Code of Ethics

1.General Provisions

This Code of Ethics (hereinafter referred to as the Code) is an adapted version of the ETI code, a single and consolidated document that is mandatory for the company with all affiliated structures and subsidiaries, including when undergoing audits for compliance with the requirements of SMETA, ICS, SA 8000 and any other social audits.

The Code of Ethics sets high standards of corporate ethics and business conduct that both the management and all employees of the company must follow in their work.

The Code of Ethics is based on the corporate values of the company: professionalism, responsibility, fairness, democracy, customer focus, partnership and solidarity, honesty and impartiality.

The Code belongs to the internal regulatory documents of the company, as well as the documents of the company's management system. The text of the Code can be changed and supplemented during practical use. Also, it is a basis for creating local acts.

The managers and all employees of the company, regardless of their status or position, are obliged to strictly comply with the norms and requirements of the Code.

All employees and managers of the company, as well as representatives of all interested parties, must be familiar with the provisions of the Code. Failure to comply with the Code may result in disciplinary measures being imposed in accordance with the current requirements.

2. Fundamental principles of the Company's Code of Ethics

• The use of child labor is prohibited;
• Any form of discrimination is prohibited, including racial, ethnic, religious, political, as well as discrimination based on gender, age, orientation, etc.;
• The use of slave or forced labor in any form is prohibited, including the use of labor or services without remuneration or under threat of sanctions;
• Freedom of association is encouraged: all forms of representation and expression of employees' opinions permitted by applicable law are observed;
• Any encroachment on the life and health of employees is prohibited;
• In matters of remuneration for work and working hours, the relevant legislation is fully observed;
• Any form of harassment, including sexual or psychological, is prohibited;
• Participation in any corruption schemes and any form of bribery is prohibited;
• Company employees must ensure the safety and protection of any information, the illegal use of which may cause damage to the company, including commercial secrets;
• The company undertakes to comply with environmental legislation related to energy use, transportation and greenhouse gas emissions, water consumption and wastewater, emissions into the atmosphere, waste management, pollution prevention, strives to use recyclable materials, reduce and stop the use of components that are harmful to the environment;
• The company strives to benefit society by actively supporting organizations involved in social and educational programs, as well as in long-term social support programs for vulnerable categories of the population.

3.Ethical principles of the company's management

• Personal example. The company's management must demonstrate an example of ethical behavior for employees.
• Compliance with the law. The law is understood as both state laws and internal company documents, standards, agreements and employment contracts.
• Ensuring labor safety and conditions that meet labor safety requirements.
• Prevention of discrimination against company employees. Discrimination is understood as infringement in hiring, remuneration, promotion on sexual, political, religious and national grounds.
• Caring for the well-being of company employees.
• Respect for the right of company employees to participate in trade union activities.
• Creating an atmosphere of openness in business communication of company employees and their satisfaction from work.

4. Ethical principles of the Company's employees

• Responsibility. Each employee is responsible for their actions and decisions.
• Professionalism. All business relationships of company employees must comply with business practices and not contradict the law.
• Honesty. All actions of company employees must be honest.
• Integrity. Employees must strive to prevent any situation of abuse of office for their own benefit, the benefit of third parties, or to the detriment of the company.
• Strengthening the image and reputation of the company. Employees must strive to prevent situations where their actions may negatively affect the business reputation of the company.
• Respect. Each employee, regardless of the position held, must treat their colleagues with understanding and respect.
• Transparency. Employees' activities must be open and transparent. All interested parties must have the opportunity to obtain reliable and objective information, subject to the principle of confidentiality.
• Anti-corruption. Employees of the Aquaphor company are prohibited, acting on behalf of and (or) in the interests of the company, from offering, transferring or accepting any incentives or gifts, remuneration, loans, guarantees, sureties, financial assistance in the form of cash and their equivalents, regardless of the amount, securities (including deposit or savings certificates), regardless of their market value, precious metals, precious stones and jewelry made from them, if this may cause a conflict of interest in the performance of employees' duties, or if such actions violate the law or may damage the business reputation of the company.

5. Interaction with stakeholders

All stakeholders interacting with the company undertake to comply with the Code and promote compliance with this Code, familiarize their employees with it and inform Aquaphor of any difficulties in complying with the Code.

6. Final provisions

The culture and ethical nature of relationships are equally a priority and area of responsibility for each employee of the company.

With questions related to the application of this Code, each employee may contact his immediate supervisor or the senior management of the company.

This Code is communicated to management, employees and all stakeholders.