Code of ethics

The key purpose of the Code of Ethics is to communicate the fundamental principles of activities that employees of the Company are expected to adhere to in order to secure the impeccable reputation of the Company.

Observance of legal acts

The proper observance of relevant legal acts constitutes the basis of the ethical norms of the Company.

All employees of the Company are required to respect laws and properly comply with the relevant legal requirements. The employees of the Company are not expected to know all legal acts in detail; however, they are expected to understand them to an extent sufficient to decide when it is necessary to apply for legal advice.

Conflicts of interests

All employees of the Company are obliged to avoid situation that could potentially raise any doubts concerning their ability to act for the benefit of the Company. Conflicts of interests may arise when an employee:

- works in a company of Invalda’s competitors, clients or suppliers,

- purchases, on behalf of Invalda, goods or services from a company in which the employee’s members of the family and/or other related persons have financial interests;

- has private financial interests, or invests into a company in which Invalda has or plans to have any financial interests.

The list of the circumstances as referred to above is not a final list, therefore, employees must each personally consider any potential conflict situation.

Employees shall be prohibited from using their family members and/or other related persons in order to circumvent the provisions of the policy of the conflict of interests.

Confidential information

Employees of the Company shall not disclose, neither in writing, not verbally, any confidential information to any other person who is not an employee of the Company.

The above requirement shall survive the termination of employment relations with Invalda. The Company also expects from any new employees, coming from other companies, will secure the confidential information of their former employers.

Insider trading in securities

Employees of the Company having access to confidential information shall be prohibited from buying/selling securities of Invalda or any other companies related thereto before such confidential information is announced publicly.

Transparency of financial information

The accounting of the Company shall be managed in accordance with all requirements of legal acts. For the financial information to be comprehensive and reliable employees of the Company shall ensure that all transactions and accurately and on a timely basis recorded in the corporate accounting system.

Employees of the Company shall be strictly prohibited from intentionally misleading, exercising any pressure on or otherwise impeding the work of independent auditors of the Company.

Gifts

Employees of the Company shall be prohibited from giving or receiving gifts or seeking to obtain other personal benefit that could potentially affect their performance related to the activity of the Company.