Code of Ethics

CODE OF ETHICS – FORNIX d.o.o.

I. GENERAL PROVISIONS

The subject and purpose of the Code of Ethics:

FORNIX d.o.o. Code of Ethics (Hereinafter: the Code of Ethics) are determined by ethical principles and rules of conduct of all administrative bodies and employees based on legal and other regulations. The purpose of this Code of Ethics is to promote ethical and moral principles and values in behaviour when working as employees are obliged to adopt them as their own personal principles and criteria of behaviour, with the aim of achieving the common good, transparent and efficient business operations and quality services to service users.

The content of the Code of Ethics

This Code of Ethics contains fundamental principles and standards of good administrative practice that employees need to comply with in relation to the citizens, physical and legal persons and other users of services (hereinafter: beneficiaries) in relation to other bodies, in their mutual relations and in attitude towards work and the workplace.

II. BASIC PRINCIPLES

During the work, employees should act in accordance with the Constitution, laws, regulations and rules of the profession.
Employees are required to act efficiently and with less cost and investment of time and as soon as possible to ensure transparent and reliable realization of the rights and interests of service users.
Employees are required to perform tasks correctly, conscientiously and professionally and achieve the set goals for them and are responsible for their actions and results.
Staff and administrative authority should ensure the rights and respect the integrity and dignity of all employees and business partners as well. Also, they are not allowed to discriminate or favour employees and business partners on the basis of age, nationality, ethnic or social origin, linguistic or racial origin, political or religious beliefs or preferences, disability, education, social status, gender, marital or family status, sexual orientation or other grounds contrary to the Constitution and laws established rights and freedoms.
Employees are not allowed in dealing with business partners and other employees to abuse their authority and position to achieve self-interest (financial and other benefits) or the interests of another person or entity.
Employees are prohibited, for the favourable solution of queries or requests, to ask for and receive the gift of free services, regardless of their value.
If the employee is requested for more favourable solutions queries or requests and therefore offered a benefit in the form of a gift or some other offers, the employee is obliged to reject it and to notify the superior employees.
Employees must dress neatly and politely, in accordance with the usual professional standards, and appropriate for the tasks he or she performs. Work-space employees are required to maintain in accordance with the usual standards and use it according to regulations.
An employee who is a member of a political party should not display their political affiliation and political work in the working time or his political party affiliation may affect the impartial and professional performance.
All employees are obliged to act in accordance with principles of effective management on the basis of laws and regulations, in compliance with the principles of economy and efficiency.
Employees are required legally, responsibly and with due care to deal with the assets of company entrusted to them and not to use it for personal gain or for any other illegal activity.

III. RELATIONSHIP WITH BUSINESS PARTNERS AND WITH OTHER SUBJECTS

In comparison with business partners, employees are required to act professionally, objectively, decent and affordable and to treat them with due care and respect. Treatment of employees must be in accordance with the stated purpose and proportionate to the aim to be achieved. The employees are required to provide quality service to business partners and should achieve good cooperation on all issues of common interests. Employees are required to abide by the usual standards of decent business communication in both, written and personal communication with business partners. At the request of partners, employees are required to provide their data (name and working position).
Employees are required to act with special attention to people with disabilities and other persons with special needs.
Employees are required to provide an explanation on the procedures and decisions taken in the performance of and to the business partners, if invited to do so.
The performance of employees is based on professionalism, which implies a high level of necessary professional knowledge and skills to perform the corresponding job, focused on continuous improvement of the quality of work and services.
In areas of joint work and interests, staff will develop and maintain good relationships and purposeful co-operation with the other employees and other bodies they preserve.

IV. RELATIONSHIPS BETWEEN EMPLOYEES

The ratio of employees to other employees

Relations among employees must be based on mutual respect, respect, responsibility, trust and cooperation.
Employees are required to develop positive relationships, to assist each other in the common work and the focus on achieving the best possible results.
Employees must respect the autonomy and expertise from their own and other professions, encourage initiative and creativity, brainstorm, sources of knowledge, their expertise and skills and transmit information and data that are relevant to their job.
Employees are not allowed to interfere with each other in carrying out their tasks.

Relations between superior and subordinate employees

While performing the tasks, subordinates and superiors employees are required to establish an honourable, decent, patient, balanced relationship and loyalty.
Staff correspond to the higher-level employee for their working methods which are applied in performance and they are obliged to report it without being specifically asked about.
A superior officer is obliged to encourage other employees for quality and efficient performance, mutual respect and cooperation, and to be in an appropriate relationship to business partners and other bodies with whom they work.
Higher-level employees should treat openly and with consideration all subordinate staff, should be fair and give them a good example, be willing to advise them on all matters and provide them access to the data necessary for the good performance.
Organized labour superior officers must take into ac-count and respect as much as possible affinities, features and capabilities of their subordinates, encourage them to professional training and education and refrain from privatizing relationships and encouraging subordinates to act incompatible with this Code of Ethics.

V. DISCLOSURE OF INFORMATION

Purpose: ensure transparency and integrity.

Guidelines:

Disclose financials, conflicts of interest, operational changes and security incidents
CFO handles financials; employees disclose conflicts; department heads manage operational and security disclosures
Report financial quarterly, conflict and security issues immediately, operational changes before implementation
Use reports, internal memos and public announcements for disclosure
Consequences: failure to disclose may result in disciplinary action or legal consequences.

VI. FINANCIAL RESPONSIBILITY

Our organization is committed to maintaining the highest standard of financial integrity and transparency. We expect all employees and stakeholders to adhere to the following principles:

Accuracy: ensure all financial records and reports are accurate, complete and timely.
Transparency: provide clear and transparent information to stakeholders
Accountability: take responsibility for financial decisions and actions, ensure they align with organization’s goals and values
Compliance: adhere to all relevant financial laws, regulations and internal policies
Ethical conduct: avoid conflict of interest and act in the best interest of the organization and its stake-holders

Any violations of these principles should be reported im-mediately through our confidential reporting system. All reports will be taken seriously and investigated promptly.

VII. CONTROL OF APPLICATION OF THE CODE OF ETHICS

Ethics Committee

Control of the application of this Code of Ethics is implemented by Ethics Committee.

The Ethics Committee consists of four members who are appointed and dismissed by the director of the company
Members of the Ethics Committee shall be appointed from among the staff and management of the enter-prise
The Ethics Committee is appointed for a term of four years and a report on it each two years.
The Ethics Committee monitors and supervises the implementation of this Code of Ethics, promotes ethical principles and all business segments and ethical behaviour in their relations with clients, customers and suppliers and to other bodies, as well as in their relations staff.

The Ethics Committee is responsible for:

receiving complaints of business partners and employees and keeping records of complaints received
carrying out the investigation procedure of the com-plaint and assessing the merits of the complaint
writing a report on the procedures conducted after complaints
providing an answer to the complaint
giving opinions and recommendations regarding the content and application of this Code of Ethics
promoting ethical principles and standards of service

Business partners and employees can file a complaint against those employees whose behaviour streaming contrary to the provisions of this Code of Ethics. The complaint may be submitted in written form or by e-mail.

Acting on the complaint, the Ethics Committee investigates the merits of the complaint and implements of all actions necessary to establish the facts of the complaint (obtaining statements of employees to whom the complaint refers, statements of other employees who have direct knowledge of the content of the complaint, etc.).

In the investigation of the merits of the complaint, all involved parties and their supervisors shall cooperate with the Ethics Committee in order to obtain the information needed for a decision. Employee to whom the complaint refers, provides necessary statements and proofs within eight days.

After the procedure Ethics Committee assesses the merits of the complaints. If the Ethics Committee finds that the complaint is founded, the report will suggest taking appropriate procedures and activities.

Ethics Commission must submit a reply to the complainant and the employee to whom the complaint relates no later than 30 days from receipt of the complaint.

Pursuant to the report, depending on the type and severity of the violations, the Ethics Committee in collaboration with the Director decides on procedures and sanctions for violation of this Code of Ethics and gives written statement to the responsible employee. Written statement should not be issued if the report states that there was no violation of this Code of Ethics, or that the complaint is unfounded.

Administrative and technical tasks of the Ethics Committee perform the service in charge of human resources management.

VIII. TRANSITIONAL AND FINAL PROVISIONS

Terms and measures for the implementation of the Code of Ethics:

Employees are required to this Code of Ethics in good faith to implement it in everyday work.

Fornix d.o.o., rev. February 2026