CODE OF CONDUCT AND GOOD PRACTICES CLOUDWARE POLSKA SP. Z O.O.

§1 General Rules

1. The Code of Conduct and Good Practices (hereinafter referred to as the "Code") provides a summary of the shared values that are observed at Cloudware Polska sp. z o.o. (hereinafter referred to as the "Company").
2. The Code applies to all employees and co-workers of the Company.
3. The Code specifies the rules of conduct relating to interpersonal and business relations and the protection of the Company's assets and image. The Code also defines the rules for preventing corruption and how the Company cooperates with partners, contractual partners and competitors.
4. We are committed to doing business in compliance with the laws and common business standards. Likewise, we expect our business partners to comply with the principles outlined herein, which means that their relevant policy matters to us when we make decisions about cooperation. 
5. We share common values such as commitment, professionalism, efficiency, responsibility, respect and quality across all employees and co-workers at the Company.
   • We are fully committed to every project, and we get the greatest satisfaction from the success of our clients.
   • We continuously improve our qualifications and are keen to share our experience.
   • We are ambitious and determined to achieve our goal.
   • We expect mutual respect.
   • We take responsibility for our work and the environment where we work.
   • We set the bar high for the quality of all our efforts.

§2 Rules of conduct in employee and business relations

1. We respect human rights and the provisions of the labour law.
2. We follow all the rules of equal and fair hiring, compensation, development and professional promotion of our employees and co-workers.
3. We treat employees and co-workers equally regardless of race, gender, sexual orientation, religion and political beliefs.
4. We build relationships on mutual trust and respect for the other person, regardless of their position or function.
5. We take care of the positive image of the Company.
6. We act in a manner that does not put the Company's reputation at risk. This also applies to our conduct outside the work environment and office hours.
7. We take care of a neat and professional image adequate to the duties performed.
8. We take care of the Company's assets as they help us achieve our business goals. We do not use the assets entrusted to us for private purposes unless this has been separately regulated. This rule also applies to assets entrusted to us by clients or contractual partners.
9. We comply with all work safety standards and principles of ergonomics. We promote health and safety awareness through regular training, adjusted to the specific duties of our employees and co-workers. 
10. We communicate with precision and clarity.
11. We share complete, objective, up-to-date and comprehensible information.
12. We respect the dignity and reputation of all people and do not accept offensive behaviour toward others.
13. Guided by the principles of social coexistence and good manners, we do not accept any form of mobbing (offensive behaviour, humiliating, insulting, slandering and threatening others) or any conduct that bears the hallmarks of or is sexual harassment.
14. We take care of good relations and cooperation and do not accept the spreading of rumours and other conflict-causing information.

§3 Compliance of operations with national and international laws, requirements of business partners, industry regulations, standards and best practices

1. We comply with the regulations provided by common law and internal regulations. We ensure that our processes comply with the binding regulations. We constantly update our knowledge of legal requirements applicable to our business.
2. We comply with the laws that apply in the countries where we do business in our relations with customers, employees and external partners.
3. We respect commitments under the ISO standards, among others.
4. We do not engage in projects that entail violating the law and put the Company's reputation at risk. 
5. We know that any action against the law involves adequate sanctions, thus exposing the Company to financial and reputational losses and the loss of trust of key business partners.

§4 Preventing corrupt practices and money laundering

1. We are guided by the principles of fair competition.
2. We prevent price-fixing practices and do not strive to gain an advantage through unfair or abusive methods. 
3. We set prices for our products and services based on a fair valuation of the work and their quality.
4. We do not hire competitors’ employees to obtain information subject to protection by law.
5. We do not distribute false information about the products or services of our competitors.
6. We do not tolerate any attempts to enter into contracts or agreements to fix prices and share customer bases, suppliers or markets with competitors and contractual partners. 
7. We do not tolerate the unauthorised distribution and acquisition of information about competitors or disclosure of confidential and sensitive information to competitors or other entities. 
8. We inform our business partners that we comply with our rules of business ethics by sharing the rules on our website, and we require our partners to abide by these rules. We are committed to the "zero tolerance for corruption" rule.
9. We prohibit disclosing sensitive data to competitors and making unofficial arrangements, agreements, etc., which could potentially violate unfair competition laws.
10. We prevent money laundering and the financing of criminal activities, especially terrorism.
11. We do our business only with verified business partners. We do not engage in transactions or cooperation with entities whose activities are of doubtful nature and whose funds may come from illegal sources as a result of such operations as terrorist acts, drug and human trafficking or tax evasion. 
12. We take financial security measures with regard to our customers. We monitor, analyse and register the transactions carried out against the risk of money laundering.
13. We counteract conflicts of interest. We report any family or personal relation with the staff of a business partner to the Company's Management Board if we participate in the performance of work with that business partner as part of our duties. 
14. We maintain process, transaction and investment transparency, mainly through the integrity of the documentation and defined information flow.
15. Any data produced in the form of reports, etc., must be true, accurate, complete, consistent, timely and comprehensible. Intentional data manipulation, especially falsification, concealing, altering, destroying or creating false data, is prohibited and may involve both disciplinary and criminal proceedings. 
16. We do not tolerate any form of corrupt behaviour in business operations, as well as in the actions of our employees and co-workers, in particular:
    • Promising, suggesting, handing in, requesting or accepting any financial or personal benefits for either oneself or a third person,
    • Claiming to have connections, seeking or using one's connections or that of others, including connections in public authorities, enterprises and other entities in order to get a material or personal benefit.
17. We do not provide political parties and their representatives, or candidates for political office, with any undue material or non-material benefits, regardless of whether such gifts are either handed in or offered directly or through third parties. We expect the same from our business partners. 
18. We do not financially support any political party.

§5 Protection of intellectual property

1. We use the concepts, materials, software, and information of another person or entity only if we are authorised to do so.
2. We use third-party software that we are authorised to use.
3. We use only tools, software, systems and equipment approved by the Company when protecting our intellectual property.

§6 Information security

1. We take care of information security and protect personal data.
2. Information security is of utmost importance to us. Compliance with national and international regulations in this area determines our standards of strategic security.
3. We follow the laws governing the flow of information which is confidential, sensitive, or constitutes a company secret with special care.
4. We protect the personal data of our employees and partners by handling them with integrity and confidentiality, and we prevent their misuse.
5. We treat the information about the Company’s operations with due care. We do not process data in public places, e.g. on a plane, in a restaurant or on a train.
6. We develop defence systems against cyberattacks and information theft on the Internet.
7. Each of us is personally responsible for complying with applicable laws relating to legally protected information and with the regulations in effect at the Company about handling news that constitutes confidential information and company secret.
8. We run programs to build awareness among our employees and coworkers about information security, including data protection. 
9. We supervise access to our spaces.

§7 Environmental protection

1. We get involved in the protection of the environment.
2. We operate in such a way as to cause a minimal negative impact on the environment and comply with legal requirements and adopted standards.
3. We build the environmental awareness of our employees and coworkers by providing access to up-to-date information on this matter and environmental initiatives.

§8 Reporting undesirable actions

1. If you believe that someone from your work environment (another employee, customer, contractual partner, supplier or any other person) is violating the law or this Code, you must report this fact to the Administration Director.
2. You can do it:

(i) by sending an e-mail to the e-mail address: zgloszenia@cloudware.pl  

(ii)  listownie na adres Cloudware Polska sp. z o.o., ul. J.P. Dziekońskiego 1, 00-728 Warszawa. 

Any person who reports a violation in good faith shall be protected. Reporting suspicion of the Code violation shall not result in any negative consequences to the employee/co-worker. Each report shall be treated in a serious and fair manner and shall be investigated promptly. Appropriate corrective action is taken if the situation so requires upon due analysis.