Code of Conduct

Message from CEO

Introduction

Employees of OL Munkaidő Kft., or any of its affiliates or subsidiaries (“we,” “our,” “us,” “the Company,” or “OL Munkaidő Kft.”), and others performing work for the Company or on its behalf, collectively referred to in this Code as “OL Munkaidő Kft. Personnel”, are expected to act lawfully, honestly, ethically, and in the best interests of the Company while performing duties on behalf of the Company. This Code provides some guidelines for business conduct required of OL Munkaidő Kft. Personnel. Persons who are unsure whether their conduct or the conduct of other OL Munkaidő Kft. Personnel complies with this Code should contact their manager or the CEO.

Moreover, while the Code is specifically written for the employees, we expect members of our extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for the Company to follow the Code in connection with their work for us. Failure of a member of our extended workforce or other covered service provider to follow the Code can result in termination of their relationship with the Company.

If any part of this Code conflicts with local laws or regulations, only the sections of this Code permitted by applicable laws and regulations will apply. Any policies that are specifically applicable to your jurisdiction will take precedence to the extent they conflict with this Code.

Reporting/Speaking Up

The company encourages all employees to ask questions and raise issues without fear of retaliation and is committed to treating reports seriously and investigating them thoroughly.

Employees must report suspected unethical, illegal or suspicious behavior immediately to their manager or Human Resources. The company does not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit.

All complaints will be properly investigated. In all instances, confidentiality will be maintained to the extent possible

No Retaliation

Employees who report a concern in good faith cannot be subjected to any adverse employment action including:

• Unfair dismissal, demotion or suspension
• Unfair denial of a promotion, transfer or other employment benefit
• Bullying and harassment, either in person or online
• Exclusionary behavior
• Any other behavior that singles out the person unfairly

Equal Opportunity

The company will not tolerate discrimination based on race, color, religion, gender, age, national origin, sexual orientation, marital status, disability or any other protected class.

Harassment

Treat all fellow employees, customers, business partners and other stakeholders with dignity and respect at all times.

Any type of harassment, including physical, sexual, verbal or other, is prohibited and can result in disciplinary action up to, and including, termination.

Harassment can include actions, language, written words or objects that create an intimidating or hostile work environment, such as:

• Yelling at or humiliating someone
• Physical violence or intimidation
• Unwanted sexual advances, invitations or comments
• Visual displays such as derogatory or sexually-oriented pictures or gestures
• Physical conduct including assault or unwanted touching
• Threats or demands to submit to sexual requests as a condition of employment or to avoid negative consequences

Bullying

We are committed to ensuring that our employees, our contractors and our customers work in safe and respectful environment that is free of bullying. Bullying can include:

• Spreading malicious rumor or gossip
• Excluding or isolating someone socially
• Establishing impossible deliverables
• Withholding necessary information or purposefully giving the wrong information
• Intimidating someone
• Impeding someone’s work
• Unfairly denying training, leave or promotion
• Constantly changing work guidelines
• Sending offensive jokes or emails
• Criticizing or belittling someone constantly
• Tampering with a person’s personal belongings or work equipment

Conflicts of Interest

A conflict of interest can occur when an employee’s personal activities, investments or associations compromises their judgment or ability to act in the company’s best interests. Employees should avoid the types of situations that can give rise to conflicts of interest.

It’s important for employees to disclose any relationships, associations or activities that could create actual, potential, or even perceived, conflict of interest to their manager or the CEO.

External Communication on Behalf of the Company

Only the CEO or a person with written authorization from the CEO are authorized to represent the company to media and/or legal authorities. Employees should refer all requests for information or interviews to the CEO.

Confidentiality

The company and its employees maintain the confidentiality of all proprietary information. Proprietary information includes all non-public information that might be harmful to the company and its customers and business partners if disclosed.

Confidential information may include but not limited to:

• Technology documentations
• Know-hows of the main business
• Any classified data
• Information about the infrastructure and IT security system
• Customer lists
• Supplier lists
• Pricing information
• Terms of contracts
• Company policies and procedures
• Financial statements
• Marketing plans and strategies
• Trade secrets
• Any other information that could damage the company or its customers or suppliers if it was disclosed

Privacy

The company complies with the requirements of the country’s and international privacy laws. All employees sign an agreement that contains provisions for information confidentiality and non-disclosure.

The company and its employees do not disclose any private, personal information of:

• Employees
• Customers
• Suppliers
• Competitors
• Third parties

Employees store all personal information securely, mark it as confidential and store it only for as long as it is needed for the purpose for which is was collected.

When providing personal information, employees limit access to only those with a clear business need for the information.

Employees are required to report any breaches of privacy, including the loss, theft of or unauthorized access to personal information, to their manager.

Competition, Fair Dealings and Antitrust

While the company competes aggressively for new business, relationships with business partners are built upon trust and mutual benefits and compliant with competition/antitrust laws.

Employees are required to:

• Communicate the company’s products and services in a manner that is fair and accurate, and that discloses all relevant information
• Familiarize themselves with the company’s fair competition policies and remain aware of the consequences of any violation of policies or laws governing fair competition
• Consult the company’s legal department before engaging in any new practice that may affect fair competition
• Refrain from price fixing, bid rigging, and any other anti-competitive activities
• Use only publicly available information to understand business, customers, competitors, business partners, technology trends, and regulatory proposals and developments
• Advise their manager immediately of possible violations of fair competition practices

Bribery and Facilitation Payments

The Company will not attempt to influence the judgement or behavior of a person in a position of trust by paying a bribe or kickback. This applies to persons in government and in private business.

The company does not permit facilitation (or “grease”) payments to government officials or private business in order to secure or speed up routine actions.

Employees are to:

• Select third parties carefully and monitor them continuously to ensure they comply with the company’s anti-bribery policies
• Keep accurate books and records at all times and monitor that funds are not being used for bribery or facilitation payments
• Refuse any offer or request for an unlawful payment and report the incident to the company’s ethics and compliance officer

Gifts and Entertainment

While gifts and entertainment among business associates can be appropriate ways to strengthen ties and build goodwill, they also have the potential to create the perception that business decisions are influenced by them. The company is committed to winning business only on the merits of its products, services and people and complies with all legal requirements for giving and receiving gifts and entertainment.

Employees are to:

• Use sound judgment and comply with the law, regarding gifts and other benefits
• Never allow gifts, entertainment or other personal benefits to influence decisions or undermine the integrity of business relationships
• Never accept gifts or entertainment that are illegal, immoral or would reflect negatively on the company
• Never accept cash, cash equivalents, stocks or other securities

Employees may accept occasional unsolicited personal gifts of nominal value such as promotional items and may provide the same to customers and business partners.

When in doubt, employees should check with the ethics and compliance officer before giving or receiving anything of value.

Political Contributions

The company does not make political contributions.

Employees are free to support any political party or entity on a personal level. However this must be kept separate from company business.

Charitable Contributions

The company may make charitable contributions to causes and organizations that are not politically affiliated.

Employees should check with the CEO before making any charitable contributions on behalf of the company.

Record Keeping

All documents, databases, voice messages, mobile device messages, computer documents, files and photos are records.

Employees are required to:

• maintain these records and protect their integrity for as long as required
• maintain official record keeping systems to retain and file records required for business, legal, financial, research or archival purposes
• dispose of your records according to the company’s records retention and disposition schedule

Employees should never destroy documents in response to, or in anticipation of, an investigation or audit.

Protection and Proper Use of Company Assets

The company requires all employees to protect its assets. All assets should be used for legitimate purposes, efficiently, and for company business only.

Assets include facilities, equipment, computers and information systems, telephones, employee time, confidential and proprietary information, corporate opportunities and company funds.

Suspected incidents of fraud, theft, negligence, and waste should be reported to the CEO.

Money Laundering

The company complies with anti-money laundering laws. Money laundering is the process of concealing illicit funds by moving them through legitimate businesses to hide their criminal origin.

Employees must never knowingly facilitate money laundering or terrorist financing, and must take steps to prevent inadvertent use of the company’s business activities for these purposes.  Employees are required to immediately report any unusual or suspicious activities or transactions such as:

• attempted payments in cash or from an unusual financing source
• arrangements that involve the transfer of funds to or from countries or entities not related to the transaction or customer
• unusually complex deals that don’t reflect a real business purpose
• attempts to evade record-keeping or reporting requirements

Insider Trading

Employees may learn information about the company, associates, clients, business partners or other companies that is not publicly available. It is illegal for any individual to use information obtained in this way for personal gain or to share it with others.

Employees are prohibited from:

• Buying or selling securities based on non-publicly available knowledge gained in the course of business
• Providing information or tips, or encourage another person to buy or sell securities based on inside information

These kinds of violence is investigated and treated by the force of law, if the information selling or giving is done towards any competitor companies or their representatives. Employees are required to report suspected insider trading immediately to the ethics and compliance department.

Health and Safety

The company conducts business in accordance with applicable health and safety requirements and strives for continuous improvement in its health and safety policies and procedures.

All employees are expected to perform their work in compliance with applicable health and safety laws, regulations, policies and procedures and apply safe work practices at all times in all locations.

Applicable safety and health requirements must be communicated to visitors, customers or contractors at any company location.

Employees using company or own cars for the company’s interest, must keep all health and safety requirements, defined in the traffic rules.

Employees are required to immediately report workplace injuries, illnesses or unsafe conditions, including “near-misses.”

Environment

The company is committed to operating in an environmentally responsible manner, from the provision of products and services, to the operation of its offices and facilities, selection of suppliers and other business activities.

The company complies with all applicable environmental laws and regulations as well as self-directed commitments to sustainable practices and environmental protection.

Information Technology

The company expects its employees to help it safeguard all computer equipment and data against intentional malicious acts by individuals inside or outside the company. Cyber-security training is provided to all employees to ensure compliance with computer security policies.

The company safeguards against inappropriate access by individuals or groups untrained in correct company policies or procedures

The company does not use software for which it does not have a license.

Internet Use

The company understands that occasional personal use of the internet during work hours is a reasonable request and allows this, within reason. Employees can ask for clarification from their managers if in doubt.

However, the company does not allow internet use to support a personal business, political venture, or embarrass the company and its customers.

Use of Social Media

The company respects the right of employees to use social media for personal and professional purposes. Employees are responsible for complying with company policies and procedures when communicating on social media. Employees are accountable for any information they publish online.

Employees are required to:

• Reveal their relationship with the company when commenting online on issues related to the company
• Respect the privacy of other employees and refrain from publishing photos of them without their consent
• Ensure any information they post related to the company is accurate
• Comply with the rules of the social media sites they use

Employees must not:

• “Pretext”, or pretend to be someone they are not online
• Speak on behalf of the company if they are not expressly authorized to do so
• Share confidential information about the company, its clients, stakeholders or suppliers
• Post comments or pictures that could harm the company’s brand, reputation or commercial interests

Corporate Social Responsibility

The company understands that corporate social responsibility extends to our entire supply chain. This encompasses not only the products and services supplied but also the human rights, ethics and social practices of our company and its suppliers.

One goal of the corporate social responsibility procurement program is to build partnerships with like-minded organizations by actively seeking out business partners who are the most environmentally and workforce friendly.

Forced Labor: The company and its suppliers shall employ all employees under their own free will with no one being subjected to bonded or forced labor. This policy applies to not only the supplier’s business operations but also those of their supplier network with which the company conducts its business.

Child Labor: The company and its suppliers shall not employ any people under the minimum legal working age of the country in which they work.

Responsible Environmental Impact: The company and its suppliers shall produce measurable environmental impact reports and conduct ongoing efforts to reduce environmental pollution while increasing sustainability.

The company encourages and supports involvement in the community that has supported it. This includes supporting local business and talent by, for example, sourcing local products and services, where appropriate, and showcasing the work of local artists in the company’s public spaces.

Charitable involvement is important to the company and a charity committee meets ones a month to discuss and execute potential and ongoing charitable projects.

Budapest, 14/12/2020

Tibor Erzse

CEO