1 SCOPE OF APPLICATION

1.1 This Code of Ethics (hereinafter referred to as the “Code of Ethics”) shall be valid and binding for all companies of the OKIN Group, consisting of OKIN FACILITY, a.s., ID No. 27102378, with its registered office at Velkopřevorské náměstí 488/5, Malá Strana, 118 00 Prague 1, the Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. B 9017, and also all daughter companies of these companies and companies which are under the common control along with these companies (each of these companies hereinafter referred to as the “Company”), employees of the Company, responsible persons of the Company , as well as persons acting on behalf of the Company, persons acting as representatives of the Company and persons cooperating with the Company in any other similar manner (each of these persons hereinafter referred to as the “Worker” or together referred to as the “Workers”).

2 PURPOSE OF THE CODE OF ETHICS

2.1 The purpose of the Code of Ethics is to ensure the fulfilment of legal regulations and fundamental ethical and moral rules and principles in everyday activities of the Company and its Workers as an expression of company values and principles vis-à-vis suppliers of the Company, its business partners or other clients, the state and other public authorities, the public as a whole and the Company itself.

2.2 Also, the purpose of the Code of Ethics is to refrain from any unlawful conduct, with special emphasis on the elimination or reduction of the risk of criminal liability of the Company, stemming from the Criminal Liability of Legal Entities Act or other analogous law.

3 COMPLIANCE WITH LEGAL REGULATIONS

3.1 The Company and its Workers shall abide by all legal regulations of the Czech Republic and the European Union (or other respective legal regulations in case the Company and its Workers are subject to another legal system) and take care not to breach them.

3.2 The Company and its Workers shall refrain from infringementof legal regulations, in particular in the area of criminal and administrative offence liability.

3.3 The Company and its Workers shall also abide by all internal regulations of the Company.

3.4 The Company expresses zero tolerance against criminal and administrativeoffence acts committed by its Workers. In case such Worker, when fulfilling work-related assignments, or acting on behalf of or as a representative of the Company, or in the interest of the Company or within the framework of the Company´s activities, commits a criminal act or an administrative offence, it shall be considered their excess in which the Company does not participateand for which the Company shall bear no liability.

4 CONFIDENTIALITY, INFORMATION HANDLING AND INTELLECTUAL PROPERTY PROTECTION

4.1 The Company and its Workers shall maintain confidentiality about all facts which will be disclosed to, passed on to or shared with them based on or in relation to their activities, unless it is excluded by their character or a legal regulation.

4.2 Such facts are mainly confidential information of the Company, its suppliers, business partners or other clients, including business secrets and personal data.

4.3 The Company and its Workers shall also not unjustifiably share these facts or provide access to these fact to third parties or use them for their own benefit or for the benefit of third parties.

4.4 When working with these facts, the Company and its Workers shall act prudently and carefully and abide by all stipulated standards and procedures.

4.5 The Company and its Workers shall protect copyright, industrial property rights and other intellectual property rights.

5 CONFLICT OF INTERESTS

5.1 The Company expects from its Workers to be able to distinguish the line between their work and private life and to act in such a manner as to keep independence, objectiveness and impartiality, to avoid conflict of interests and to make decisions and carry out their responsibilities in the best interest of the Company.

5.2 Conflict of interests may arise, among other situations,in case personal, social, financial, political or other activities and interests of the Worker could influence the Worker’s decisions or the performance of his/her responsibilities or if such activities and interests appear to be influencing the Worker’s decisions or the performance of his/her responsibilities. Conflicts of interests may also arise whenvarious presents, hospitalities and other similar benefits are given or received, in close personal relationships with suppliers, business partners or other clients of the Company or in various public procurement procedures.

5.3 Conflicts of interests or suspicions thereof shall be announced by the Worker to his/her superior Worker or the Compliance Manager Department, who shall decide whether there isa conflict of interests in a given situation and what measures will be adopted. Such decision shall be adequately recorded.

6 PRESENTS, HOSPITALITIES AND OTHER SIMILAR BENEFITS

6.1 Provision and reception of presents, hospitalities and other similar benefits by the Company and its Workers must comply with legal regulations, the Code of Ethics and other internal regulations of the Company and must be transparent at all times and appropriate with respect to the particular situation and the purpose it serves.

6.2 Provision and reception of presents, hospitalities and other analogous benefits by the Company and its Workers is allowable only if they cannot influence decisions or the performanceof responsibilities of the person who receives such benefits or create perception that such benefits influence decisions or the performance of responsibilities of such person.

6.3 Presents, hospitalities and other similar benefits must not be provided nor received by the Company and its Workers as a reward or a motivation to perform illegal, unethical or immoral acts or gain unauthorized advantages.

6.4 The Company and its Workers shall not provide nor receive financial presents, hospitalities and other similar benefits in cash payment.

6.5 Presents, hospitalities and other similar benefits shall not be given to political parties, political movements or independent candidates, politically exposed persons or another subjects who have a close relationship with political parties, political movements or independent candidates ifthe provision of such benefit constitutes a breach of legal regulations, the Code of Ethics and other internal regulations of the Company.

6.6 Within the framework of beneficent activities, charitable events and other similar activities, presents, hospitalities and other similar benefits may be provided only for non-profit purposes on the basis of a prior written agreement.

7 MEASURES AGAINST BRIBERY AND CORRUPTION

7.1 The Company and its Workers shall not engage in any form of bribery or corruption.

7.2 Bribery and corruption are mainly accepting bribes, bribery, indirect bribery, machinations in insolvency proceedings, breach of regulations on rules of economic competition, arranging advantage in a public procurement procedure, public contest and public auction, machinations in a public procurement procedure and public contest, machinations in public auction. As criminal acts with signs of corrupt behaviour could be classified in a certain situation alsoa breach of duty in administration of property of another, negligent breach of duty in administration of property of another, abuse of information in business relations or abuse of status in business relations.

7.3 In accordance with the respective internal regulation of the Company, Workers shall undertake a training concerning criminal liability of legal entities a part of whichshallalso deal with measures against bribery and corruption. A special emphasis shall be placed on training of Workers working on work positions with an increased risk of bribery and corruption. Work positions with an increased risk of bribery and corruption are organisational units with process and decision-making power when acting on behalf of the Company, negotiating contracts and other agreements for the Company, dealing with property of the Company, public procurements procedures, filling vacancies, organisational units that are associated with the knowledge of important information, and organisational units which can influence decisions of the above-mentioned organisational units.

7.4 In accordance with the respective internal regulations of the Company, the Company shall perform audits concerning the fulfilment of duties associated with criminal liability of legal entities a part of which shall also deal with the control of the fulfilment of duties connected with measures against bribery and corruption.

7.5 In relation to measures against bribery and corruption, some significant indicators of their occurrence with the Workers of the Company are stated below:

a) preference of oral agreements instead of written arrangements, preference of communication via phone instead of written or email communication;

b) inadequately frequent personal contact with suppliers of the Company, its business partners or other clients and frequent personal contact with such clients without presence of other Workers;

c) inadequately frequent acceptance of invitations to celebrations and other events organised by suppliers of the Company, its business partners or other clients;

d) frequent and unproportionate presents, hospitalities and other similar benefits from suppliers of the Company, its business partners or other clients;

e) costly lifestyle without any basis in real incomes or family situation;

f) missing conflicts with counterparts in situations where they normally occur, or conspicuous compromises in dealing with counterparts or similar behavioursatisfying thecounterparts;

g) unjustified or sudden changes in standpoints or opinions;

h) enforcement of unusual processes without clear reasons;

i) failure to react to suspicious moments or matters and insufficient transparency;

j) missing documents or communication to record the taken procedure in a matter;

k) failure to follow established processes and regulations;

l) conspicuous change in the price for an assignment from the original offer and negotiation of inadequately high commissions; or

m) sudden changes in behaviour towards other Workers, increasing reserve and distance.

7.6 The Worker shall announce, in accordance with the respective internal regulation of the Company, any bribery or corruption, or suspicion about such acts, to his/her superior Worker or to the Compliance Manager Department.

8 EQUAL TREATMENT AND PROHIBITION OF DISCRIMINATION

8.1 The Company and its Workers in their relations with other Workers, suppliers of the Company, its business partners or other clients, as well as other third persons, shall behave professionally, shall avoid any form of inequal treatment or discrimination on the grounds of race, culture, ethnic origin, nationality, sex, sexual orientation, sexual identification, pregnancy, maternity or paternity, age, disability, religious belief, religion, marital status, political opinion, global opinion or other different characteristics, as well as any alleged above mentioned ground.

8.2 Harassment, sexual harassment, victimisation, instruction to discriminate orincitement to discrimination shall also be considered to bediscrimination. Exclusion or similar behaviour is not acceptable. This includes, but is not limited to: threats of violence, discriminatory jokes or language, sharing sexually explicit or violent material through electronic devices or other means, personal insults, particularly those using racist or sexist language, unwelcome sexual attention, advocacy or encouragement of any of the above mentioned behaviours.

8.3 A Worker shall report any conduct referred to in paragraphs 8.1 and 8.2, or any suspicion of it, to the Compliance Manager following the relevant internal policy.

8.4 Company respects the principles of equal treatment and non-discrimination and reflects them in its approach to all Workers and third parties, as well as in all internal processes as described in internal management documentation. The established language (use of the masculine gender, e.g. in job titles) used in the internal documentations does not affect compliance with this Code of Conduct, in particular the policy under this Article 8.

9 ENVIRONMENTAL PROTECTION

9.1 The Company has a permanent interest in improving the quality of the environment.

9.2 The Company and its Workers shall behave and act in such a manner as to protect the environment and to avoid any environmental damages.

9.3 The Company and its Workers shall contribute to the fulfilment of principles of sustainable development.

10 PUBLIC PROCUREMENT PROCEDURES

10.1 Within public procurement procedures, the Company and its Workers shall abide by only the provisions of the respective legal regulations and refrain from acts which could be interpreted as a breach of such provisions.

10.2 Within public procurement procedures, the Company and its Workers shall state only correct, complete and undistorted information and in case any non-standard procedure is found they shall announce such a fact to the respective authority.

10.3 Within public procurement procedures, including the preparation of offers or the procurement proceeding, the communication with contracting authorities or participants, performance provision within public procurement procedures and relating negotiations, the Workers shall protectonly the lawful interests of the Company.

11 MEASURES AGAINST MONEY LAUNDERING

11.1 The intent of the Company is to cooperate only with suppliers, business partners and other clients who pursue only lawful activities within their businesses and whose resources and profits come from legitimate sources.

11.2 The above being also the reason the Company and its Workers shall strictly abide by all legal regulations and measures for the protection against legitimisation of proceeds of criminal activities and financing of terrorism, including the rules regulating admissible forms and amounts of payments.

12 RELATIONSHIPS WITH THE EMPLOYEES

12.1 The Company in relation to its employees shall, in particular:

a) abide by legal regulations and the internal regulations of the Company, including the rights and lawful interests of the employees;

b) in accordance with legal regulations protect and respect employees’ privacy;

c) provide appropriate working conditions;

d) ensure health and safety protection at work;

e) provide adequate remuneration for the performed work;

f) provide information necessary for the work;

g) support employees’ education, training and other forms of their professional development;

h) abide by other rules and principles set out by this Code of Ethics.

12.2 The employees of the Company in relation to the Company shall, in particular:

a) abide by legal regulations and the internal regulations of the Company,

b) use the working hours to perform the assigned tasks;

c) protect and respect the Company´s goodwill and reputation;

d) always act to the benefit of the Company and in accordance with the rights and lawful interests of the Company;

e) handle the entrusted property in accordance with due managerialcare;

f) attend to their professional growth and development;

g) abide by other rules and principles laid down by the Code of Ethics.

13 RELATIONSHIP TOWARDS THE STATE AND OTHER PUBLIC AUTHORITIES

13.1 The Company and its Workers shall actively cooperate with the state and other public authorities.

13.2 The Company and its Workers shall provide the state and other public authorities only with timely, correct, complete, undistorted information.

13.3 The Company shall keep its official records and documents in accordance with the respective legal regulations.

13.4 The Company shall keep duly its accounts and fulfil its tax and other duties to the state and other public authorities.

14 RELATIONSHIP TOWARDS SUPPLIERS, BUSINESS PARTNERS OR OTHER CLIENTS

14.1 The Company and its Workers shall behave politely, helpfully, correctly, honestly, fair, professionally, transparently and with appropriate due care towards suppliers of the Company, its business partners or other clients in order to reach satisfaction of these suppliers of the Company, its business partners or other clients.

14.2 The Company and its Workers shall behave to suppliers of the Company, its business partners or other clients also in such a manner so as not to cause any unlawful damage to them.

14.3 The Company shall provide services and other products to suppliers of the Company, its business partners or other clients only if the Company has necessary permissions, knowledge and capacities.

14.4 The Company and its Workers shall respect fair trade rules and rules for protection against abuse and restriction of competition.

15 SUBMITTING OF COMPLAINTS, SUGGESTIONS, PROPOSALS AND OTHER SUBMISSIONS

15.1 In accordance with the respective internal regulation of the Company, the Worker may submit a complaint, suggestion, proposal or other submissionas regards the upholding, breaching or suspected breaching of this Code of Ethics, legal regulations and internal regulations of the Company, including proposals for improvement, to the Worker’s superior or to the Compliance Manager Department; in case of suspicion of a criminal act or other illegal act the Worker shall be obliged to announce such act.

15.2 In order tosubmitsuch complaints, suggestions, proposals or other submissions with the Compliance Manager Department, there is a specific e-mail address, website and phone line established in accordance with the respective internal regulation of the Company.

15.3 The Company shall review such complaints, suggestions, proposals and other submissions in accordance with respective internal regulation of the Company and if these are justified, the Company shall ensure a proper remedy, including adoption of measures to prevent repetition.

16 FINAL PROVISIONS

16.1 The Company and its Workers shall abide by all rules set out by this Code of Ethics while performing their activities.

16.2 In accordance with the respective internal regulation of the Company, the Workers shall undertake a training concerning criminal liability of legal entities.

16.3 The Company is aware that, if necessary, it must amend, update and otherwise develop this Code of Ethics.

16.4 This Code of Ethics shall be changed only in a written form.

16.5 This Code of Ethics shall be valid and effective as from 1st July 2020.