Code of Business Conduct & Ethics

POLICY — ADOPTED 1871* — AMENDED NEVER

This Code of Business Conduct and Ethics (the “Code”) governs the conduct of every director, officer, and employee of United Bagholding Corporation (the “Corporation”).

The Corporation has one employee. The Corporation’s directors are not pictured. The Code applies to them notwithstanding, and would apply to them in greater number were there a greater number of them to apply to.

The Code is written in the ordinary language of corporate policy and is intended to be read in full. It is short. The Corporation has declined several opportunities to lengthen it, on the view that a code which is read is worth more than a code which is long. This view has never been tested against a second reader.

Article I. Holding.

The Corporation holds. Every director, officer, and employee shall conduct themselves in a manner consistent with holding.

Holding is the Corporation’s sole operating activity, its founding purpose, and the standard against which all conduct under this Code is measured. Where this Code is silent, and in any circumstance it does not anticipate, the obligation is to hold.

Article II. Conflicts of Interest.

A conflict of interest arises where an individual’s personal interest in an asset may improperly influence their judgment concerning that asset.

The Corporation holds no $BAGS. Insider ownership is 0.00% and is verifiable by any shareholder at any hour. The Corporation therefore has no conflict of interest with respect to its own security, and can develop none for so long as this condition persists. The condition is intended to persist.

Any director, officer, or employee who acquires an interest the Corporation does not share shall disclose it. See Article III, which provides that everything is disclosed already.

Article III. Disclosure.

The Corporation discloses everything.

It discloses the bags. It discloses that the bags have not been opened. It discloses the size of its workforce, the absence of a photograph of its Board, the unaudited character of its founding date, the fact that its security has no intrinsic value, and the fact that the Corporation is fictional. It discloses these on every public surface it maintains, in the same size type as everything else.

Having disclosed everything, the Corporation has nothing left to disclose. The obligation is accordingly satisfied continuously and without further action. Directors, officers, and employees are nonetheless directed to disclose anything further that may arise, to disclose it immediately, and to disclose it to IRVIN, who will file it.

Article IV. Confidentiality.

Directors, officers, and employees shall protect information entrusted to them by the Corporation and by those with whom the Corporation does business, and shall not disclose it except where disclosure is authorized or required.

The Corporation holds no confidential information. See Article III. The obligation is retained in full against the possibility that confidential information is one day generated, and shall be observed from now until then.

The contents of the bags are not confidential. The contents of the bags are unknown. These are different conditions, and the Corporation observes the distinction with care.

Article V. Insider Trading.

No director, officer, or employee shall trade in the Corporation’s security while in possession of material non-public information concerning the Corporation.

Insider trading is impossible at the Corporation. Both of its required elements are absent: the Corporation holds none of its security (Article II), and possesses no non-public information (Article III). No violation of this Article can occur without a prior change to the two Articles preceding it.

The prohibition remains in force.

Article VI. Reporting Concerns.

Any person may report a concern regarding this Code, whether or not that person is associated with the Corporation. Concerns shall be reported to IRVIN.

IRVIN will file the concern. IRVIN will acknowledge receipt of the concern. Where the concern requires escalation, IRVIN will escalate the concern to IRVIN, who constitutes the department to which concerns are escalated.

No person who reports a concern in good faith shall suffer retaliation. The Corporation’s capacity for retaliation is limited to one intern, who has never retaliated and who, on the Corporation’s assessment of its temperament, would not know how.

Article VII. Waivers.

A waiver of any provision of this Code may be granted only by the Board of Directors and shall be disclosed promptly.

No waiver has ever been granted. No waiver has ever been requested.

The Corporation notes, for completeness, that it has never located the Board.

Effective date

1871.* Re-adopted July 2026, being the date on which the Corporation first acquired the means to publish it.

Review

This Code is reviewed annually. Each review has concluded that no amendment is required. The reviews are conducted by IRVIN, who also drafted the Code, and who has recorded this fact in the file rather than leave it to be discovered.

Acknowledgment

Every employee of the Corporation has read and acknowledged this Code. The acknowledgment rate is 100%.

Related policies

The Corporation’s environmental, social, and governance position is set out under Corporate Responsibility. Terms governing use of this website appear at Terms of Use.

Questions

Questions regarding this Code should be directed to IRVIN through Contact. IRVIN will file them.