ETHICAL CODE

The company Whalebone, Ltd.

Whalebone was founded in 2016. The company focuses on the development and application of cybersecurity products. It is an innovative, quality and proven product that is applied in large organizations and especially in the telecommunications sector.

The company's goal is to provide high level products and services and to emphasize the needs of the customer. The company continuously develops and improves its business processes by applying the requirements of EN ISO 9001, EN ISO/IEC 27001 standards.

In Brno on 01.03.2020

Mgr. Ing. Richard Malovič, Managing Director

 

1.1 General

1.1.1 Internal rules of conduct

Whalebone has developed a code of ethics as one of its standards as it recognizes the importance of responsible social and ethical behaviour and feels a responsibility for its employees. For Whalebone, s.r.o., these internal rules of conduct represent a set of core values and an approach to business that guide the company in the conduct of its business activities, and it expects its business partners to do the same. The Internal Code of Conduct therefore applies to all employees as well as all business partners; suppliers are included in the Code through contractual terms and conditions.

1.1.2 Legal requirements

The Internal Rules of Conduct are not generally binding legislation and therefore do not replace applicable legislation. If any part of these rules does not coincide with the applicable legislation, the legislation shall take precedence. In the event that a situation arises for which there are no specific guidelines, ethics should comply with the Rules of Conduct.

11.1.3 Seeking advice and reporting events

Whalebone strives to create conditions for every employee to have a voice in the conduct of the company or its employees.

If an employee is concerned about something and wishes to make a complaint or report a violation of the Rules and Ethical Conduct, the owner of the Company or the person responsible for compliance with the "Internal Rules of Conduct" should be notified. Complaints by employees are considered confidential information and will not be forwarded without the consent of the person making the complaint. Whalebone further excludes any action to penalize or discriminate against an employee who has made a complaint in accordance with this Code of Conduct.

1.1.4 Introduction and monitoring

Whalebone monitors the implementation of the "Internal Rules of Conduct" and violations will be addressed immediately.

1.2 Business ethics

Whalebone respects the laws and regulations on business ethics and requires the same approach from its business partners.

1.2.1 Healthy competition and antitrust legislation

Whalebone considers compliance with applicable legal standards as the main prerequisite for creating a favourable business environment. Therefore, it bases its business on lawful conduct, responsibility, reliability and trustworthiness. When dealing with its business partners, the company is committed to consistently fulfilling its contracts, agreements and obligations. It treats all business partners fairly, respects their rights, maintains good relations with them and considers all information from them to be confidential. Whalebone acts fairly, and in no way supports anti-competitive agreements or arrangements, or unfair or inaccurate comparisons. Furthermore, it is crucial for the company that the products and services offered to its customers meet high quality criteria and comply with the parameters contained in international standards and regulations. A healthy business environment and good business relations are also based on good payment behaviour. Whalebone ensures that it fulfils the obligations arising from the services it provides within the set or agreed deadlines.

1.2.2 Bribes

Whalebone is committed to actively oppose corruption and does not accept bribes or other facilitation payments or extortion in any form, whether as a provider or initiator or recipient.

1.2.3 Entertainment, gifts, tips and gratuities

Neither Whalebone nor any of its employees give or accept any gifts, gratuities or offers of entertainment that may influence an employee or customer. Exceptions are small gifts and hospitality, which are common in business relationships. If these forms of remuneration are of low value, they are acceptable after careful consideration, but only if they do not adversely affect the outcome of the business transaction.

1.2.4 Embezzlement

For Whalebone any form of embezzlement is unacceptable.

1.2.5 Records and Reports

Whalebone places the utmost importance on the integrity of the Company's record keeping and reporting system, including electronic reports and systems. The Company requires its employees to take special care in the accuracy of records and to ensure that they are completely prepared and reviewed, whether for internal or external purposes.

21.2.6 Conflict of interests

Whalebone strives to avoid conflicts of interest between the employee and the company. In the event that a conflict of interest arises, the employee is required to inform his/her immediate supervisor, the person responsible for compliance with the "Internal Rules of Conduct" or the owner of the company.

1.3 Employees' rights, human rights, consumer interests and social impact

1.3.1 Child labour

Every child (in this context, a person under the age of 15) has the right to be protected from economic exploitation and from performing work that may endanger his or her physical, mental or psychological health, impair his or her moral or social development or adversely affect his or her education. Whalebone respects this right and opposes child labour.

1.3.2 Forced or community labour

Whalebone does not recognize any form of forced or public labour, nor does it employ illegal workers.

1.3.3 Freedom of association and collective bargaining

Whalebone does not oppose the freedom of its employees to form associations of their choice, to organize and to communicate and express their ideas freely. No employee is threatened with any attack or reprisal for exercising these rights.

1.3.4 Employment contracts, working hours and compensation

Whalebone is governed by applicable laws regarding employment contracts, hours of work, including overtime, and compensation. Wages are paid to employees on a regular basis and in accordance with applicable legislation and the market situation. Employees are entitled to at least one day off per week and to observe public holidays. Employees are entitled to the stipulated annual leave, sick leave and parental leave without any negative impact.

1.3.5 Diversity and gender equality

Whalebone values and encourages diversity in the recruitment process.

1.3.6 Discrimination, Harassment and Equal Opportunity

It is crucial for Whalebone, Ltd. to provide a work environment where every employee is treated with respect and seriousness and where everyone has a fair and equal opportunity to develop. Whalebone does not tolerate any form

of discrimination or harassment in the workplace because of race, ethnicity, sexual orientation, gender, religion, age, disability, political opinion, national origin or any other potential discriminatory factor. In the event that violations are found and proven contrary to the above, management will negotiate remedies in accordance with the Company's disciplinary policies.

1.3.7 Employee Privacy

• Email correspondence: company email and internet functions may only be used for business purposes and

this communication traffic is the property of the company 3• Telephone Calls: Whalebone does not monitor telephone calls, and monitoring of telephone calls could occur only for specific reasons permitted by law. Any potential monitoring of telephone communications is subject to prior notification and approval by the employee and the company. A third party must also be notified in advance of a monitored telephone call.

• Employee work and medical records are treated confidentially and are only disclosed for legitimate reasons.

Employee health records are confidential and private and are kept separate from other employee records in locked areas. These records will not be disclosed to any person unless they are authorized by law or have the written and signed consent of the employee concerned.

• Employees' personal data is protected in accordance with the applicable provisions of EU GDPR legislation;

1.3.8 Alcohol and drug use

Whalebone does not tolerate the use of narcotics and addictive substances. It requires its employees to come to work sober and to avoid the use of alcohol or other drugs that would affect their work performance.

1.3.9 Social impact

Whalebone acts as a good citizen wherever it has operations and supports local, regional and global communities.

1.4 Environment, occupational health and safety

1.4.1 Environment and Sustainability

• Whalebone is committed to complying with local legal requirements in the conduct of its business.

• Whalebone continually strives to reduce resource consumption, prevent pollution and reduce the overall impact of its operations on the environment.

• It is important for Whalebone to support the development and implementation of technologies that have a positive impact on the environment.

• Whalebone expects all employees to support and share responsibility for the company's environmental approach.

1.4.2 Working environment

Whalebone cares about a dignified employer climate, respect for its employees, a fair remuneration system, adequate safety and hygiene at work, sufficient information for employees and improvement of their qualifications.

The company is committed to providing a safe working environment for its employees and to reducing any risks that could contribute to accidents in the workplace or adversely affect the health and mental well-being of employees.

At the same time, it requires its employees to follow the principles of safe working, to observe the established working hours, to manage properly the resources entrusted to them and to protect the company's assets. All chemicals must be properly labelled and handled safely, the work environment must be kept clean and free of contaminants, and employees must follow instructions on the use of protective and work equipment.

1.4.3 Buildings and fire safety

Emergency exits in the Whalebone building are marked, well lit and must not be blocked. Evacuation plans are displayed on all floors of the building. Fire alarm tests are carried out with regular evacuation drills. Whalebone 4informs all its employees about important safety measures such as emergency exits, fire extinguishers, first aid equipment, etc

1.4.4 First aid and medical care

Whalebone ensures that first aid equipment is available at appropriate stations and that at least one person at each station is trained in basic first aid. Medical assistance must be summoned to an accident or injury on company premises when necessary.