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Code of ethics

EMPLOYEE CODE OF ETHICS OF PROMOTEus s.r.o.

This Code of Ethics describes the fundamental principles and expectations for the conduct of employees of PROMOTEus s.r.o., hereinafter referred to as the Company.

Our main policies:

•   Our customers’ interests come first.
•   We are honest in business and fair in relationships.
•   We are responsible and discreet in negotiation.
•   We respect the law.
•   We appreciate our colleagues.
•   We follow the principles of the PEARL culture and behave ethically.

These policies apply to all employees of the Company. Management-level employees have more responsibility; they lead their teams by example, and create an environment in which honesty and integrity are presented as the fundamental qualities. No employee can be ever asked to act in violation of this Code. The Code of Ethics is enshrined directly in the general definition of the Company’s mission and it is its fundamental and most important standard on which other regulations are based.

The Company is committed to becoming an organisation that:

•   listens to its customers and anticipates their needs by providing excellent products and services;
•   fulfils the potential of its employees;
•   helps the local environment with an emphasis on sustainable development.

An organisation, for which people come first, is based on specific principles which are the cornerstone for everyday thinking and conduct of its employees. These principles are abbreviated PEARL:

Our behaviour is essential in order to follow these principles: we show respect, we are open-minded and result-driven. We believe that conduct in compliance with these values will help us not only maintain trust in our Company but it will also serve as a point of reference for our existing and new clients.

That is why all the policies described in this Code of Ethics are tied to the aforementioned principles and values of conduct.

P / PERFORMANCE

E / EMPOWERMENT

A / ACCOUNTABILITY

R / RESPONSIVENESS

L / LOCAL EMBEDDEDNESS

Respect:

We show respect to our customers. Showing respect means treating all people as equals, transparency, appreciation for people based on what they do and who they are, in particular, however, based on the dignity of each individual. Respect is always mutual. It is not only required but it must be always shown.

Responsiveness:

We listen to our clients, employees and everyone we deal with, we identify their needs and make every effort to fulfil them. Responsiveness means anticipation and swift and responsive behaviour based on suggestions, influences, requests and/or efforts. Responsiveness also means interest, acceptance, generosity, impartiality, observation, an open mind, helpfulness, tolerance and understanding. It implies the “we are all in the same boat” feeling and cooperative behaviour.

Results driven:

We strive to achieve goals for our customers, employees and organisation. We keep our promises!

As part of our results-orientation, we focus on meeting objectives and achieving results in accordance with the required assignment, deadline, cost and quality. Procedures must be respected which, however, does not excuse poor performance. Cooperation improves the ability to achieve results. A results-driven person or organisation focuses on achieving specific and measurable objectives and continuous improvement.

Scope and binding nature of the Code of Ethics

This Code of Ethics is binding on all employees of the Company. It is the minimum set of rules that all employees are required to follow.

The Company is entitled to monitor compliance with the Code of Ethics and regularly evaluates the behaviour of individual employees in relation to the Company's values. Non-compliance with any standard in the Code of Ethics may, after impartial assessment, lead to disciplinary action in accordance with applicable labour laws.

PERFORMANCE

Employees strive to achieve excellent results in all tasks, combating below-average performance. We are customer-oriented. Through impeccable execution, we are constantly improving the quality of our products and services so that they exceed our customers' expectations.

Working hours

The long-term success of a company depends largely on the high work efficiency of its employees. The Company creates such conditions for its employees to ensure that they can perform their work properly during working hours.

Employees must use working hours efficiently and perform only activities that benefit the employer. Such activities are prescribed by labour laws and internal regulations.

Addictive substances affecting performance

The consumption of alcoholic beverages, use of narcotics and other addictive substances during working hours may pose a risk to health or life, significant damage to the Company's reputation or major financial damage.

Employees must not work under the influence of narcotics, psychotropic and other addictive substances or alcohol.

EMPOWERMENT

Our management style encourages the creativity of every employee and supports their cooperation. Employees have enough space to create such procedures and rules that convince our customers of the high level of our services.

Business conduct

In order for a company to be successful in business, it creates and supports a strong entrepreneurial spirit. The Company also encourages and values creativity and initiative. Therefore, employees must base their actions on sound business thinking and act as if they were the owners of the Company. Such conduct will benefit the Company financially in the long term.

Initiative

To succeed in a competitive market, a company needs to have highly efficient and effective processes in place. That is why we take a proactive approach to suggestions for improving existing work processes. New ideas promote change. All employees can openly express their opinions and their opinions are taken into account.

Compliance with the entrusted powers

In business relationships, the Company is always represented by a specific employee who deals directly with the customer and creates a long-term business relationship with the customer. All signing, decision-making and approval authority and business transaction restrictions must be observed. An employee may execute, decide on or approve on behalf of the Company only such transactions for which they have been granted approval authority.

ACCOUNTABILITY

Employees assume 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. We publish the results in a transparent manner.

Compliance with the rules

The Company can only follow the rules that regulate its business if its employees follow the rules that regulate their work. The Company requires compliance with all applicable legal and internal labour regulations and conducts ongoing monitoring of such compliance.

The employer informs employees about applicable internal regulations and allows them to view these as well as other regulations, for example on the intranet.

Conflict of interest

The company expects its employees to be able to clearly distinguish between their professional and private lives and to always act in such a way as to maintain their independence and avoid conflict of interest. Employees must not engage in deals or transactions in which they have a direct or indirect personal interest and which could lead to a conflict of interest. Employees are required to refuse any intervention, coercion, influence, wish or request that could jeopardize the impartiality of decision-making in matters of customers or business partners. No relationship between employees other than a purely work relationship must interfere with the normal work performance of the employee or team.

Protecting the Company’s assets

The Company provides employees with various types of communication tools to allow them to work efficiently (e.g. computers, phones, Internet and data access, etc.). Such tools must be used only in relation to the work duties for which they are intended. Unless otherwise provided by internal regulations, the Company’s assets may be used only for work purposes; any resources provided may only be used in accordance with the law. All employees are required to keep their workplace and its surroundings clean and tidy.

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 and clients cannot be discriminated against in relation to the products and services offered, access to employment, employment conditions, education, career advancement or classification into job positions.

Private business outside working hours

The Company respects private activities of employees outside working hours. However, it is possible that the entities in which employees will participate will have a business relationship with the Company that constitutes a conflict of interest. Therefore, business activities (including mandates) performed outside the employment relationship with the employer must comply with applicable laws, the employment contract and the internal regulations of the employer. Employees are not allowed to engage in business activities that would or could lead to a conflict of personal interests and the interests of the group. The Company must be immediately informed about any private business activities.

Data protection and confidential information

Customer relationships are based on mutual trust and confidentiality. The Company’s activities is partially based on the protection of confidentiality customer data. Decision-making is based on complete and true data.

All information about customers or business partners of the Company obtained in the performance of activities is subject to an obligation of confidentiality. Such information must be treated as confidential. Employees must protect all internal information and customer and business partner data against unauthorised use, disclosure, alteration or destruction. Such data may be used only for the purpose for which they were obtained. The protection of confidential data applies to all data carriers regardless of their form. Employees must not enter false or misleading data into the group's information systems and must not conceal any data relevant to decision-making. Employees must not allow unauthorised persons to access the Company’s premises or information systems. Employees must comply with legal and internal regulations on confidentiality, handling and processing of personal data. The Company protects all data and personal data of its employees in accordance with applicable laws and regulations.

RESPONSIVENESS

Employees perceive and swiftly and open-mindedly respond to suggestions, requests and efforts of the management, colleagues and our customers.

Culture and ethical behaviour

Proper and ethical conduct of each employee affects the Company's reputation. It contributes to a positive corporate culture and influences the personal motivation and performance of each employee. We always expect every employee to comply with the PEARL principles.

The Company places great emphasis on good manners. Behaviour in the workplace must not disturb others or endanger the health and safety of others.

In accordance with the laws and internal regulations regarding prevention and intervention, all employees are prohibited from:

•   exerting inappropriate pressure or influence,
•   making offensive remarks,
•   acting in a manner that undermines the integrity or dignity of other colleagues

at work,

•   colluding against other colleagues,
•   bullying, harassing or sexually harassing colleagues,
•   abusing one’s position in relation to its colleagues.

The Company’s reputation

The public’s perception of the Company also affects the behaviour of the Company’s employees. A professional approach in all activities is an expression of respect for the Company’s reputation. Employees must not abuse the Company's reputation or their position in the Company to promote their private interests, opinions or the interests of third parties.

Customer orientation

Since the Company strives to build long-term relationships with its customers, its approach is professional, exhibiting sufficient skills and know-how, and is characterised by openness and respect for others. Such conduct is expected of every employee. The Company's goal is to treat every customer honestly and fairly in all areas of the relationship. That is why complete and accurate data are available to our customers. The Company makes sure that the conditions and conduct are always transparent and understandable for the customer.

Team spirit and cooperation

The success of the Company as a whole largely depends on the quality and level of communication and cooperation between employees. The Company expects a friendly and open approach to colleagues, respect and team spirit building from its employees. It is necessary to communicate information that could be important to others, always with regard to compliance with other rules, such as maintaining the confidentiality of information.

Employee needs and professional development

The Company understands that the motivation of its employees is determined, among other things, by the extent to which their individual needs and requirements are met. Through its managers, the Company monitors such needs and requirements, offers its employees the opportunity for professional development and strives to fulfil their reasonable wishes, taking into account the nature of work and technical and operating conditions to allow the employees to perform well at work.

The Company supports the initiative of individuals directed at their further development and offers employees the opportunity to acquire all the knowledge they need to perform their work. In addition, the Company supports initiatives that promote employee motivation, such as working from home, a wide range of opportunities for personal development, programs for parents, etc.

LOCAL EMBEDDEDNESS

As employees, we are socially responsible. We follow local rules and regulations. We act environmentally friendly. We welcome the diversity of our customers, cooperate and create long-term client relationships.

Corporate social responsibility

The Company promotes corporate social responsibility. It is always necessary to apply the group's policies and statements regarding corruption, human rights and environmental protection. The Company respects, promotes and applies throughout the Company principles on which universal human rights are based.

Public perception of the Company

When expressing our opinions publicly and communicating with the media, the Company’s principles and values must be respected. As used herein, media means traditional media (radio, TV, press, etc.) as well as new and social media (e.g. text messages, Internet, chat, blogs, discussion boards, the virtual world of "Second Life" and social media such as Facebook, Netlog and other).

Activities outside the Company

The Company welcomes its employees’ involvement in sports, culture, scientific research, hobby organisations etc. in their free time. However, in such activities, the employees must under no circumstances act as employees of the Company. This also applies to any political or religious activities.

PROMOTEus s.r.o. does not promote political, religious or any other ideological agitation in the workplace or towards customers.

Closing

Conduct in accordance with this Code is the foundation of the successful operation of our Company. In case of any unclarities or doubts, employees can contact their supervisors.

Violations of the ethical standards described above cause harm to the Company and its employees. Any suspected material violation of the law, a regulation or ethical standard must be reported to the supervising manager.