CODE OF ETHICS OF COMPANY SOLVERSHIP d.o.o.

1. GENERAL PROVISIONS OF BUSINESS ETHICS

The Code of Ethics of Solvership d.o.o. the basic ethical rules of behavior of all employees in Solvership d.o.o. Zagreb (hereinafter: Company) are established.

The purpose of the Code of Ethics is to determine and promote fundamental ethical values ​​in business relations within the Company and with the environment. The environment includes clients, business partners, related companies, workers, potential workers, associations and associations, media, state and other institutions, owners of the Company and other interested groups.

The code of ethics sets general rules of conduct and principles that create prerequisites for the permanent and affirmative development of organizational culture, awareness and healthy business and personal relationships.

It is of inestimable importance that this Code of Ethics is the basis of daily behavior and affirmation of the highest ethical principles in mutual relations and in the overall business of the Company.

This Code of Ethics applies to subcontractors, subcontractors and external collaborators, which must be incorporated into contractual relations with them, and they must be informed and educated about this Code of Ethics.

Terms used in this Code of Ethics, which have a gender meaning, are used neutrally and refer equally to men and women.

1. ABOUT THE COMPANY

The company is an IT consulting company that deals with the implementation of advanced analytical solutions, big data systems and artificial intelligence and machine learning. It also develops its own software in the field of data management. The company operates through five business lines: Data & Analytics, Advanced Analytics, Data Migration, Data Governance and BIRD Products.

The strengths through which we bring value are:

• An approach aimed at bringing value to the client,
• Knowledge of business processes in numerous industries (communications & media, financial institutions, production, distribution and retail, high-tech and digital, state institutions and infrastructure),
• Domain knowledge and knowledge of methodologies and concepts,
• Broad experience throughout the entire Data & Analytics life cycle,
• Partnership with the world's leading software product vendors / partners.

The Company's headquarters are in Zagreb, and it also operates from an office in Osijek, and subsidiaries in London, Vienna, Stockholm, Ljubljana, Belgrade, Podgorica and Sarajevo, with over 200 employees and over 20 years of experience. With its knowledge and experience, the Company is leading the way in enabling clients to create value from their data.

Clients are leading companies, mainly from the Adriatic region, the European Union, Great Britain, the United States of America and Africa.

In accordance with the principle of continuous improvement and the need to provide top-quality services to clients, the Company has certificates of the ISO 9001:2015 quality management standard and the ISO 27001:2013 information security standard, and both introduced systems are the commitment of the Company's management and all employees and, as such, are an inseparable part of the management structure of the Company.

1. FUNDAMENTAL VALUES

The fundamental values ​​of the Company, which are encouraged and expected from all employees of the Company, are:

a) INTEGRITY

We stick to our personal values. We are honest, considerate, open and honest in our communication. We are loyal to colleagues, users and partners. We are aware of our strengths and weaknesses. We review our behavior and try to be objective, no one is perfect and everyone can make mistakes. We respect other people's personality and diversity.

b) RESPONSIBILITY

We do our work conscientiously, we respect agreements, we communicate openly and in a timely manner, and we strive for a bigger picture. Colleagues and clients can trust us with full confidence. We care carefully about how our work affects others and contributes to our joint success.

c) AGILITY

We love change! In changes, we recognize new opportunities for growth and development and readily accept them. We adapt our products and solutions to the needs of the market and users. We make sure that the speed of changes does not threaten the stability of the system and we take care that the stability of the system does not slow down the changes.

d) INNOVATIVENESS

We are always thinking about what and how we can do better or differently, we boldly propose it and involve others in the development of ideas.

e) EXCELLENCE

We are dedicated to developing technical and business competencies, exchanging knowledge with colleagues, striving for constant personal growth and development and consistently creating value for clients and the Company

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1. FUNDAMENTAL ETHICAL PRINCIPLES

The fundamental principles of ethical behaviour promoted by this Code of Ethics are as follows:

• The principle of trust and collegiality,
• The principle of compliance with laws and other regulations - legality of work and business,
• The principle of respecting the integrity and dignity of citizens and workers,
• The principle of expertise and responsibility – professionalism in business,
• The principle of teamwork and professional communication,
• The principle of respecting the needs of clients and business partners,
• The principle of creativity and innovation – quality and excellence in business,
• The principle of avoiding and preventing conflicts of interest,
• The principle of responsible management of assets, business finances and the procurement process,
• The principle of confidentiality of personal data and information in business,
• The principle of intellectual property protection and correct use of the computer system
• The principle of avoiding receiving and giving gifts, hospitality, favors and money,
• The principle of zero tolerance for the consumption of opiates during working hours,
• The principle of environmental protection, safety and human health,
• The principle of social responsibility.

1. APPLICATION OF PRINCIPLES OF ETHICAL BEHAVIOR

• The principle of trust and collegiality

The behavior of workers at the workplace and outside it is based on mutual trust and respect, correctness and respect for the personality and dignity of associates.

The immediate manager is obliged to provide the employee with and make available to him all relevant data, information and resources necessary for quality work and to familiarize him with all internal regulations, standards and procedures necessary for quality performance of work in accordance with the legal framework.

• The principle of compliance with laws and other regulations - legality of work and business

All employees of the Company are obliged to comply with laws and other regulations, the provisions of the Code of Ethics, general acts and decisions of the Company and employment contracts when performing their duties, and to apply and enforce the highest professional, business and ethical standards and norms and thus ensure legality in work and business for the purpose of building and preserving the Company's business reputation.

Workers are expected to act professionally, proactively, conscientiously and diligently and protect the interests of the Company.

Any incorrect presentation of facts, malicious manipulation, concealment and retention of data and information that would benefit the employee or others or harm the work of associates, cooperation with third parties and the interests of the Company is strictly prohibited. 

• The principle of respecting the integrity and dignity of citizens and workers

The worker is obliged to ensure the realization of rights, respect for the integrity and dignity of citizens and other workers, without discrimination or privilege on any basis.

Discrimination means separating or distinguishing between individuals or groups of people on the basis of their social, ethnic / national, religious, racial, sexual, gender, age or other characteristics. This includes the treatment of an individual or group based on their actual or perceived membership in a particular social group or social category, in a manner that is less favorable than the usual treatment of the individual or group.

All workers should be respected as persons in accordance with the guaranteed rights to life, integrity and dignity.

All workers should be guaranteed the right to privacy and protection of personal data.

The worker has the right to protection from harassment, i.e. behavior that aims or actually represents discrimination or a violation of the worker's dignity, and that causes fear or a hostile, humiliating or offensive environment.

The worker has the right to protection against sexual harassment, i.e. behavior that represents verbal, non-verbal or physical behavior of a sexual nature.

• The principle of expertise and responsibility – professionalism in business

Workers are expected to responsibly, conscientiously, professionally and ethically fulfill all obligations towards colleagues, clients and other interest groups with whom they come into contact during their work in the Company.

When performing work, workers must respect the prescribed deadlines and strive to complete all tasks and jobs without unnecessary delay.

Workers should avoid any activities that may harm professionalism and objectivity in work and refrain from activities that are contrary to the interests of the Company.

Workers are obliged to treat their colleagues with respect, be available to clients and treat them kindly, as well as all other interest groups with whom they come in contact during the performance of their work.

In an effort to improve the efficiency and quality of work, workers should achieve a high level of professionalism and expertise through constant training. The obligation of direct managers is to lead a policy of continuous professional development and to enable the education and professional development of workers for the tasks they perform or will perform.

• The principle of teamwork and professional communication

Workers are obliged to develop a culture of teamwork and to continuously communicate with each other horizontally and vertically. Communication should be based on mutual respect and professional relationship.

Workers are obliged to refrain from any form of discrimination in communication. In communication, you should avoid encouraging or spreading rumors and gossip and creating a negative working atmosphere.

• The principle of respecting the needs of clients and business partners

Relationships with clients and business partners must be nurtured with the highest level of honesty and fairness.

The relationship of workers towards clients and business partners must be based on professionalism, availability, courtesy, seriousness, reliability and confidentiality.

Workers are obliged to treat all citizens, clients, business partners and other interest groups equally without discrimination or privilege.

• The principle of creativity and innovation – quality and excellence in business

In order to increase business excellence, effectiveness and efficiency of business, creativity, innovation, commitment and the special contribution of each employee are especially motivated and valued.

• The principle of avoiding and preventing conflicts of interest

Workers are obliged to protect the reputation and reputation of the Company, act according to the principles of a good businessman, respect the laws and must not participate in activities that could lead to a conflict of interest.

Workers are obliged to avoid any conflict of interest and upon learning of its possible existence, immediately notify the Company's management and/or the Ethics Committee.

The existence of a conflict of interest is reported to the Ethics Committee, which proposes a way to resolve it to the management, and the management decides on the solution.

In the event of a conflict of interest, the employee will be exempted from participating in the resolution of a case in which he is not neutral, at his own request or based on the decision of the Company's management.

• The principle of responsible management of assets, business finances and the procurement process

Employees are personally responsible for ensuring that the equipment entrusted to them and other assets of the Company (laptops, mobile phones, official vehicles, etc.) are not damaged, misused or lost. Reasonable care must be taken of entrusted equipment.

Workers who work in asset management, financial and procurement activities are also required to adhere to additional ethical principles according to specific professional standards.

In the same way, workers who work in the above-mentioned jobs are obliged to avoid all attempts to influence the making of objective and impartial decisions and to act responsibly and with the attention of a good expert when performing their jobs.

Procurement of goods, services and works are performed according to the principle of ensuring the expected value for the invested money. 

• The principle of confidentiality of personal data and information in business

Personal data about employees and candidates for positions in the Company, as well as personal data and information about clients, suppliers and other business partners obtained directly or indirectly, are confidential and protected in accordance with applicable laws and the Company's acts.

In the performance of their duties, workers are obliged to keep confidential information, regardless of the way in which they came to know it. All information about the Company, employees, clients, business partners, contracts, material and intellectual property of the Company, unpublished financial data of any kind, data about products and processes are confidential and may only be used for the purpose of performing the duties of the workplace for which the employee has entered into a contract about work.

In all forms of public appearances and activities in which he represents the Company, including appearances in the media, the employee is obliged to respect this principle of confidentiality and express the Company's views in accordance with the regulations, the obtained powers, professional knowledge and the Code of Ethics. When expressing the views of the Company and personal views, the employee is obliged to take care of the reputation of the Company and personal reputation.

• The principle of intellectual property protection and correct use of the computer system

Special attention is paid to the protection of intellectual property, either that which the Company itself develops, or that which it uses through various licenses, or the intellectual property of third parties. Employees may not load unauthorized software (or software without a slanderous license) onto the Company's computers. The same applies to the use of other materials protected by intellectual property rights (parts of image, audio or video content - «downloading from the Internet») without the special permission of the holder of intellectual property rights.

When using the Company's computer system, employees must not use the system to send mass and unwanted messages ("spam"), for illegal activities, they must never intentionally access, save, send, print pornographic, sexually explicit or sexually exploitative images or texts; any materials that promote violence, hatred, terrorism or intolerance towards others; any material that is abusive, obscene or offensive. In case of unsolicited or unexpected receipt of such material via unsolicited e-mail, it must be deleted immediately.

In case of reasonable suspicion of misuse of the Company's computer system, or in case of reasonable suspicion of use of the computer system contrary to the principles from the previous paragraph of this point and in order to prevent the same, the Company may access and monitor files on computers and electronic communications saved on servers, computers and other devices of the Company.

• The principle of avoiding receiving and giving gifts, hospitality, favors and money

Workers and their family members may not receive gifts from persons with whom the workers have a business relationship.

In addition to concrete things, decorations, favorable conditions or discounts on products/services, loans, use of vehicles, travel expenses or vacation facilities, tickets or gift vouchers are also considered gifts.

Exceptionally, in the case of occasional gifts of a symbolic value of up to EUR 60, which are considered a common sign of attention in a business environment, receiving gifts is permitted if it does not lead the recipient to a binding dependency, does not affect the conclusion of a deal or place the gift giver in any privileged position position.

The principles stated previously in this point also apply to giving gifts, as well as receiving and giving hospitality to persons with whom the workers have a business relationship. Hospitality is considered to be honoring with a business meal, recreational, cultural or sports events and the like.

Gifts and hospitality with a value of more than EUR 60 may be considered bribery and must be reported to the Ethics Committee and/or the Company's management and may be approved by the aforementioned bodies only exceptionally and in writing.

Any gift or hospitality provided with the intent to influence or obtain influence for abuse is considered bribery regardless of value, whether reported or not.

If a gift cannot be refused for reasons of courtesy or practicality (e.g. it has already been given and cannot be returned in an appropriate manner), the Ethics Committee and/or the Society's management must decide whether to allow the gift to be kept or to give it to charity or for the benefit of the community.

Any charitable donation must be transparent and conducted in accordance with applicable law and must never be used to conceal corruption.

Receiving and giving gifts and/or hospitality to state or local officials, political stakeholders and participants in public tenders/contests, regardless of the value of the gift and/or hospitality, is strictly prohibited.

Receiving and giving counter-services and/or money is strictly prohibited.

• The principle of zero tolerance for the consumption of opiates during working hours

The consumption of opiates during working hours is strictly prohibited, in accordance with the law.

Employees of the Company may be subjected to an opiate test at any time during working hours in order to verify compliance with paragraph 1 of this point of the Code of Ethics.

The test for opiates is carried out by an authorized employee of the Company by order of the management.

Coming to work under the influence of opiates is considered a particularly serious breach of employment obligations.  

• The principle of environmental protection, safety and human health

In their work, workers are obliged to comply with the rules of work in a safe manner and at the same time take care of their personal safety and the safety of other persons and equipment, and the Company's obligation is to ensure the conditions for safe work of workers.

The Company provides workers with regular systematic inspections at the Company's expense. Workers are obliged, upon instruction and at the Company's expense, to undergo a medical eye examination and submit a legally required certificate of the eye examination.

Workers are obliged to attend regular systematic examinations and vision examinations organized by the Company.

Every worker in his work is obliged to take care of the possible harmful impact of the working environment on human health, as well as work activities on the environment and to comply with all applicable laws and prescribed rules of environmental protection and sustainable development.

• The principle of social responsibility

Regarding the role in society and social responsibility, the Company believes that no company can act in isolation from the environment in which it is located, and strives to act in accordance with ethical and moral principles, striving for sustainable development and the welfare of all stakeholders. Because of the above, the Company actively works to change and improve society through participation in associations, academic communities, and through sponsorships and donations of sports clubs and needy groups, contributes to the development of our social community.

The company is a signatory to the Charter on Diversity, by which it is committed to implementing a policy of diversity and non-discrimination in its working environment and business environment. The charter is part of a European initiative that brings together more than 7,100 signatories from 18 EU member states, who are committed to promoting diversity, inclusion and equal opportunities in the workplace.

The company is also the holder of the MAMFORCE and DADFORCE certificates, which are a recognized mark of quality that confirms to employers their competence in implementing a family-friendly and gender-aware human resources management policy. The MAMFORCE and DADFORCE certification process is a powerful means of changing the organizational culture through which the organization adapts and changes its policies to enable its workers to parent without consequences for professional development, and supports the development of a corporate culture based on inclusion, diversity, openness and trust.

The company is the holder of the Certificate Employer Partner, Employer Friend of the Family, RUN Friendly Employer, Best company for well - being 2020, as well as the winner of numerous awards, which is a confirmation of continuous care for workers and the wider social community. The company nurtures the reputation of a socially responsible entrepreneur who builds his strong reputation, i.e. reputation, with credible work and quality

attitude towards all interested parties: employees, clients, customers, partners, suppliers and the wider social community. It promotes sustainable development because it is a business strategy aimed at balancing long-term growth and competitiveness in changing external conditions with an impact on economic, environmental and social development.

It is one of the most active members of the association CISEx, UGP, CroAI and AmCham in order to influence positive social and economic changes through the activities of the association.

The company's employees are active members of the Women in Adria association, which represents a brand for ambitious women, entrepreneurs, corporate women and women who want to achieve a successful career in any field.

The representation of women in the Company is about 50%, which they are proud of, and when hiring, if possible, preference is given to the underrepresented gender, because the Company recognized that the most innovative and effective teams were those that had an equal (50:50) representation of men and women.

The company also founded the BIRD Incubator in 2021, whose vision is to support startups that apply artificial intelligence and machine learning as part of their solution, and to position Croatia on the map of Europe and the world as one of the headquarters for the development of successful startups in this area. Through the BIRD Incubator, we create and support a startup ecosystem and influence the creation of an entrepreneurial environment within which startups that want to develop technological solutions based on artificial intelligence quickly and efficiently get the necessary mentoring support and investment opportunities, as well as contacts with the economy, technological partners and academia through that can test their concepts and solutions.

The company strongly integrates care for the environment and society in its business activities, striving for a balance between economic growth and the well-being of society and the environment. The company is aware of its influence on the wider social community and strives to make positive contributions through ethical and socially responsible behavior.

1. IMPLEMENTATION OF THE CODE OF ETHICS AND SUPERVISION

Ethics committee

The Ethics Committee is an independent working body that gives opinions on the content and method of application of the Code of Ethics, and promotes ethical principles and standards in the Company, receives complaints from workers and citizens about unethical behavior and actions of workers and conducts the procedure for investigating the merits of the complaint, gives opinions on the content and method application of the Code of Ethics, and promotes ethical principles and standards in the Company.

The Ethics Committee has 3 members. The Management Board of the Company by decision appoints the members of the Ethics Committee for a period of two years.

A committee member cannot be a person who has been found to have violated the Code of Ethics.

The Ethics Committee is independent in decision-making, and decides by majority vote.

The ethics commission issues opinions, recommendations and warnings, in the event of a complaint or at the request of a worker or user of services, at the request of the management, as well as on its own initiative.

The Ethics Committee submits a report on its work to the Company's management once a year, no later than January 31 of the current year for the previous year.

The Company's management can always request a report on the work of the Ethics Committee.

Filing a complaint

Workers can submit a complaint to the Ethics Committee in case of unwanted behavior from the provisions of this Code of Ethics, direct superiors, as well as other workers who they believe is against the provisions of the Code of Ethics.

Citizens can submit a complaint to the Ethics Commission about the behavior of workers, which they believe is against the provisions of the Code of Ethics.

Complaints are submitted in writing, and exceptionally also orally.

If the complaint is received by the Company's management, it will be forwarded to the Ethics Committee without delay.

Information about the applicant is considered confidential information. Submission of an application by a worker in good faith cannot be a reason for sanctioning it.

Examination of the merits of the complaint

The Ethics Committee conducts the procedure of examining the merits of the complaint, and prepares a report to the Company's management on the procedure.

Within 10 days from the date of receipt of the complaint, the Ethics Committee is obliged to conduct an investigation into the merits of the complaint, and prepare a response to the complainant, which it submits to the Company's management.

The ethics committee is obliged to conduct the procedure of examining the merits of the complaint also based on an anonymous report.

In the process of examining the merits of the complaint, the Ethics Committee will request a written statement from the worker to whom the complaint relates, statements from other workers who have direct knowledge of the content of the complaint, reports from competent authorities in case of suspicion of possible criminal offenses, and take other actions necessary to establish the factual basis condition.

All workers are obliged to cooperate with the Ethics Committee in gathering information necessary for its decision.

After the procedure, the Ethics Committee will vote to decide whether there is a violation of the Code of Ethics. The decision is made by the majority of votes, and in the case of an equally divided number of votes, the decision is made by the chairman of the Ethics Committee, and the decision will be made in writing by the committee.

If the Ethics Committee determines that there is a violation of the Code of Ethics, it will state in its decision all the facts that indicate that a certain employee has violated the Code of Ethics and will propose to the Company's management to take appropriate measures against the employee, all in order to prevent further violations of the Code of Ethics.

If the Ethics Committee determines that there is no violation of the Code of Ethics, it will reject the complaint and notify the complainant in writing.

The Ethical Committee keeps a record of the conducted investigation into the merits of the complaint, and of the conclusions and decisions reached, which, along with a written report and a proposed response to the complainant, is submitted to the Company's management.

The Company's management is obliged to give an answer to the complainant within 10 days from the date of receipt of the report of the Ethics Committee, and to inform him of the actions taken.

The complainant has the right to submit a complaint to the Ethics Committee within 10 days from the expiry of the deadline for responding to the complaint, i.e. from the day of receipt of the response to the complaint in the event that the complainant is not satisfied with the response of the Company's management or the report of the Ethics Committee.

The action of the Ethics Committee does not prevent the implementation of measures within the competence of the immediate manager in connection with the responsibility of workers for violations of obligations from the employment relationship, as well as other prescribed measures and in connection with internal supervision when certain behaviors fulfill the prerequisites for the implementation of these measures.

1. FINAL PROVISIONS

In order to effectively implement this Code of Ethics, the Company conducts training for all new employees so that they adopt the principles and rules from this Code of Ethics as soon as possible and apply them in their daily work. Also, at least once every two years, the Company conducts training for all employees, which ensures continuous implementation, compliance and improvement of the principles and rules of this Code of Ethics. Appropriate records are kept about it.

Exemptions from this Code of Ethics may be approved by the administration in writing with an explanation of the reasons for the exemption.

Employees can propose amendments to this Code of Ethics to the member of the management for the business area of ​​business support.

The member of the management board for business support, who is also the owner of this document, is responsible for the implementation of the Code of Ethics. The document must be reviewed and, if necessary, supplemented at least once a year.

This Code of Ethics was published on February 28, 2024. since it has been applied, with subsequent changes to the Company's company name.