Code of ethics
of Aures Holdings

Code of ethics of Aures Holdings

This Code of Ethics is a document describing the fundamental principles of ethical conduct and the behaviour expected from all employees of the AURES Group. It does not introduce new principles of conduct, but merely defines the adopted rules of conduct for the Group.

This Code of Ethics applies for all employees of the group. The group includes all companies within AURES Holdings (“The Group”). Employees in managerial positions have a greater degree of responsibility; they are called upon to lead their teams by setting a good example and are expected to create an environment steered by honesty and integrity.

The Code of Ethics applies to all co-workers and employees of the Group as well as all other external entities that perform any action or tasks entrusted to them by the Company. It is applicable to all countries in which the Group operates, regardless of local practices.

1. INTRODUCTORY PROVISIONS OF THE CODE OF ETHICS

Binding nature of the Code of Ethics

As internal regulation, this Code of Ethics ranks alongside the generally applicable labour laws and regulations for each employee and external partner. The Code constitutes a basic description of the ethical standards on which the corporate philosophy of the entire Group is based. Failure to comply with this Code will not be tolerated.

Purpose of the Code of Ethics

The purpose of the Code of Ethics is to provide guidance to our employees, colleagues and partners so they can most effectively do business in accordance with the highest ethical standards and the Group’s core values.

This Code also helps in the effective promotion and protection of our brand. It helps us to identify ethical risks and provides a clear guideline for recognising and resolving ethical issues. The Code also provides us with a mechanism for reporting unethical conduct without fear of reprisal.

Obligations for employees

Reporting problems

Honest work and mutual respect promote a culture that encourages innovation and helps us all to achieve success. Any activity that could be unlawful, fraudulent or unethical must be reported immediately. The AURES Group takes all reported violations seriously and investigates them

immediately. The company does its utmost to protect the anonymity of anyone who reports a possible violation in good faith, and will not tolerate reprisals against anyone who reports such a violation. Details of the correct procedure for reporting said violations are defined by a separate internal document. Employees also have access to an online platform that enables reports to be filed anonymously.

Ban on reprisals

The company prohibits and will not tolerate reprisals of any kind against anyone who reports, in good faith, an actual or suspected violation of any law, rule, regulation or provision of this Code. Reprisal or repression is in itself considered a violation of this Code. If you suspect that you have experienced any form of reprisal, you should immediately report the matter to your superior, or the Compliance Officer.

Acting in accordance with the principles of the Code of Ethics

This Code of Ethics is not exhaustive and does not aim to cover all laws, rules, principles and circumstances relating to ethical conduct.

When deciding what constitutes suitable behaviour we must all exercise common sense and good judgment. If, as an employee of the Group, you find yourself in a situation where you are unsure of the ethical impact of your actions, ask yourself the following simple questions, which may serve to guide your moral compass:

• Is it in accordance with the Code of Ethics?
• Is it moral?
• Am I being fair and honest?
• Am I acting legally?
• Is what I am doing right?
• Will it show me and the Company in a good light?
• Would I like to read about it in the newspaper or on the internet?

If your answer to any of these questions is “no”, don’t do it.

Additional advice can be found in the Compliance Manual, or you can discuss the matter further with your superior, manager, division head or the Compliance Officer.

2. BASIC PRINCIPLES AND PHILOSOPHY OF THE CODE OF ETHICS

Compliance with the law

Everyone who works for AURES Holdings a.s. (the “Company”), or for any of the companies within the Group, is obliged to comply with the laws of the country in which they work, as well as the internal regulations of the Group. They are obliged to act in an honourable manner and in accordance with the moral and cultural principles generally recognised in the place they are currently in. Environmental protection

The Group is committed to protecting the environment and actively helping to reduce the adverse effects of its activities on its surroundings. The minimum standard expected is to at least comply with all the legislative requirements and permits granted by local state authorities.

In order to uphold our environmental protection principles we have implemented and apply strict regulations for the management of waste, water and energy.

We are aware of the danger of climate change and its consequences. We are committed to reducing our carbon footprint with the aim of achieving carbon neutrality in 2025.

Mutual respect

Everyone who works for the Group is obliged to respect their superiors and colleagues and uphold the principles of mutual trust and cooperation at all times. Each employee is made aware that the manner in which they conduct themselves outside the company represents a business with international significance and reach.

We must respect everyone as an individual and treat them in a respectful manner. In the spirit of openness we accept the individual differences that all people have and strive to provide them with the opportunity to develop to their full potential. By acting with respect for one another, in a courteous, polite and fair manner, we continue to build on our success through teamwork and cooperation.

Confidentiality

Any information associated with the Group’s business activities that is not in the public domain is considered to be confidential information and each employee is obliged to keep such information confidential. The disclosure of confidential information to any person not authorised to receive it, including other employees of the Group, and any misuse of confidential information for any purpose other than that designated by the Company may be seriously detrimental to the Company.

Employees are obliged to keep information secret and avoid the above both while employed with the Company, and after leaving the Company. The Company will maintain the proper flow and sharing of information as required for the purpose of developing the Company’s business activities.

Responsible communication

The Company projects its image to the public through its business communication. All communication must therefore always be transparent and in accordance with the Group’s strategic aims and values. Therefore, only employees authorised to communicate with the press or post on social networks should speak on behalf of the Group.

Employees of the Company who are not authorised spokespersons may not respond to questions relating to the business, facilities, employees or customers of the Group posed by persons they do not know or representatives of the media. All such questions must be put to the Group’s PR department.

Health and safety

Everyone must ensure full compliance with all the health and safety regulations, principles and procedures in place and be prepared to implement emergency readiness plans. Dangerous working conditions or procedures must be reported immediately, to enable timely precautions to be taken. All workplace-related accidents must be reported immediately, regardless of their significance. The business health and safety procedures are defined in detail in an internal framework.

Loyalty

In all circumstances each employee is obliged to defend the good name of the Company and to act to promote the good reputation of the Group. This also means that any promotion of one's own interests in violation of the Company’s interests is prohibited.

Team spirit

Teamwork is a core guiding for the Company. We therefore emphasise behaving and acting as a team, this crucially includes cooperation with colleagues and respect for the work of others.

Ban on substance abuse

We are committed to maintaining a workplace free from drugs and alcohol. When working for the Company or on the Company’s premises no one is permitted to be under the physical or psychological influence of drugs or alcohol, in order to maintain a pleasant and safe working environment.

If an employee is found to be working under the influence of alcohol or illegal drugs, or to be using, possessing or selling illegal drugs during working hours or when working for the Company, they risk having their employment terminated with immediate effect. The purchase or consumption of alcoholic beverages in the Company’s premises is prohibited, with the exception of cases explicitly permitted by Company management at corporate events. If you take prescribed medication that could affect your performance at work or could impair your ability to work safely, you are obliged to discuss the matter with a manager or superior.

Diversity and equal opportunities

The Company wants to create a working environment that is open to everyone, regardless of their gender, race, skin colour, nationality, ethnic origin, religion, political preference, physical health, age or sexual orientation.

We aim to encourage diverse teams of people and select our employees objectively, without prejudice, on the basis of their competence.

Ban on harassment and violence in the workplace

Everyone has the right to a safe working environment, free from any form of harassment. We will not tolerate any verbal, non-verbal or physical conduct by anyone associated with our Group (including suppliers and clients) that constitutes harassment or creates an intimidating, offensive, defamatory or hostile working environment, including violence in the workplace and sexual harassment.

We require all our employees to fully comply with the anti-harassment laws in place in their place of work.

In accordance with the applicable laws and regulations we prohibit the possession and/or use of firearms, explosives and/or other hazardous substances in the Company’s premises or when performing work for the Company.

Protection of the Company’s property

Theft, vandalism and the inappropriate use of the Company’s property may impair the Company's profitability and the status of its assets. Employees are obliged to protect the tangible and intangible assets of the Company entrusted to them. Employees must also ensure that the Company’s property is used for the purpose in which it was intended.

3. ETHICAL PRINCIPLES OF BUSINESS AND RELATIONS OUTSIDE THE COMPANY

Dealing with authorities

During the course of its business activities the Group needs various licences, approvals and permits from a variety of authorities in each individual country. The Company is obliged to maintain the required contact with these authorities according to best practice ethical and professional standards and also with respect to the relevant laws. The Company’s employees are prohibited from using illegal or dishonourable means (including the provision of bribes, gifts or other payments and incentives) for the purpose of promoting the Company’s business interests.

The Company is committed to cooperating with official authorities and is subject to their legal rules; it is also obliged to provide true and accurate information, if required to do so. In the event of any doubt as to how to respond to a request from an authority, employees must discuss the request with their direct superior and the Group’s legal department.

Dealing with customers

We act honourably and courteously towards our customers and always strive to provide them with accurate and verified information.

Dealing with suppliers

The Group maintains efficient, honourable and legal business relations with its suppliers based on approved procedures. The Company insists on compliance with tender procedures when dealing with suppliers in order to obtain the best possible terms and prices and so as to provide potential suppliers with a competitive opportunity to gain a share in the total quantity of the Company’s purchases. This helps to ensure that suppliers are motivated to provide quality services at competitive price points. The Company considers it very important to build strong working relationships with suppliers, all of which have to strictly comply with the law during the course of their activities with the business.

Dealing with competitors

The Company and its employees will not engage in any activity that could result in the exploitation of employees or other when obtaining information relating to competitors’ business activities and thus breach the confidentiality agreement or other commitments to competitors, or exert influence over their assets or rights.

The Company and its employees will carry out their activities in accordance with the relevant competition laws and under no circumstances may be privy to any agreements or arrangements, written or verbal, with current or potential competitors that do not uphold the law.

Zero tolerance for bribery and corruption

The Group strictly applies a zero tolerance policy with regard to bribery and/or corruption, as follows:

• The Group will not offer, give or accept bribes for any purpose directly or through a third party;
• The Group does not knowingly enter into business relations with any person or entity that gives or accepts bribes for any purpose directly or through a third party;
• The Group is subject to all the applicable laws, regulations and contractual requirements related to tackling bribery and corruption;
• The Group informs each employee of the Company, as well as current and potential business partners, of its policy of zero tolerance for bribery and corruption;
• The Group will enforce, check and require the above principles of zero tolerance for bribery and corruption from all its employees and business partners;

Avoiding conflicts of interest

During negotiations and decision-making processes employees may not favour their own private interests or allow themselves to be influenced by positive or negative relations with specific people. Employees must not allow their private interests to conflict with their position as employees of the Company. Private interests include any advantage for employees, their families, people close to them, relatives, friends and legal entities or individuals with whom they have business or other relations.

Employees are obliged to prevent conflicts of interest and avoid situations that could give rise to a suspected conflict of interest. In order to properly avoid an apparent conflict of interest employees are obliged to inform their direct superior and/or the Compliance Officer, in writing, of any suspicion that such a conflict of interest has occurred or could occur.

In addition to this, employees may not directly or indirectly accept any gifts or other forms of hospitality from any suppliers or third parties with which the Group trades (this does not apply to nominal gifts, which are typically given).

The particulars of managing conflicts of interest and the giving or acceptance of gifts and hospitality are explained in further detail in the Group’s internal regulatory documentation.