North West : Code of Business Conduct and Ethics (Code of Business Conduct and Ethics 2024 Compliance SEP8 2025)

About this update from North West Company Inc.

CODE OF BUSINESS CONDUCT AND ETHICS (ENTERPRISE WIDE) We all need to come to work each day ready to perform our jobs ethically, with integrity and to the best of our abilities in a way that serves our customers, adds value to our owners or shareholders, and preserves our reputation for trust. This Code of Business Conduct and Ethics (the " Code ") describes the standards of conduct required of directors, officers and employees of the company and covers in general terms some of the various situations that North West directors, officers and employees may encounter. While it is not possible to cover every situation that you will face, the Code covers basic principles that every North West director, officer and employee must follow. If a law conflicts with any portion of the Code, North West directors, officers and employees must comply with the law. If a local custom or policy conflicts with the Code, North West directors, officers and employees must comply with the Code. The Code was adopted and approved by the Board of Directors of The North West Company Inc. (the " Board ") on September 11, 2014, was amended by the Board on December 11, 2017, December 11, 2018 and September 7, 2022, and was further amended by the Board on September 8, 2025. Any amendments to the Code must be authorized by the Board. GENERAL INFORMATION ABOUT THE CODE To Whom Does The Code Apply? The Code applies to all directors, officers and employees (collectively, " we ", " us ", " our ") of The North West Company Inc. and all of its subsidiaries that are not publicly traded entities (collectively, " North West ", or the " company "). Basic Principles on How We Conduct Our Business At North West, we: Make business decisions in the best interests of the company. Understand and comply with laws, regulations and rules that apply to our company. Respect and maintain the privacy of information belonging to our employees, customers and suppliers. Promote integrity, honesty and ethical conduct, including the ethical handling of actual or apparent conflicts of interest. Promote full, fair, accurate, timely and understandable disclosure in reports and documents that North West files with, or submits to, securities regulators and in other public communications made by North West. Do not use undisclosed material information to trade in North West shares. Protect and promote the protection of company information and assets including corporate opportunities and confidential information. Protect the company's assets from loss, misuse, and theft. Ensure the company's books and records are complete and accurate. Obtain competitive information in a legal manner. Promote fair dealing practices and avoid situations where personal interests conflict or might conflict with the interests of the company. Deter wrongdoing and do not tolerate any form of abuse, harassment or other forms of disrespectful and inappropriate behavior towards our employees, directors, officers, investors, suppliers, customers, and other stakeholders. Ensure accountability for adherence to the Code. Many of the topics covered in the Code are also governed by specific key company policies or directives which should be referred to in more detail on the subject. To review these policies and directives, please talk to your manager. If You Have Questions on What to Do When in doubt as to what to do in a particular situation, you must exercise proper judgment by seeking additional information and guidance before acting. The following are the steps to keep in mind when you have a new question or problem. If you still need assistance after following these steps, or do not feel comfortable approaching your manager with your question, discuss it locally with your manager once removed. If this is not appropriate for any reason, or if you still feel uncomfortable, please request guidance from the Ethics Committee of the company. Please refer to page 12 for contact information for the Ethics Committee. Make sure you have all the facts. In order to reach the right solutions, we must be as fully informed as possible. Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will help you to focus on the specific question you are faced with and the alternatives you have. Use your judgment and common sense - if something seems like it might possibly be unethical or improper, it probably is. In every situation, ask yourself: If the result of my actions were to appear on the front page of the newspaper, would it be embarrassing to me, my family, or the company? Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved and discuss the problem. Discuss the problem with your manager . This is the basic guidance for all situations. In many cases, your manager will be more knowledgeable about the question, and will appreciate being brought into the decision-making process. Remember that it is your manager's responsibility to help solve problems. Always ask first, act later. If you are unsure of what to do in any situation, seek guidance before you act. What Can Happen If I Do Not Follow the Code? All directors, officers and employees are required to be familiar with the Code, comply with its provisions and report any suspected violations as described below. If you are found to have not followed the Code, appropriate remedial or disciplinary action will be taken. This may include, but is not limited to, training, coaching, written warnings, monetary penalties, and termination of employment. THE CODE We Make Decisions in the Best Interests of North West Conflicts of Interest A conflict of interest occurs when you allow your personal interest to influence or appear to influence your ability to make honest and ethical business decisions in the best interests of the company. A conflict of interest can arise when you take actions or have interests that may make it difficult for you to perform your work for the company, objectively and effectively or have an interest in an agreement or transaction involving the company. Conflicts of interest may also arise when you or a member of your family receive personal benefits as a result of your position with the company. For example, accepting gifts, favours or entertainment may influence or be perceived to influence your ability to make objective business decisions. Conflicts of interest are to be eliminated or avoided as a matter of policy, except as may be approved (after full and appropriate disclosure) by the Governance and Nominating Committee of the Board. Conflicts of interest may not always be clear cut. If you have a question, you should consult with your manager or the Ethics Committee. If you become aware of a conflict or potential conflict, you should bring it to the attention of your manager or the Ethics Committee. If your manager is involved in the potential or actual conflict, you should bring it to the attention of the Ethics Committee. Please refer to page 12 for contact information for the Ethics Committee. Gifts and Entertainment Invitations to business entertainment in the form of meals should only be accepted for the purpose of conducting business and in the spirit of relationship building for the benefit of the company. There should also be an opportunity to give in return at a future date. Invitations to sporting, cultural or corporate events should not be accepted, other than invitations to community events hosted by community organizations, which may be accepted for the purpose of conducting business or in the spirit of relationship building for the benefit of North West. You may accept gifts from community organizations or government officials (including Indigenous government officials) only as permitted by law, and only for the purpose of conducting business or in the spirit of relationship building for the benefit of North West. Any gift received is deemed to be the property of the company, and you must declare any such gift to your manager and the Ethics Committee. You must not accept gifts, monetary or otherwise, from actual or potential suppliers, competitors or other non-government third parties with whom North West does business. If you do receive a gift, advise your manager and politely decline the gift and return it, with a note explaining North West's guidelines on accepting gifts. If the gift is perishable or otherwise not practicable to return, consult with the Ethics Committee on what you should do. If you win a prize or award at an event where you are representing the company or receive any type of participation gift, this is deemed to be the property of the company. You must declare any such prize, award or gift to your manager and to the Ethics Committee. The Ethics Committee will determine the dispensation of the prize or award. However, if you personally purchase a raffle ticket at such an event and win a prize or award, you may keep the prize. Travel and accommodation for any business trips must be paid for by the company, unless approved in advance by the Ethics Committee. You or your family members must not offer, give or provide or authorize any gift or entertainment unless it is not a cash gift, is consistent with customary business practices, is not excessive in value, cannot be construed as a bribe or payoff and does not violate any laws. If a disinterested third party would be likely to believe that the gift affected your judgment, then it must not be offered, given, provided or authorized. All business dealings must be on arm's length terms and free from any favourable treatment resulting from your personal interests. Payments, Favors and Gifts to Government Personnel You must comply with all laws regarding payments or gifts to any government officials, including Indigenous government officials. The promise, offer or delivery to an official or employee of various governments of a gift, favour, or other payment or gratuity in violation of these laws violates North West policy, but could also be a criminal offense. You must obtain the prior authorization of the President and Chief Executive Officer prior to making any payment, favour, or gift of any kind to any government official. Lobbying Any contact with government personnel for the purpose of influencing legislation or rule making, including such activity in connection with marketing or procurement matters, is considered lobbying. You are responsible for knowing and following all relevant lobbying laws and associated gift laws, if applicable, and for compliance with all reporting requirements. You must obtain the prior approval of your manager to lobby or authorize anyone else (for example, a consultant or agent) to lobby on behalf of North West unless the subject matter is national in scope or may be perceived to affect the overall reputation of North West in which case you must obtain the prior approval of the President and Chief Executive Officer. Sample Merchandise All merchandise or products provided to you by representatives of other companies for the purpose of demonstration or samples are the property of the company. Samples should never be delivered directly to your home. Competition and Fair Dealing North West seeks to excel and to outperform any competitors fairly and honestly through superior performance and not through unethical or illegal business practices. Taking proprietary information without the owner's consent, inducing disclosure of that information by past or present employees to other persons, or using that information is prohibited. You should respect the rights of, and deal fairly with, North West's competitors, persons with whom North West has a business relationship, shareholders and employees. You should not take unfair advantage of anyone through illegal conduct, manipulation, concealment, abuse of proprietary information, misrepresentation of material facts, or any other intentional unfair-dealing practice. Nor should you act in a manner that may be anticompetitive under competition or anti-trust laws. We Comply With Laws Each of us must be proactive and make sure we are aware of and comply, both in letter and spirit, with all laws, rules and regulations that apply to our company and in particular, those which impact our role within our company. Although you may not know all of the details of these laws, it is important to know enough to determine when to seek advice from your manager. The Vice President, Legal and Corporate Secretary is also available to assist you in determining applicable legal requirements and to seek extern al advice if you have a question. Please refer to page 12 for contact information for the Vice President, Legal and Corporate Secretary. Examples of some of the key areas of law that impact our company are: Unlawful payments We never accept bribes, kickbacks or other unlawful payments. They can sometimes be disguised as extraordinary gifts, entertainment and charitable donations. Competitors We deal with our competitors fairly. We obtain information about our competitors in a legal manner. Customers We do not engage in misleading advertising.

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