Introduction

The trust of our customers and the public in RAYA-CONSULTING, s.r.o. (hereinafter referred to as “the Company”), i.e. owners, employees, sales representatives depend to a large degree on the professional work of each of them, i.e. their expertise and, last but not least, their behaviour. This trust is based on the continuous observance of legal regulations and all rules within our Company.

Responsive behaviour is also a right at the same time. Every employee and sales representative is responsible, within the scope of his or her competence, for appropriate conduct that is in accordance with the rules set out in this Code of Ethics. We expect our leaders to do even more by ensuring that their code of conduct between their employees and business partners is respected by their exemplary behaviour and leadership.

Definitions:

Co-worker – the word means a person who has a working relationship with the Company;

Sales Representative – the word refers to a person or company having a contractual relationship with the Company under a Dealership Agreement;

Business Partner – The word refers to a person or company having a contractual relationship with the Company on the basis of delivery contract or order.

Purpose of the Code of Ethics

• Establish the principles of ethical behaviour of employees and sales representatives of RAYA-CONSULTING, s.r.o.

• Helping collaborators and sales representatives to comply with them.

• Inform the public about the expected behaviour of co-workers and sales representatives.

• Protect your co-workers and business representatives from attempts to abuse them.

The Code of Ethics sets out rules of conduct and principles that promote professional and responsible operations and which the Company expects from its employees as well as business representatives.

The scope of application of the Code of Ethics

In the interest of the feasibility of a single set of requirements, the Code of Ethics is applicable to RAYA-CONSULTING, p. r. about. in all employment relationships as well as other business relationships (sales representatives).

1. Content of the Code of Ethics

1.1. Ethical standards

Operation of RAYA-CONSULTING, p. r. about. is based on honesty, strict respect for the laws and expectations of the owners, as well as the principles of respect for the individual. The Company’s good functioning, reputation and good reputation are based on the experience, talent, outstanding performance of its associates, as well as the commitment to the company and the acquisition of values ​​that the company confesses in its business. Relationships with our business partners (customers, suppliers and service providers) can only be maintained in the long run with commitment, high level of performance and personal integrity of employees and vendors.

For RAYA-CONSULTING, s.r.o. to meet the expectations of those who trust it, must represent the following values:

• HONOUR,

• OBJECTIVE ASSESSMENT,

• LOGIC RELATIONS,

• HELP CUSTOMERS TO MEET THEIR OBJECTIVES.

1.2. Health and safety

RAYA-CONSULTING, s.r.o. ensures a safe working environment for all its employees. Great emphasis is placed on ensuring that all employees are aware of both safety and environmental regulations. It pays special attention to the protection of workers’ health.

1.3 Equal treatment

RAYA-CONSULTING, s.r.o. treats all employees and business partners with the same respect and caution while taking into account their personality. It creates working conditions without discrimination. It motivates employees and business representatives to build relationships on and outside the workplace in a spirit of openness, trust, trust, mutual dignity and respect, mutual recognition and the principles of mutual support. In order to avoid conflicting situations in mutual communication.

1.4. Privacy

RAYA-CONSULTING, s.r.o. undertakes to maintain the confidentiality of the personal data of its employees, sales representatives and clients. Fully complies with all applicable laws on employee data processing, sales representatives and clients, collecting and retaining only those data that are necessary for the effective operation of the company or are required by law.

1.5 Suppliers, business partners, sales representatives

RAYA-CONSULTING, s.r.o. builds relationships with their suppliers and other business partners on the basis of mutual trust and respect.

Suppliers are selected based on the content of their bids and their previous references, while avoiding any conflict of interest or any possibility to influence selection.

RAYA-CONSULTING, s.r.o. assesses suppliers’ offerings fairly and impartially. The evaluation of individual offers, their evaluation, acceptance and implementation must be strictly professional.

When selecting business partners and resellers, RAYA-CONSULTING, s.r.o. requires the partner to comply with the relevant ethical standards contained in this Code of Ethics. Violation of this policy by your partner may result in termination of the business relationship.

An agreement with suppliers, business partners, traders, persons, organizations can only be concluded on the principle of mutual benefit that management has allowed.

RAYA-CONSULTING, s.r.o. properly processes the confidential business and other information of its partners, sales representatives, suppliers.

1.6 Competitors

RAYA-CONSULTING, s.r.o. promotes fair and open competition. It carries out its activities in accordance with the rules of fair competition and observes the rules of competition law in force. In competition, it relies on the quality and performance of its products and services.

2. Standards of behaviour of employees and entrepreneurs

Employees and sales representatives during their cooperation with RAYA-CONSULTING, s. r. o. they must act according to their best expertise, taking into account the values ​​and interests of society. If they find an error, they should immediately do everything to remedy and ensure faultless condition, eliminate and mitigate the consequences and possible or anticipated damage.

2.1 Legality, compliance

RAYA-CONSULTING, s.r.o. expects all employees and agents to behave in accordance with law, internal corporate policy, company guidelines and interests, and ethical standards.

2.2 Maintaining good reputation

It is in the interest of all employees and sales representatives to maintain good reputation and name of RAYA-CONSULTING, s.r.o. The external perception of the company, the achievement of its professional goals through the work and behaviour of its employees and vendors contribute significantly to the overall image of the company with its partners and customers.

2.3 Offering, accepting and redeeming a business gift for employees

The process of bidding and receiving business gifts, invitations and preference should be given the appropriate attention. Gifts and invitations are allowed only to the extent that their value, determined by the fiscal framework or otherwise, does not affect the person and the decision he has taken. In case of event invitations, it is necessary to determine whether the event is adequate and proportionate to its nature and extent.

Receiving donations from business partners that objectively express their satisfaction, in the form of business gifts, invitations, kindness, provided the management is informed.

Commissions or other payments made to third parties, in particular agents, agents, consultants or other intermediaries, should be proportionate to the activity performed by the beneficiary. Agreements with agents, traders, consultants and other intermediaries, including any adjustments, should be recorded in writing. The conclusion of these agreements is subject to the consent of the management.

Commercial gifts that are in accordance with customs may be accepted to a limited extent but must not jeopardize the reputation of the company or lead to a conflict of interest. It is strictly forbidden to require personal benefits, services or invitations; the ban applies to employees as well as their close persons or institutions.

2.4. Protection of information and data

The protection of information and data is a shared responsibility of the cooperating parties. Internal documents or data and procedures acquired by employees and sales representatives can only be used to perform the tasks resulting from their position in RAYA-CONSULTING, s. r. o., they can not pass it on to third parties except as instructed by their superior (in the case of employees) or if the agent of the company (in the case of commercial agents) has so in writing. With personal data, special data known to be used during work, employees and sales representatives can only handle the extent necessary and in accordance with applicable laws.

No employee or business representative of RAYA-CONSULTING, s.r.o. it can not pass on to third parties or parties information that contains new knowledge, trade secrets. Every employee and sales representative must respect the legal protection of others. It is strictly forbidden to obtain or use the secrets of others.

RAYA-CONSULTING, s.r.o. does not want to limit its use of social media to its employees and sales representatives, but considers it essential that all the publications and opinions published in these forums be ethical and unambiguous. When using social media, it is necessary to comply with all rules and guidelines regarding the Company’s confidential information. It is forbidden to publish confidential information, copyrighted information or otherwise legally protected information. It is forbidden to transfer information, data, photos or videos to social networking sites that would give a negative image of the Company.

In all social media forums that the Company does not officially use, contributors should indicate that the information they provide reflects their own opinion, not the opinion of the Company. It is forbidden to publish the Company logo without a written consent.

If an employee or agent finds any offensive or defamatory contribution to the Company anyway, he should immediately inform the Company’s direct head or statutory body.

2.5 Conflict of interests

Employees of RAYA-CONSULTING, s.r.o. are required to avoid conflicts of interest in the performance of work tasks, including the hint of such a conflict.

RAYA-CONSULTING, p. r. about. puts great emphasis on the fact that employees do not enter into conflicts of interest or disloyal status during their day-to-day activities. Such conflicts may arise, for example, in the case of business relations between the branches of RAYA-CONSULTING, s.r.o. and employees or their close relatives. Before closing business relationships of this type, the intention must be discussed with the management of the company.

Employees are required to notify in writing if they or any of their close relatives are unlimited liability partners, dominant owners, directors, executive employees, agents, subcontractors, consultants (jointly: cooperating) in a company that has business relationships with the same employer with a company that performs a similar activity as an employer.

2.6 Protecting Corporate Property

Employees of RAYA-CONSULTING, s.r.o. are responsible for the Company’s assets that are under management or use, as well as for its maintenance and efficient use. Every employee has to do everything within his power and within his / her own capacity to eliminate any deficiency caused by his / her work and to correct or, reduce the damage caused.

RAYA-CONSULTING, s.r.o. expects its employees and sales representatives to protect the material and intellectual assets of the company. These assets include assets, production facilities and inventory, cash, office equipment and equipment, information systems and software, know-how, as well as everything that is not listed but valuable. In case of violation of these principles, in the case of fraud, theft, fraud and money laundering, criminal proceedings shall be initiated.

Employees may use corporate assets and facilities, including the Internet, for private purposes only on a stand-alone basis.

In the case of dealing with business information, caution should be exercised.

For information concerning internal affairs of RAYA-CONSULTING, s.r.o. – which the Company does not disclose – employees and sales representatives are required to maintain confidentiality, even after termination of employment or termination of cooperation.

It is mandatory for third parties to protect business materials related to RAYA-CONSULTING, s.r.o. and information carriers.

It is strictly forbidden to disclose or transmit confidential information.

Employees and sales representatives must communicate truthfully in case of oral, written, internal or external reports. Any content manipulation is prohibited.

2.7 Public appearances, representation of the company in public events

RAYA-CONSULTING, s.r.o. supports all public appearances of employees and sales representatives that improve its reputation and contribute to its professional development. It is forbidden on behalf of the Company to express political opinions, take actions, promises that are contrary to internal rules or interests of society and to provide inaccurate information orally or in writing in any forums – including the workplace.

RAYA-CONSULTING, s.r.o. does not take part in the activities of political parties. However, it does not limit its employees and sales representatives to take part in political events in their free time and in an appropriate manner. We expressly welcome the civic, social and charitable activities of our colleagues and business representatives. Employees and business agents who commit to such a form of work for a company do so as individuals / citizens, and in such cases may not use the Company’s name, contact details, communication channels, and their social activities should not be against the interests of RAYA- CONSULTING, s.r.o.

3. Increased ethical requirements for executives

Ethical Standards RAYA-CONSULTING, s.r.o. apply to all employees and sales representatives, but there are special requirements for those in leadership positions.

Leaders must, in the course of their management activities, approach subordinate employees fairly, consistently and duly, must refrain from any action that would be contrary to human dignity.

3.1 Personal example

Leaders of the company must demonstrate exemplary behavior and leadership to ensure a sense of belonging and create a working atmosphere that allows good co-operation and efficiency. It is necessary to provide suitable conditions for the implementation of the expected standard of work of employees and sales representatives, to allow effective cooperation between business representatives and employees and to regularly evaluate the results achieved. All senior staff are required to support the fight against corruption.

A personal example is particularly important because the responsibilities of executives are the planning of departmental activities, workflow organization, implementation management and related audits.

3.2 Relations with employees

Leaders are expected to try to identify their subordinates, their personality, the level of their ability to position and their attitudes in their own organizational units, in order to constantly improve their knowledge and readiness and to deal with conflicts with the involvement of all stakeholders.

Leaders are expected not to behave in any violent, intimidating, hateful, evil or offensive way.

Management of RAYA-CONSULTING, s.r.o. their staff decisions, the assessment of the activities of their employees can only be taken on the basis of their merits, performance and factors related to the work.

4. Breach of the Code of Ethics

Notice of breach of the Code of Ethics is the option, right and duty of all employees and business representatives. They must alert the person concerned that his behaviour is not acceptable in RAYA-CONSULTING, s.r.o.

Any indication of ethical defaults must be reported by employees to a direct superior and, in the case of sales representatives, to the company’s manager, but the employee may also choose another channel – the HR department or senior management. Interested decision-makers may decide within their competence whether or not the Ethics Committee’s decision is required in this case.

RAYA-CONSULTING, s.r.o. does not tolerate retaliation. Every employee and sales representative has the right to inform management about workplace issues or concerns or other issues that concern the Company without any discrimination.

Employees or sales representatives who, in good faith and on the basis of their internal conviction, suspicion or tangible evidence, report a violation of the Code of Ethics and inform their immediate superior, HR department or top management to ensure that they do not result in any disadvantage . Notifications must be treated confidentially by all managers and leaders at all levels. The same applies to the identity of those employees and sales representatives who have contributed to the detection of breaches of the Code of Ethics and cooperate in its investigation.

Entries into force: 1 January 2017

Validity: until canceled

Zoltan Feher

managing director / CEO

This Code of Ethics was machine translated from it’s original Slovak version.