Application of the Code

It is the policy of Phonexia, s.r.o. (“Phonexia”, “we”) to maintain the highest level of ethical standards in the conduct of our business affairs. Our values guide our actions in all cases. The actions and conduct of our officers, directors and employees (collectively, “Phonexia personnel”), as well as others acting on our behalf, are essential to maintain these standards and promote highly ethical reputation of Phonexia. To that end, all our personnel including agents, consultants and contractors must read, become familiar and comply with this Phonexia Ethical Code (the “Code”), as amended by Phonexia from time to time. Furthermore, we request our business partners to acknowledge our ethical standards and be compliant with them and actively promote the Code also to the end users of our products.

Compliance with laws

We must remain legally compliant at all times and with no exceptions, and always act in order to enhance protection of the Czech Republic and European Union interests.

We comply with all applicable laws, whether local, national or international and we want the same approach from our business partners. Furthermore, we Phonexia personnel, and those acting on our behalf, are responsible for understanding the applicable rules and must work with us to ensure strict compliance. Violations of law can result in significant harm caused to Phonexia or to our business partners, including financial penalties, denial of government contracting privileges, imprisonment for criminal misconduct and damage to our business relationships and reputation not only in the respective region but with a global impact.

No Bribery

Under anticorruption laws, it is illegal to offer or give gifts or entertainment if done with a corrupt intention. A corrupt intention means that the goal in giving the gift or entertainment is to influence someone to misuse their position in order to benefit us or our business partner. As we highly value free market competition, we do not give or accept bribes and also our business partners shall apply this principle.

Export Control

We and our business partners must comply with all applicable export control rules (including but not limited to the relevant EU Export Control Programmes). We review all business opportunities to ensure such compliance and we do ask our business partners for complete and truthful responses within such reviews.

End Users Identification

Due to the nature of our product we need verify that the end users of our product would not act in any manner that would be in conflict with the interests of the Czech Republic and EU. Therefore, we need our business partners to identify potential end users of our products and assist us in relevant verification of such user. If the confidentiality obligations of our business partner would not allow such identification, we will require the verification to be made by the business partner and conveyed to us.

We cannot provide our product to the business partner or end users which do not follow ethical standards stipulated in the Code.

Changes to the Code

Phonexia may change the Code from time to time even without notifying all its business partners or end users of its products. The currently applicable version of the Code is always available on Phonexia website.

Non-compliance with the Code

Although any potential or actual breach of the Code will be taken by Phonexia very seriously and even might lead to termination of the cooperation between us and our business partners or end users of our products, we strictly encourage all Phonexia personnel and our business partners to share with us immediately any information about such breach. We will make our best effort to mitigate the risks arising out or in connection with such breach and in many cases we might remove the risk completely thanks to the full and immediate cooperation of all involved parties. However, if the breach proves to be significant and there is lack of cooperation from the side of Phonexia personnel, business partners or end users, we reserve the right to take steps leading towards termination of our cooperation, discontinuation of use of our product and cooperation with investigation forces.

Reporting

All Phonexia personnel including agents, consultants and contractors as well as our business partners must report any suspected or actual (whether or not based on personal knowledge) instances of non-compliance with this Code and must provide all pertinent information to assist in any internal investigation of the relevant circumstances. Reports should be made to the Phonexia representative or using the designated contact at [email protected]

In order to appropriately assess potential non-compliance reports, we ask all our personnel including agents, consultants and contractors as well as business partners to keep accurate business, corporate and financial records and in cases of suspected or actual non-compliance to provide them to Phonexia.

Unless otherwise required by applicable laws or relevant official authority, we will always keep provided information in strict confidentiality and use it solely in the extent and for the purpose of maintaining continuous compliance with the principles set forth in this Code.