CODE OF ETHICS OF
SYNCHRONIX, A. S.

1. Legal compliance
SYNCHRONIX, its employees, agents, and business partners commit to conduct themselves in accordance with valid Slovak law and not to expose the SYNCHRONIX company to the threat of criminal liability of a legal entity for illegal actions.

2. Protection of confidential information and personal data
SYNCHRONIX takes care to preserve the privacy of people and the confidentiality of information about its business partners, and therefore ensures the consistent protection of their personal data and confidential information by appropriate and adequate technical and organisational means. Only personal data that is required by law, with the consent of the person concerned, is collected for the specified purpose and to the extent necessary to achieve the purpose of its processing. In connection with the protection of personal data and confidential information, a number of security measures have been created to prevent loss, deletion or unauthorised access and possible misuse.

3. Securing data and systems
SYNCHRONIX is committed to complying with strict information security rules, and thus ensuring the confidentiality and integrity of collected, processed and stored information during the entire period of its use or storage. All employees and agents working with SYNCHRONIX system infrastructure only do so after completing information security training and only in the scope of the access rights assigned to them.

4. Responsible keeping of accounting records
SYNCHRONIX commits to keeping accurate and reliable accounting and other records relating to the company, which give an exact statement about its condition and performance and are important for the proper fulfilment of obligations towards customers, suppliers, creditors, employees and other entities with whom it does business or otherwise cooperates.
Exaktné účtovné záznamy sú nevyhnutné aj pre manažment, akcionárov, veriteľov, plnenie povinností voči inštitúciám, akým sú napríklad príslušný daňový úrad či Sociálna poisťovňa. Akékoľvek nesprávne a zavádzajúce vstupy do účtovných záznamov sú prísne zakázané a môžu viesť až k trestnej zodpovednosti konkrétneho jednotlivca či samotnej spoločnosti SYNCHRONIX.

5. Respect for basic human rights
SYNCHRONIX rigorously respects the human rights of all stakeholders and requires adherence to such human rights from all counterparties.

Basic human rights include:
the right to life, the right to human dignity, the freedom and security of persons, the right to justice and favourable conditions at work, the right to a fair wage and an adequate standard of living, the right to health protection, the right to form and join unions, the right to collective bargaining, the right to prevent all forms of forced and compulsory labour, the right to prevent child labour, the right not to be discriminated against, the right to freedom of opinion.

6. Favourable working conditions, environmental protection and safety
In connection with its commitment to protect and adhere to basic human rights, SYNCHRONIX commits to creating favourable working conditions for its employees, to maintaining a safe working environment, and to protecting the environment as much as possible within its activities. SYNCHRONIX’s objective is to provide its employees and all other persons conducting work within its premises with a working environment in which risks that put their health or lives at risk have been eliminated.
SYNCHRONIX does not tolerate any form of forced, compulsory or child labour, withholding of any wages, refusal of sick leave, evasion involving statutory contributions to national insurance schemes and similar unethical employment practices.

7. Non-discrimination, equal opportunities for all, respect and dignity
SYNCHRONIX does not tolerate any form of discrimination and diversity is one of its leading values, which allows the company to move forward and meet the diverse demands of its customers.
The internal work environment and SYNCHRONIX’s activities directed externally towards third parties are built on mutual trust, respect and dignified treatment. SYNCHRONIX expects such treatment from its employees, agents and business partners and does not tolerate humiliating, insulting or intimidating behaviour.
Sexual harassment/violence and immoral conduct are considered serious violations of human dignity. Certain forms thereof may be qualified as criminal acts and will not be tolerated by SYNCHRONIX.

Discrimination is defined as:
discrimination based on race, colour, sex, age, language, religion, political or other opinions, ethnic, national or social origin, property, gender, sexual orientation or any status, including marital or parental status.

Immoral conduct is defined as: production, dissemination and storage of child pornography, endangering morals by the production, purchase, import and subsequent distribution of pornography and its publication on various media, sexual abuse of persons under 15 years of age, including the proposal of a personal meeting through an electronic communication service with the intention of committing sexual abuse.

8. Corruption and bribery
SYNCHRONIX does not tolerate corruption or bribery in any form. Unjustified favouritism does not fit into its corporate culture, therefore SYNCHRONIX commits to support its employees in reporting their suspicions of various forms of corruption.

Corruption is defined as:

• a promise, offer or provision of a bribe to another, directly or through an intermediary, so that they act or refrain from acting in such a way that they violate their obligations related to their employment, profession, position or function,
• a promise, offer or provision of a bribe to another directly or through an intermediary in connection with the procurement of a matter of general interest,
• a promise, offer or provision of a bribe to a foreign public official or other person directly or through an intermediary in connection with the performance of their official position with the aim of obtaining or retaining an undue advantage.

Indirect corruption is defined as:

a promise, request for a bribe or acceptance of a bribe directly or via a third party in exchange for exerting influence over the person legitimately exercising authority in some capacity.

Bribery is defined as:

• a promise, request for a bribe or acceptance of a bribe directly or via a third party so that they act or refrain from acting in such a way that they violate their obligations related to their employment, profession, position or function,
• a promise, offer or provision of a bribe to another directly or through an intermediary in connection with the procurement of a matter of general interest,
• a promise, offer or provision of a bribe to a foreign public official or other person directly or through an intermediary in connection with the performance of their official position with the aim of obtaining or retaining an undue advantage.

9. Gifts and hospitality
SYNCHRONIX only accepts the giving and receiving of gifts when the items involved do not have a high material value and the purpose of their giving and receiving is not corruption. Gifts and hospitality must always be given or received without creating the impression that they are intended to influence an impartial decision.

A gift is defined as:
monetary/non-monetary items (discounts on products or services, equipment, use of vehicles and recreational facilities, gift vouchers, travel expenses, tickets to various events, business lunches/dinners, etc.).

10. Fraud and embezzlement
SYNCHRONIX is committed to zero tolerance for fraud and all employees are responsible for acting in accordance with the applicable rules and for being prudent in the event of even the slightest hint of fraud.

Fraud is defined as:

• enriching yourself or others to the detriment of someone else’s property by misleading someone or taking advantage of their mistake,
• special types of fraud are credit fraud (inducing a loan as a result of misrepresenting the fulfilment of the conditions for granting and repaying the loan), insurance fraud (inducing insurance payment by misrepresenting the fulfilment of the conditions for its provision), subsidy fraud (obtaining a subsidy, contribution or other funds from the state budget as a result of misrepresentation regarding the fulfilment of the conditions for the provision of such funds).

Embezzlement is defined as:

Appropriation of entrusted property of another party to the detriment of their property.

11. Economic competition, competitors and international sanctions
SYNCHRONIX operates in compliance with the rules of fair competition. Any unfair business practice that could harm a competitor is prohibited. Likewise, illegal/cartel agreements between competitors that distort free and fair competition to obtain or maintain a monopoly are not permissible. Any advantage that
SYNCHRONIX obtains may only derive from the exceptional quality of its products and services, and never from unethical or illegal behaviour towards competitors. Doing business/providing services to countries or individuals subject to international sanctions is prohibited.

12. Money laundering
SYNCHRONIX is committed to enforcing the prohibition of money laundering and does not engage in business activities that are aimed at supporting or financing criminal activity or terrorism.

Money laundering is defined as:
hiding illegal funds and assets and using them in a way that conceals their illegal origin or the purpose of using them to commit criminal activity or terrorism (loans, borrowings, transfers to third parties, bank transfers, etc.).

13. Conflict of interest
SYNCHRONIX employees are obliged to refrain from any action that would interfere with their ability to make impartial and objective decisions on behalf of SYNCHRONIX and that could harm the reputation or interests of SYNCHRONIX.

14. Protection of trade secrets, business information and intellectual property
SYNCHRONIX collects data in a strictly legal manner and uses only publicly available sources of information to evaluate competitors, customers and suppliers. All employees are responsible for the confidentiality, integrity and accessibility of data obtained and used by SYNCHRONIX within its business activities, regardless of their form or storage location.

Intellectual property is primarily defined as:
patent, copyright, computer software, technical solution, trade secret, trademark, logo, new product, product design, written work (including on the website), etc.

SYNCHRONIX’s intellectual property is its property and action must be taken to prevent its use by others without permission.

15. Protection of company property
SYNCHRONIX employees are obliged to protect company property and to use it economically, carefully and efficiently.