CODE OF CONDUCT

1. BASIC REQUIREMENTS FOR ETHICAL BEHAVIOUR, PRINCIPLES OF COMPANY CULTURE

The Code of Conduct is valid in its entirety for all employees of MAS Services, s.r.o. during and outside of working hours as part of their employment relationship. The Code of Conduct defines and regulates relations with all interested parties and formulates the principles of conduct, actions and behaviour of the employees. The Code of Conduct serves as additional material that more closely defines and explains the internal processes and course of business of the company and its employees. It serves as additional material to the Labour Code and the Civil Code, which are priority documents for the company regulating the activities of business entities, as well as MAS Services.

1.1. LEGAL FRAMEWORK AND EMPLOYEES’ CONDUCT

Compliance with the legal regulations is one of the priority principles of MAS Services. All its employees are obliged to act in accordance with the legal framework and to ensure that it does not lead to its violation. This includes compliance with laws and regulations, internal guidelines, ordinances and the contents of this Code of Conduct.

Employees are aware that in the event of a violation of the above, disciplinary consequences arising from the employment contract will be drawn, and in the case of a more serious offense, they may be fined and/or imprisoned.

Every employee of MAS Services behaves honestly, continuously learns, improves and follows applicable laws, regulations and standards. At the same time, each employee is a representative of the company and therefore acts loyally and in such a way as not to damage the company’s assets and reputation.

1.2. RESPONSIBILITY FOR THE GOOD REPUTATION OF THE COMPANY

The company actively participates in making its employees aware the Code of Conduct and takes care of its practical application. The members of the company, especially in their private life, should refrain from speaking, sharing information and content, false information, and anything else that could damage the good name of the company.

It is not allowed to publish any non-public information, especially information marked as internal, confidential or secret, without the express consent of the management of MAS Services, which means that the employee must maintain confidentiality about the internal affairs of the company both during and after the end of the employment relationship.

In the event of proven damage or misuse of the company’s tangible or intangible property (including know-how, leakage of information to the benefit of competitors or third parties, misuse for one’s own benefit, loss and damage to property) due to intentional fault or negligent action, MAS Services may recover damages from the employee, which was created by such an action.

1.3. INTEGRITY AND MUTUAL ACCEPTANCE

The employees create a pleasant atmosphere at the workplace with their appearance and behaviour regardless of age, race, nationality, gender, or cultural customs and religion. Verbal or physical attacks are not tolerated in the workplace during, immediately before and after working hours.

Employees behave in such a way that their behaviour does not appear superior and disrespectful towards their co-workers, on the contrary, they strive to create a unified collective in which every employee is an important member and equal participant.

They respect each other and support each other in the fulfilment of work tasks and tasks that they perform individually or in groups. Together, they create an environment in which each of them can fully fulfil themselves and present their opinion or comments on the given issue. All arising ambiguities and problems are clearly and unambiguously communicated by the employees with the aim of solving them as quickly and smoothly as possible.

The company also complies with Directive 2010/41/EU of the European Parliament and the Council of 07 July 2010 on the application of the principle of equal treatment between women and men, the so-called gender directive, by which the company does not differentiate between men and women in terms of treatment, remuneration and performance of work, advancement in employment or similar preparation for employment performance.

1.4. RELATIONS WITH PARTIES INTERESTED

MAS Services interacts with various groups of persons or companies within the scope of its activities, which directly or indirectly influence its activities and which, on the other hand, are directly or indirectly influenced by their activities. Most common groups with which the company interacts and with which relations are regulated by this Code of Conduct are as follows:

• relations with the applicants – we value each potential employee and treat them as we treat others. We do not make differences in approach and try to fully meet their requirements. Every employee, whether in person or during a telephone conversation or through email communication, does not use vulgar or unprofessional words, expresses themselves professionally and do not provide clients with misleading or deceptive information.

• relations with the partners – the company treats its partners with respect, communicates openly, acts justly, politely and fairly. When communicating with the partners, employees behave in such a way as not to degrade the good name of the company in any way, and they act and make decisions that lead to the improvement of the company in all directions.

• relations with the competitors – as the company’s business activity is oriented towards a branch with many companies, it enters a competitive environment. The company’s employees do not act or behave in any way in order to lower the level and tarnish the good name of other competitors. We act fairly towards our competitors and in the case of interaction we act openly and friendly. We condemn and do not accept any false and intentional promotion of ourselves over the competitors. If an applicant or employee decides in our favour over the competitor, it is purely their decision and we as a company did not in any way force or persuade them to this decision. Our actions are straightforward and honest, and therefore in such cases we do not have to fear that we have not acted correctly or in accordance with this Code of Conduct.

• relations with the environment – as a company, we are fully aware of our responsibility towards the environment and the ongoing climate crisis. Our business cannot match the production and emissions of large corporations, but even with small steps we try to contribute to the improvement and reduction of the company’s impact on the environment. The company’s employees save nature and its resources, for example, by not unnecessarily printing almost all necessary documents that do not need to be physically archived in this form. If it is necessary to keep the necessary documents in printed form, the company uses recycled office paper, which is a more ecological choice. Also, during the summer period, the company does not unnecessarily waste electricity in the office premises and uses energy-efficient office equipment.

• internal relations among the employees – employees try to create a pleasant atmosphere at the workplace and outside it, in which everyone feels comfortable and satisfied. Colleagues respect each other and help each other in the performance of various tasks and duties as part of their work. The company makes sure that good cooperation prevails among employees and that good and strong relationships are built between them. Therefore, it regularly holds various teambuilding activities and meetings, during which it gives every employee the opportunity to realize themselves and supports meeting even outside of working hours in order to build better intra-company relations.

1.5. CONFLICT OF INTEREST, BRIBES AND GIFTS

This part of the Code of Conduct is very important. Some of its parts have already been mentioned, but here we emphasise them again. Our employees are required to act in loyal, transparent and acceptable behaviour and conduct.

Employees of MAS Services may not accept or provide bribes in any form, or intentionally enter into situations that could lead to such situations. Employees are obliged to immediately report to their direct supervisor any possible form of corruption they witness.

Each employee is also obliged to prevent a conflict of interests. It is forbidden to misuse confidential or other information obtained while working at MAS Services for their own business activities or for the business of employees’ acquaintances. The company avoids such behaviour, but in the event of its occurrence, it is necessary to draw adequate consequences and proceed in accordance with the relevant internal regulations, laws and decrees.

1.6. PERSONAL DATA HANDLING

MAS Services handles personal data in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in the processing of personal data and on the free movement of such data and Act No. 18/2018 Coll. on the protection of personal data and on the amendment of certain acts. The personal data protection policy, the obligations of the intermediary, the MAS Services company, and the rights of the data subject are set out in the Personal Data Protection Policy located in the main menu on the MAS Services website.

The company’s employees are cautious and work with the utmost caution in providing information that could be in violation of the Personal Data Protection Act.

1.7. FINAL PROVISIONS

This Code of Conduct is the property of MAS Services, s.r.o. and has become effective as of 17 August 2016, when the company started its business activity. All information provided herein is correct and applied by the company. Before concluding the employment contract, every employee of the company is obliged to study the Code of Conduct in detail and then, in case of identification with the information provided in it, sign the Employee Consent form on acceptance of the Code of Conduct.