Code of Ethics

Commerce Media s.r.o.

1. INTRODUCTION

1.1 The Code of Ethics is a set of moral requirements, rules and principles that every employee, including the management, should follow in relation to both the internal and external environment. It describes possible violations, provides guidance in identifying and resolving ethical issues, and explains how to report ethical violations.
1.2 The Code of Conduct is a tool that raises the standard of employee conduct, promotes the development of ethics and corporate culture, helps to improve interpersonal relations in the workplace and also contributes to the maintenance of the Company's reputation.
1.3 The Code of Conduct is binding on all employees of the Company. The Company's management and employees in management positions shall conduct themselves in such a way as to set an example in applying and observing the Code of Conduct.

2. BASIC PRINCIPLES

2.1 Equal Opportunity
2.1.1 Relationships between employer and employees and between employees at all levels with each other are based on respect for the dignity and dignity of each person and respect for fundamental human rights. It is the duty of every employee to create an atmosphere of mutual respect, courtesy and trust. Any form of discrimination is prohibited in the Company. Any form of ridicule, threat, intimidation or hostile behaviour, in particular hostile behaviour based on race, colour, gender, nationality, age, sexual or religious orientation or any other morally inappropriate context, both towards another employee and towards a business partner or a third party representative, is unacceptable.
2.1.2 Employees shall not be subjected to acts of psychological or physical violence. No acts of sexual harassment are tolerated. Any attitudes or behaviors that discriminate against and harm an individual's personality, opinions or preferences are rejected. There are no differences in recognition, opportunities for job advancement, allocation of financial rewards, or other barriers based on gender, religion, or background.

3. EMPLOYEE LOYALTY AND PROTECTION OF THE COMPANY'S REPUTATION

3.1 Employee reputation and loyalty is a fundamental and valuable business value of the Company. The management of Commerce Media Ltd. creates the conditions for equal communication and requires close cooperation between employees, subordinates and supervisors and between departments.
3.2 Each employee not only represents himself/herself by his/her behaviour, conduct, speech and appearance, but also acts as a representative of the Company. It is the duty of every employee to uphold the good name of the Company and to act in a manner consistent with the Company's reputation.
3.3 An employee shall ensure that he/she is at all times dressed and attired in a manner appropriate to his/her work and to the position he/she holds.
3.4 The employee shall also take care to maintain adequate personal hygiene and to keep the work environment clean and cultured to the extent that it does not in any way restrict other employees.
3.5 The employee shall treat everyone with consideration, in a manner appropriate to their social abilities and communication skills. Commerce Media Ltd. employees are required to provide timely, complete, unbiased, truthful and understandable information about products and services.

4. RELATIONS WITH INTERNAL AND EXTERNAL ENVIRONMENT

4.1 Employee and co-worker relations
4.1.1 As an employer, Commerce Media Ltd. recognizes that employees are of the highest value to the Company and is committed to achieving the best possible results by encouraging and rewarding quality performance. Accordingly, the Company creates an environment for its employees that provides conditions for personal and professional growth, while expecting high personal standards from its employees in work performance, employee relations, and health and safety.
4.2 Relations with customers and suppliers
4.2.1 Commerce Media s.r.o. highly values good customer relations and therefore adopts an honest, fair and responsible approach towards its customers and suppliers, considering the satisfaction of their needs and interests as a prerequisite for a successful and lasting business relationship.

5. ADHERING TO THE CODE OF CONDUCT AND ENSURING COMPLIANCE

5.1 All employees of the Company are aware that breaches of the Code of Ethics undermine trust in the Company. Senior employees are expected to actively participate in the implementation and enforcement of the Code of Conduct. All employees are expected to familiarize themselves with the Code of Conduct and to apply and adhere to the principles set forth in the Code of Conduct in the day-to-day performance of their work.
Employees may report violations of the Code of Conduct to management anonymously or request absolute confidentiality. Management is committed to maintaining confidentiality with respect to the identity of the individual making the report and, until the report is clarified, with respect to the identity of the person to whom the report is directed. An employee who reports a suspected violation of this Code will not be sanctioned or disadvantaged in any way. However, any patently purposeful false report made with the intent to harm another person will be considered a violation of the Code of Conduct.

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