Code of Ethics

PRAGUE, MARCH 9, 2020

1. INTRODUCTORY STATEMENT

The Premiot Group is a very diversified group both in terms of industry and geography. Compliance with legal regulations and ethical rules is our priority.

The purpose of this code of ethics is to establish the basic principles and rules of ethical behavior by which the Premiot Group is guided, both in relation to our business partners, customers and investors, as well as within the company between individual employees. This code of ethics is binding not only for all companies in the group, but also for all employees employed within this group.

2. PREMIOT GROUP IN RELATION TO EMPLOYEES

When selecting employees and co-workers, we fill positions with workers with appropriate professional and moral competence. The basic principle is the principle of equal treatment with the exclusion of discrimination in terms of gender, race, religious or political beliefs, sexual orientation or health or social differences. Setting and following the rules of the personnel policy is the cornerstone of preventing actions contrary to legal regulations.

The goal is to create a safe and pleasant working environment where everyone respects each other and works together to achieve the group's goals. Therefore, it is the basis of compliance with basic ethical and moral rules. A working environment based on these principles enables the achievement of corresponding results. Managers are responsible for the results of their assigned area within the group and have the authority to control the activities and results of their subordinates. At the same time, senior employees must be a work and moral role model for their subordinates.

Within the group and outside it, we always act with respect and loyalty towards the group, its owners, investors, but also other employees and collaborators, so as not to tarnish their good name. However, this should not prevent anyone from reporting unethical or illegal behavior if they witness it.

2.1 Our Workplace Obligations
The basic duty of a Premiot Group employee is to support the group's prosperity and development. We treat the group's property with all respect and protection, protect it and use it in accordance with the principles of economy and, above all, the interest of the group. We use working time efficiently and productively.

We do not use the group's property for purposes that are not related to the content of our work, unless otherwise stipulated by internal regulations.
We use working hours only and exclusively for the interests of the group and not for our own business or activities unrelated to the group.
We do not use company funds and group property for private purposes.
In the event that an employee or any other cooperating person discovers damage caused in the group, they report this fact to the employee's immediate superior.

2.2 Anti-corruption measures
As a group, we are fully aware that corrupt and any other unfair practices are completely and exclusively socially unacceptable. We act in accordance with the so-called zero tolerance rule.

We note that a bribe is the provision of monetary funds or other material values, information or services and other benefits that are not claimed, and which directly lead to a financial or other advantage. A bribe is not a gift that is provided in accordance with typical market practice primarily for the purpose of representing or supporting the good name of the group. The provision of such a gift or other performance to a third party in a value exceeding CZK 5,000 or the equivalent of another currency must be approved in writing by a senior employee, and expenses related to such a gift must always be recorded, including the identity of the recipient, the reason and purpose of the gift, so that a gift made in this way can always be verified.

We immediately report any suspicion of such behavior to our supervisor or group management so that appropriate measures can be taken.

2.3 Behavior of employees outside the workplace and working hours
The employee is generally obliged to contribute to the dignity and respectability of the Group through honest, fair and decent behaviour, including behavior and demeanor outside of working hours. The employee is obliged to fulfill the assumed obligations. He may only assume a liability or guarantee for another's liability if he is certain of its fulfillment. The employee's statements in connection with his work performance must not be knowingly false.

We are fully aware that we are constantly perceived by those around us and any negative manifestations, even outside of working hours, can lead to a negative impact on the group's name.

We note that even opinions expressed outside the workplace and outside working hours may be considered the opinions of the Group.
We take care of the good name of the group and represent it honestly and representatively.

2.4 Personal data protection
Personal data means all personal data about employees, customers or business partners and investors that the group obtains. We pay close attention to compliance with all regulations for the protection of personal data.

It is the duty of every employee to carefully protect all personal data with which he comes into contact during the performance of his work. He is authorized to provide this data only to persons who are authorized to do so, according to the relevant legal regulations or with the written consent of the person concerned.

It is our duty to immediately report suspected leakage or misuse of personal data to the relevant manager.

2.5 Protection of sensitive and confidential information
The group places emphasis on the protection of sensitive and confidential information not only about the group, but also on the protection of any information concerning employees, business partners and investors.

Employees are obliged to communicate only absolutely necessary information within the scope of their work and when dealing with business relationships. They make sure that part of business relations is the obligation to maintain confidentiality about the information shared.

It is our duty to immediately report suspected leakage or misuse of sensitive or confidential data to the relevant manager.

2.6 Conflict of interest and competition
With respect to our group, as its employees, we try to avoid situations that could lead to a conflict of interest in the event that our private interest could influence our business or professional decisions. For this reason, we ensure effective procedures that can be used to identify potential conflicts of interest. Likewise, our effort is to ensure that the internal system, together with control mechanisms and procedures, serve to identify and resolve potential conflicts of interest.

The employee is entitled to refuse to provide the agreed service if there is an obvious risk that a conflict of interests will arise during the handling of the matter, while always taking reasonable measures to avert serious harm that the applicant for the agreed provision of services is in immediate danger of. It is our duty to immediately report the refusal of the agreed service to the relevant manager and wait for his decision.

3. PREMIOT GROUP IN RELATION TO THE EXTERNAL ENVIRONMENT

3.1 Our customers
The legitimate interests of our customer take precedence over the own interests of the employee and the Group.

Satisfied customers are our primary goal and priority. Based on our priorities, customers can expect the highest level of service delivery, reliability and professional assistance from us.

We do not abuse our customers' trust or any lack of knowledge or experience.
We may not use to the detriment of the customer or for our own benefit or for the benefit of third parties information that we have obtained from the customer or about the customer in connection with the provision of the agreed services.
We fulfill all our obligations to our customers on time and with high quality.
We are obliged to properly inform our customers how the processing of their case is progressing, and to provide them with timely explanations and documents necessary for the consideration of further orders.
We treat our customers equally regardless of age, gender, race, sexual orientation or political or religious affiliation.

3.2 Our investors
The group's aim is to ensure permanent and sustainable growth for owners and investors. According to applicable laws, we respect all rights of investors to receive the necessary information about the group.

3.3 Our business partners
We build relationships with our business partners primarily on mutual respect and trust, transparency and integrity.

We fulfill our obligations towards business partners properly within the set deadlines
In accordance with the contractual terms, we pay our financial obligations on time.
We evaluate business partners in terms of their business aspects and qualities.

3.4 Competition
We conduct our business with respect to the principles and rules of competition. Everything is done transparently. Economic competition is primarily based on the high quality of goods and services offered at appropriate prices.

We do not engage in anti-competitive practices such as deceptive advertising, misleading labeling of services, creating a likelihood of confusion, parasitizing the reputation of another competitor's services, bribing, belittling, comparative advertising, breach of trade secrets, intrusive harassment.
We do not create cartels or conduct negotiations that should lead to distortion of economic competition.
If we provide information to the public, then only on the condition that this information is accurate, not misleading and respects the obligation of confidentiality and other basic values stated in this Code of Ethics.

An employee's active participation in business, the subject of which is not the subject of the Group's activity, but which includes activities falling under the concept of providing similar services, must not be in conflict with this Code of Ethics.

4. FINAL PROVISIONS

This Code of Ethics and all its subsequent modifications always come into force on the day of its publication.