CODE OF CONDUCT

Our fundamental ethical values

Integrity

Our behaviour towards all stakeholders (customers, owners, employees, suppliers of labour and materials, government and regulatory authorities, competitors, media), and towards society as a whole, is impeccable.

Awareness of responsibility

We fulfil our commitments and are personally responsible for our actions. We only promise what we can keep. We do not mislead our partners.

Honesty

We deal with stakeholders courteously and in line with our interests. We support equal opportunities and create an environment where honest behaviour is the norm and harassment of any kind has no place.

Compliance (Compliance with standards and regulations)

We recognize the importance of and comply with all relevant laws, internal and external regulations, guidelines and standards. We expect our managers to behave in an exemplary manner, and we are committed to creating quality conditions for monitoring and compliance with legal norms and regulations.

Transparency

We maintain a constructive, transparent and open dialogue with our partners based on mutual respect and professionalism.

Purpose and scope of validity

The Code of Conduct is a clear summary of the common principles of NEXO HB, intended for management and our employees. Our Code of Conduct is intended to prevent dishonest behaviour and support the values ​​and principles that are listed in the following chapters.

Although NEXO HB's guidelines, instructions and manuals are not part of the Code of Conduct, they are based on the values and principles contained in this document.

Members of management, senior managers and all employees are expected to respect these values and principles.

General principles

The law and standards of conduct

NEXO HB complies with applicable regulations and other basic rules in both Czech and European legislation, or the legislation of countries where the company supplies its products, and it is fully committed to adhering to the ten principles of the UN Global Compact initiative.

NEXO HB also supports the dissemination of the principles contained in the code of conduct issued by the International Chamber of Commerce under the title 'ICC Rules of Conduct and Recommendations for Combating Extortion and Bribery' and 'Combating Corruption - ICC code of conduct for business' as amended.

Business principles

In order to meet our responsibilities, we aim to generate profit from our business, maintain a strong financial base and keep our risks at an appropriate level. However, profit must never come at the cost of violating legislation or standards of conduct.

Responsibility

Our responsibility applies to the following areas and pursues these goals:

• Responsibility to customers: Our activities are focused on meeting the legitimate requirements and expectations of customers. In order to meet market demands, we must be accommodating to our customers, highly professional, willing to innovate and maintain competitive prices. We share information and experience with our customers openly and guarantee them the necessary level of discretion and confidentiality.
• Responsibility towards employees: In achieving our company's goals, we rely on the diligence and professional competence of our employees. We support their personal development by offering education and further training, providing the necessary information and suitable working conditions. Our employees actively inform themselves. Their own goals and the goals of the company must be in line, and the interests of the company must come first for them.
• Responsibility to the owner: We handle the owner's money responsibly and strive to ensure stable returns. We implement a transparent information policy and strive for high-quality and responsible business management.
• Responsibility towards suppliers and subcontractors: In ensuring the quality and profitability of our work, we also rely on the experience and capacities of purposefully selected suppliers and their employees.
• Responsibility towards regulatory and governmental authorities: We strictly comply with applicable laws, regulations, guidelines, standards and customs of the countries in which we operate.
• Responsibility towards our business partners: Our prices, services and the quality of the products and services we offer speak for themselves. We deal with all our business partners honestly; all our employees are obliged to be honest and transparent in concluding contracts, setting prices and invoicing, and they also act honestly and openly in all phases of placed orders, ensuring that the promised guarantees are reliably met.
• Responsibility towards the media: We recognize the function of the media; we communicate with journalists and support them in their task of objectively reporting on our society.
• Responsibility to society: We respect human rights and support public benefit activities. We follow applicable law and support fair competition. We are aware of our responsibility towards the environment. In providing our services, we strive to save energy and raw materials, and to reduce emissions and waste.

Confidentiality of information

We keep business and trade secrets confidential. The above principle also applies to other information that SMR PLUS, its contractual partners and customers are interested in keeping confidential. Such information may not be provided to unauthorised persons without the consent of the person authorised to decide on the lifting of confidentiality. This obligation continues even after the termination of employment or another contractual relationship.

Sustainable development

We always keep environmental protection, resource efficiency and social issues in mind when making our business decisions and managing our resources.

Social and community commitments

We welcome our employees' social engagement, where appropriate. We support selected humanitarian, social, non-profit, educational and cultural organizations and institutions.

The company's management as an example

The company's management must set an example for others. The behaviour of the company's management and executives must be impeccable. Impeccable behaviour in the workplace means honesty and fairness in dealing with employees, customers, suppliers, competitors, authorities and the public. The integrity and good reputation of the company are of paramount importance to our success.

Principles of personnel policy

Competence of our employees

The professional ccompetence of our employees is important for achieving our company's goals. We support and manage the personal and professional development of our employees through regular interviews and open communication, and ensure adequate information for employees and suitable working conditions. The company ensures a safe and healthy working environment, including the provision of drinking water, a break room, appropriate safety equipment and facilities. The safety and health of our employees is our top priority.

The relationship between employer and employee is based on the following pillars:

• Shared knowledge that adherence to ethical and legal standards in business is in the interest of both the company and its employees;
• Creating an environment that is attractive to qualified workers supports them;
• Equal opportunities regardless of race, nationality, gender, sexual orientation, religion, origin, disability, age, social status, political affiliation or belief;
• A working environment free from discrimination, harassment, psychological and physical pressure and verbal abuse of workers or repression;
• We strongly condemn forced labour, child labour, and all practices that exploit people or expose them to dangerous conditions;
• An 'open door' policy that allows all workers access to senior management;
• A corporate culture with a motivating and competitive remuneration system and regular fair and objective employee evaluations, taking into account the employees' contribution to achieving the company's goals, their work in a team and their adherence to the values and principles of the Code of Conduct. The remuneration paid for work must meet legal requirements and regulations.

As part of further education at NEXO HB, training events are organized in close cooperation with internal and external experts to meet the company's needs so that all employees can continue to receive the best possible support in fulfilling their tasks, as well as professional and methodological know-how. The extensive range of training courses aimed at specific target groups includes basic, professional and methodological training.

Respect and honesty towards managers, colleagues and employees

The quality of cooperation between managers, colleagues and employees is of fundamental importance for the successful functioning of the company. Integrity in mutual dealings, respect and openness towards everyone, and decent and honest conduct in mutual communication ensure the quality of the corporate culture and decisively influence the presentation of the company to the public. The aforementioned behaviour, which is guaranteed by appropriate institutional measures, establishes mutual trust. We undertake to resolve any disagreements objectively, with respect for the persons involved and in accordance withour company's fundamental values ​​and visions.

Social responsibility for our employees

NEXO HB supports and assists its employees in resolving their difficult life situations with an effort to mitigate social impacts, especially after work and leisure accidents, long-term illnesses, deaths, disasters and job loss.

Responsibility of the company's management and its employees

Every member of the company's management, every superior and every employee is responsible for adhering to the principles set out below:

• compliance with laws, guidelines, regulations and internal guidelines of NEXO HB, including the values and principles of the Code of Conduct;
• knowledge and conscientious adherence to guidelines, manuals and common business practices in the assigned area;
• asking questions and intervening in the event of violation of standards of conduct;
• taking part in teamwork and contributing to achieving common goals to the best of their abilities;
• helping create workplace relationships based on trust, professionalism, high work commitment, respect and self-esteem;
• acting in good faith and loyalty, in accordance with the principles of responsibility, with due care and expertise, without misrepresentation of facts;
• acting objectively while maintaining personal judgment;
• protection of NEXO HB's assets and resources, support of their effective use, and adoption of appropriate organizational measures, including monitoring of their compliance. The measures taken may not give rise to liability NEXO HB's liability
• honest and ethical behaviour, aksi in the event of an actual or potential conflict of interest;
• honest behaviour towards customers, suppliers, competitors and other associates, never benefiting at the expense of another person from actions that would be contrary to the law or this Code of Conduct;
• reporting violations of the law or NEXO HB's policies and procedures so that such matters can be addressed appropriately;
• regular participation in training courses offered by NEXO HB;
• demonstrating of a manager's competence through clear customer orientation, personal example, reliability and keeping promises, adequate control of subordinates, control of compliance with legal standards and regulations, and ensuring working conditions that enable employees to do their best work.

Communication

Principles

The company's management must ensure employee compliance with applicable laws and regulations. All employees are regularly informed about important legal regulations, and particularly the principles contained in this Code of Conduct. Compliance with the listed principles is strictly required.

We also place great emphasis on professional, correct and timely communication with our partners and participating institutions. The information we provide to authorities or the public is complete, true, concise, objective, up-to-date and easy to understand in all material aspects.

We undertake to comply with applicable laws in implementing these principles.

The following principles must be adhered to in communication:

• Our communication must be open, transparent and proactive.
• Our employees must be informed before our other stakeholders, or at least at the same time as them.
• We have clearly defined contact persons for communication with the media.
• We generally don't provide any information about customer relationships, matters concerning individual employees, competition, or routine investigations.
• We do not comment on rumours and similar false information.

Specific ways in which the content of the Code of Conduct is communicated

NEXO HB has taken steps to ensure that all employees are aware of the principles of the Code of Conduct, promoting compliance in daily practice.

• The Code of Conduct is available to all employees in the company's human resources department at any time for viewing or studying. In case of any ambiguities, the principles are explained to employees individually.
• Employment contracts are concluded on the basis of the Code of Conduct. According to the employment contract, each employee must become acquainted with applicable regulations, compliance with laws and company guidelines, and the documents provided.
• All applicable guidelines and regulations are available to employees at the HR department of NEXO HB.

Contact persons in the system for obtaining confidential information from employees

The principles of this Code of Conduct could not be implemented without the support of employees. This is why contact persons have been appointed within the system for obtaining information from employees.

These persons may be contacted by all employees of our company, as well as by third parties, such as subcontractors and their employees.

The ombudsman is available to every company employee; he helps them with labour-related issues that have not yet been resolved within the company, as well as with problems of discrimination, unfair remuneration and sexual harassment. The same applies to questions in matters of Business Compliance (corruption, antitrust law, money laundering, consulting agreements, business partner due diligence, donations and sponsorship, etc.).

The current list of whistleblower contacts within the whistleblowing system (personnel structure) is available at the company's human resources department. In addition to the usual reporting channels (telephone, email, fax, anonymous letter, etc.), it is also possible to report any concerns/suspected violations (even anonymously) via a mailbox. All reports will be treated confidentially.

Sanctions

If corporate ethical guidelines or applicable regulations are violated, the necessary organizational measures will be taken and disciplinary and labour law proceedings will be initiated — ranging from a warning to dismissal. Regardless of the criminal consequences, we want to respond adequately to illegal behaviour and prevent it in the future.