Code of Ethics of ASES GROUP, s.r.o.

Introduction

The Code of Ethics expresses the fundamental principles and expectations for the behavior of the employees of ASES GROUP, s.r.o. (hereinafter "AG-SRO").

Our main principles

• we put customer interest first,
• we are transparent in business and correct in relationships,
• we are responsible and discreet in negotiations,
• we respect the law,
• we value our colleagues,
• we follow the principles of the PEARL culture and act ethically.

These principles apply to all employees of the company. Employees in managerial positions bear greater responsibility, leading their teams through exemplary behavior and creating an environment where frequency and integrity are presented as core qualities.

No employee can be asked to act in contradiction to this code. The Code of Ethics is embedded in the company's overall quality policy definition and is its fundamental and most important standard, upon which other regulations are based.

Background
AG-SRO aims to become an organization that:

• listens to its customers and anticipates their needs by providing excellent products and services
• realizes the potential of its employees
• helps the local environment.

An organization that puts people first is based on specific principles that form the foundation for the daily thinking and actions of its employees. These principles make up the acronym PEARL:

• P / PERFORMANCE
• E / EMPOWERMENT
• A / ACCOUNTABILITY
• R / RESPONSIVENESS
• L / LOCAL EMBEDDEDNESS

When following these principles, it is important how we behave: we show respect, are approachable, and focus on results. We believe that behavior aligned with these values will not only help continually reinforce trust in our company, but will also serve as a reference for current and new clients.

Therefore, all the principles described in this Code are linked to the above-mentioned principles and values of behavior.

Respect

We show respect to internal and external customers. Showing respect means treating all people as equals, being transparent, recognizing people based on what they do, do, and who they are, especially based on the dignity of each individual. Respect is always mutual. It is not only required, but it must also be demonstrated.

Responsiveness

We listen to our clients, employees, and everyone we deal with, identify their needs, and try to fulfill them as best as we can. Responsiveness means anticipating and responding promptly and considerately to suggestions, influences, requests, or efforts. Responsiveness also involves interest, acceptance, generosity, impartiality, observation, open-mindedness, approachability, tolerance, and understanding. It implies the feeling of "we're all in this together."

Results driven

We strive to achieve goals for our customers, employees, and organization. We fulfill what we have promised. When focusing on results, we concentrate on meeting goals and achieving results in accordance with the required brief, deadline, costs, and quality. Procedures should be followed, but poor performance is not excused. Cooperation describes achieving the result. A result-driven person or organization focuses on achieving specific and measurable goals and on continuous improvement.

Scope and Binding Nature of the Code of Ethics

This Code of Ethics applies to all employees of the company. It forms the minimum set of rules required for all employees to follow. The Code also reflects the general business principles. The company is authorized to monitor compliance with the Code of Ethics and regularly evaluates the behavior of individual employees in relation to the company's values. Non-compliance with any standard within the Code of Ethics may, after impartial evaluation, lead to disciplinary action in accordance with applicable labor laws.

P / PERFORMANCE

"Employees strive to achieve excellent results in all tasks, thereby combating mediocrity. We are customer-focused. Through perfect execution, we continuously improve the quality of our products and services to exceed customer expectations."

Working Hours

The long-term success of the group primarily depends on the high efficiency of employees' work. The company creates conditions for its employees to perform their work properly during working hours. Employees must use working hours efficiently and perform only activities that are beneficial to the employer. These activities are defined by labor law and AG-SRO's internal regulations, particularly the Work Regulations. The employer does not tolerate bringing, consuming, or being under the influence of alcohol or other narcotic substances at the workplace. Substance abuse that affects performance: Consuming alcoholic beverages, narcotics, or other addictive substances during working hours may endanger health or life, significantly damage the company's reputation, or lead to significant financial loss. Employees must not work under the influence of narcotic, psychotropic, or other addictive substances or alcohol.

E / EMPOWERMENT

"The management style encourages the creativity of every employee and supports their collaboration. Employees have sufficient space to create procedures and rules that will convince our customers of the high level of our products and services."
Entrepreneurial behavior
To be successful in its business, the company creates and supports a strong entrepreneurial spirit. The company also encourages and values creativity and initiative.
Employees must therefore base their actions on sound entrepreneurial thinking and act as if they were the owners of the company. Such behavior will bring the company and its owners the greatest long-term financial benefit.
Initiative
To succeed in a competitive market, the company needs highly efficient and effective processes. Therefore, a proactive approach to proposals for improving existing work processes is applied. New ideas support change. All employees are encouraged to express their opinions openly, and their opinions are taken into account.
Compliance with delegated powers and mandates
In business relations, the company is represented by a specific employee who directly communicates with the customer and creates long-term working relationships with them. It is necessary to comply with all signing, decision-making, or approval powers and limits for carrying out business transactions. An employee may only conclude, decide, or approve commitments on behalf of the company if they have been given the approval authority for those commitments.

A / ACCOUNTABILITY

"Employees take personal responsibility for their tasks. We serve the interests of our customers and earn their trust by working in an ethical and financially reasonable manner. Results are published transparently."
Compliance with rules
The company can only comply with the rules governing its business if its employees follow the rules that govern their work. The company requires compliance with all generally binding legal and internal work regulations and continuously monitors this compliance. The employer informs employees about applicable internal regulations and allows them to view these and other regulations.
Conflict of interest
The company expects its employees to clearly distinguish between their professional and personal lives and always act in a way that maintains their independence and avoids conflicts of interest. Employees are required to refuse any interference, pressure, influence, requests, or demands that could jeopardize the impartiality of decision-making regarding customers or business partners. It is unacceptable to jeopardize personal independence by accepting gifts or similar benefits from clients and suppliers. Any relationship other than a purely professional one between employees must not disrupt normal work performance in the team.
Protection of company assets
The company provides employees with various communication tools to enable them to work efficiently (e.g., computers, phones, internet access, data access, etc.). These tools must be used only in connection with the work activity for which they are intended. Unless otherwise specified by internal regulations, company property can only be used for work purposes, and provided resources can only be used in accordance with the law. All employees are required to maintain their workplace, including entrusted assets, and its surroundings in good order and cleanliness.
Equal treatment
The company prohibits any form of direct or indirect discrimination or unequal treatment of employees or customers based on race, gender, status, sexual orientation, age, marital status, disability, religion, etc. Employees or clients must not be discriminated against in relation to offered products and services, access to employment, employment conditions, education, career advancement, or position assignments.
Gifts and bribes
The company places great emphasis on preventing conflicts of interest, transparency in relationships between employees, customers, and third parties, and especially on the moral integrity of its employees. In connection with work performance, employees must not accept or offer gifts or similar benefits. Accepting, offering, or facilitating bribes is unacceptable. The company rejects all forms of bribery and corruption.
Private business outside working hours
The company respects employees' private activities outside working hours. However, it is possible that entities in which employees are involved may be in a business relationship with the company that represents a conflict of interest. Therefore, business activities must be conducted outside the employment relationship with the employer in accordance with applicable legal regulations, the employment contract, and the employer's internal regulations. Employees are not permitted to engage in business activities that would or could lead to a conflict of personal interests and company interests.
Ethics and fraud
In a constantly changing environment or due to internal and external pressures, mistakes or violations of rules and regulations may occur, either intentionally or negligently. It is important to communicate such mistakes openly so that the situation can be resolved quickly, and other employees can learn from it.
Employees are expected to:

• act honestly and maintain integrity at all times,
• know all relevant laws, internal regulations, policies, and standard operating procedures related to their work and comply with them,
• take care of the resources for which they are responsible,
• cooperate and assist investigating authorities to the best of their ability.

Employees who have information on any fraudulent activities should immediately inform their supervisor. Under no circumstances should an employee attempt to personally lead an investigation, conduct interviews, or contact suspects.

The company's executives are responsible for ensuring that all activities are carried out in a manner that:

• complies with the quality policy or the company's policies,
• complies with all applicable legal, tax, accounting, and regulatory provisions, as well as with internal policies, procedural limits, and guidelines.
• allows proper control by local and other relevant legal, tax, accounting, and other state authorities.

In relation to fraud, the company's management is responsible for:

• thoroughly understanding the types of fraud that could occur in the workplace.
• maintaining constant vigilance and awareness of any indicators of fraudulent activity,
• implementing effective controls and procedures to mitigate fraud risks and ensuring that
  controls are effective and continuously functioning,

Data protection and confidential information
The relationship with the customer is based on mutual trust and confidentiality. Decision-making is based on complete and truthful data. All information about customers and business partners obtained during the course of activities is treated as confidential. Employees must not enter incorrect or distorted data into the company's information systems and must not withhold any information important for decision-making. Employees must not allow unauthorized individuals access to the company's information systems.

R / RESPONSIVENESS

"Employees recognize and promptly and courteously respond to suggestions, requests, and efforts from management, colleagues, and our customers."
Culture and ethical behavior
Proper and ethical behavior by each employee influences the company's good reputation, contributes to a positive corporate culture, and impacts the personal motivation and performance of each employee. We always expect employees to behave according to the PEARL principles. The company places great emphasis on good behavior. Workplace behavior must not make others uncomfortable or jeopardize their health and safety. Employees are prohibited from:

• making offensive remarks,
• acting in ways that undermine the integrity or dignity of other colleagues at work,
• conspiring against other colleagues,
• harassing, bullying, or sexually harassing colleagues,
• abusing their position in relation to their colleagues.

L / LOCAL EMBEDDEDNESS

"As employees, we are socially responsible. We comply with local rules and regulations. We behave ecologically. We collaborate and build long-term customer relationships."
Corporate social responsibility
The company AG-SRO supports corporate social responsibility. The principles and statements of AG-SRO regarding corruption, human rights protection, and environmental protection must always be applied.
Perception of AG-SRO by the public
The perception of AG-SRO is strongly influenced by maintaining the company's good reputation within the broad customer public.
Conclusion
Behavior in accordance with the code of ethics is the foundation of the successful operation of our company. In case of any uncertainties or doubts, employees can approach their supervisor. If anyone violates the signed ethical standards, it damages the company and its employees. Any suspicion of a serious breach of law, regulation, or ethical standard must be reported to the supervisor.