government authorities. Violations may result in discipline up to termination, contract cancellation, recovery of compensation, referral to authorities, and civil action. Waivers for directors or executive officers require approval by disinterested directors and disclosure if legally required.