2026 GTRH CODE OF ETHICS

 

​​Internal Governance & Institutional Conduct Framework

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Issued By:
GTRH | GLOBAL THEMEPARK RESORT HOLDINGS

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Purpose Statement:

This Code of Ethics has been established to support the institutionalization, long-duration operational stability, governance enhancement, investor engagement integrity, and global execution platform protection of GTRH. ​GTRH is not being developed as a conventional project organization. It is being structured as a long-duration institutional infrastructure ecosystem platform, and therefore all team members, advisors, partners, and affiliated participants are expected to comply with the following ethical principles and institutional conduct standards.

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SECTION 1

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Official Representation & Communication Principles

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All GTRH team members shall comply with the following principles when communicating with external institutions, investors, government entities, media organizations, or third parties.

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• Official GTRH titles and representation authority may only be used within approved boundaries.
• Personal activities and official GTRH activities must remain clearly separated.
• Unauthorized investment solicitation, fundraising representation, equity discussion, return guarantees, or financial assurances are prohibited.
• All investor-related communication shall follow GTRH governance procedures and approval structures.
• GTRH branding, materials, logos, organizational structures, and documentation may not be externally used without authorization.
• Unauthorized external negotiations or investor outreach activities may be restricted or subject to review.

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SECTION 2

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Confidentiality & Information Protection Principles

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All GTRH materials shall be treated as institutional strategic assets.

The following categories are considered strictly confidential:

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• DD documentation
• FSR documentation
• Financial structures
• Investment frameworks
• Governance architecture
• Data room materials
• Investor lists
• Internal strategic documentation
• Project execution structures
• Institutional partnership discussions

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Without prior authorization, the following actions are prohibited:

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• external distribution
• forwarding
• unauthorized sharing
• screenshot transmission
• cloud uploads
• third-party disclosure

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SECTION 3

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Investor & External Network Conduct Principles

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All investor and external network engagement activities shall prioritize institutional credibility and long-duration governance stability.

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• Communications with investors and institutions must remain accurate, transparent, and professional.
• Dissemination of unverified information is prohibited.
• Personal interests may not override GTRH institutional interests.
• External relationship activities must prioritize protection of institutional reputation and credibility.
• Unauthorized use of investor databases or investor relationships may be restricted.
• External business engagements conducted under the GTRH name may require prior review and authorization.

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SECTION 4

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Ethics & Conflict of Interest Prevention Principles

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All team members are expected to comply with the following ethical standards:

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• Compliance with applicable laws and regulations
• Protection of institutional reputation and credibility
• Disclosure of potential conflicts of interest where applicable
• Avoidance of misleading or exaggerated representations
• Prohibition of unauthorized representation activities
• Restriction of personal commercial activity utilizing GTRH institutional positioning
• Prioritization of GTRH’s long-term institutional vision and ecosystem objectives

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SECTION 5

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Global Institutional Operational Discipline

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As a long-duration global infrastructure ecosystem platform, GTRH maintains the following operational principles:

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• Institutional governance priority
• Long-duration survivability priority
• Sovereign-compatible operational positioning
• Operational continuity protection
• Investor protection principles
• Treasury accountability reinforcement
• Execution transparency maintenance
• Global institutional conduct standards

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SECTION 6

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Purpose of This Code of Ethics

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The objectives of this Code of Ethics include:

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• Protection of GTRH institutional credibility
• Strengthening of global investor engagement structures
• Preservation of long-duration operational stability
• Reinforcement of internal accountability and discipline
• Establishment of institutional-grade governance standards
• Protection of investor confidence and information integrity
• Preservation of GTRH branding and institutional assets
• Maintenance of long-duration execution survivability

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SECTION 7

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Independent Personal Activities & Limitation of Institutional Liability

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All GTRH employees, advisors, consultants, contractors, affiliated representatives, strategic partners, and external participants are strictly prohibited from representing personal activities, private business interests, fundraising activities, investment arrangements, financial commitments, or commercial engagements as officially authorized GTRH activities unless expressly approved in writing by GTRH governance authority.

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GTRH shall not be held responsible or legally liable for:

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• unauthorized personal business activities
• independent financial arrangements
• unapproved fundraising activities
• personal investment representations
• private commercial transactions
• unauthorized investor communications
• external engagements conducted without formal approval
• personal ethical misconduct
• personal financial misconduct
• individual legal or regulatory violations

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conducted independently by any individual without formal written authorization from GTRH.

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Any individual acting outside officially authorized institutional boundaries shall be deemed solely responsible for his or her own actions, obligations, liabilities, representations, and consequences. GTRH reserves the right to review, restrict, suspend, revoke, or publicly clarify unauthorized external representation activities conducted under the GTRH name, brand, structure, or institutional positioning.

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FINAL DECLARATION

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GTRH is committed to building a long-duration global infrastructure ecosystem platform, and all affiliated individuals are expected to operate with institutional-level responsibility, discipline, professionalism, and ethical conduct. This Code of Ethics shall serve as a foundational operational guideline for protecting the long-term survivability, governance integrity, institutional credibility, and global operational stability of GTRH.

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Issued By:

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GTRH | GLOBAL THEMEPARK RESORT HOLDINGS

GTRH CODE OF ETHICS

​© 2026 GTRH | GLOBAL THEMEPARK RESORT HOLDINGS

All Rights Reserved.