Let us introduce our

Code of Conduct

Neos Code of Business Conduct

Neos has set a high standard of ethics and business conduct – in the technology field of business, legal, social, and other business and ethical values. We highly value business ethics, which includes compliance of business with all laws and regulations in force.

At the same time, we also expect such approach to business conduct from our partners and suppliers.

For that purpose, we have prepared this Code of Conduct. This document provides to our suppliers and clients – business partners – a short overview of principles and obligations that NEOS has adopted in its business conduct. In our relations with clients and suppliers we aim at applying the same principles and building a relationship based on mutual regard
and respect, as well as responsibility by all involved parties.

With its solutions and applications Neos is present on the world market. Our goal is to spread positive world practices to all entities with which we cooperate and achieve compliance with all companies being our key suppliers.

Compliance to laws and regulations, including other legal requirements and policies

NEOS and its business partners conduct business in line with all effective laws and regulations wherever they do business. When local laws are less restrictive than this Code, Neos will comply with the Code, even if our conduct would otherwise be legal. If local laws are more restrictive than the Code, we will always, at a minimum, comply with such
laws.

Neos expects its employees to:

– Act ethically and with integrity in all business dealings,
– Comply with the law, this Code, other Neos policies and business practices, specifically but not only regarding quality and security,
– Report known or potential violations using available reporting channels,
– Actively cooperate with compliance audits and investigations,
– Actively inform themselves regarding Neos compliance requirements, policies, and business practices.

Further, Neos expects its managers to:

– Promote and support ethical behaviour and business practices that comply with this Code,
– Act as a leadership model for this Code,
– Ensure that employees who report to them directly or indirectly understand where and how to report violations of this Code,
– Ensure that employees who report to them directly or indirectly complete all mandatory compliance education courses and other requirements in a timely manner,
– Maintain an “open door” policy with regard to employee questions, including those of business conduct and ethics, and ensure availability of compliance and ethics resources and support, such as printed materials and relevant contact information,
– Encourage employees to challenge and report questionable conduct,
– Encourage open, honest, and confidential dialogue without retaliation.

This Code is important vehicle for Neos operation, and it is revisited from time to time. Current version is provided to all employees and clients in company web site, as well as internally on Neos Management System.

Ethical business conduct

Neos and its business partners will always use their best efforts to conduct their business in line with the highest ethical standards. NEOS and its business partners will always strictly comply with all laws and regulations regarding bribery, corruption and forbidden business practices.

Security and compliance

Neos is constantly working on preventing security incidents and reducing their potential impact. Our policy is to protect the organization’s and our clients’ informational assets against all internal, external, deliberate, or accidental threats. All our consultants are professionals with high awareness of security issues. All our clients are protected on legal level by NDA and other documents on company level and personal level for our staff.

Neos policy is to always work with client’s data on their location. Client’s data is never copied or otherwise removed from original site and location, or otherwise threatened by Neos staff. Client data we are working on is anonymised, masked and otherwise secured from unauthorized view, analysis and distribution.

Neos as company is certified according to ISO 27001 and 27017 standards and actively promotes adherence to this and other professional standards regarding security.

Environment protection

Neos and its business partners do business in a manner that protects the environment. Business will always be conducted in line with all effective environment protection laws, regulations and standards, such as requirements regarding conservation of resources such as water, management and disposal of waste and chemical substances, recycling, emission control, ecological licenses and environment protection reporting.

Communication

Neos and its business partners shall make the principles of business conduct and other relevant information available to their employees in English and/or their respective native language. We will clearly and positively communicate our business, ethical and other values, including our obligations defined by this Code.

Health and safety

Neos secures to our employees a safe and healthy workplace, above or at least in compliance with the valid laws and regulations. We strongly comply to legal obligations regarding work and other health and safety policies and regulations defined by professional bodies as well as state defined laws. In line with those obligations, Neos introduces and implements effective programmes covering safety, incident investigation, ergonomics etc. and secure the same health and safety standard in all areas assigned for the employees.

Respect and dignity

Neos consistently treat all employees with respect and dignity, regardless of their position in organisation. Neos employees never use violent threats or other forms of psychological and physical coercion or harassment.

Discrimination ban

Neos as a company and its employees do not discriminate anyone based on position, gender, religion, age, nationality, social or ethnic group, race, sex orientation, gender identity or expression, marital status, pregnancy, disability, political orientation, or any other individual characteristic. Any type of discrimination is banned from Neos, and we expect same conduct from our business partners.

Salary and benefits

Neos pays work remuneration at a minimum in line with all valid laws and regulations regarding salaries and hourly rates. This includes compensations and regulations regarding minimum wages, overtime work, rates and other elements of remuneration and securing of benefits provided for by the law.

Quality

Neos employees make excellence and quality a part of day-to-day work processes and seek continuous improvement in all that they do. Neos as company is certified according to ISO 9001 standard and actively promotes adherence to this and other professional standards regarding quality of our processes, work in general and our products and services.

Working hours

Neos does not exceed valid local working hours and overtime work is compensated appropriately. The employees shall not work more than the prescribed number of hours per week, including overtime work, except in extraordinary circumstances and provided they agree to do so. In the countries where a maximum work week is shorter, such standards shall be applied. The employees are permitted a minimum of one free day in a seven-day working week.

Forced labour

NEOS and its business partners shall never use forced labour of any kind (e.g., compulsory, debt bondage or slave labour). Employment shall always be voluntary.

Child labour

NEOS and its business partners shall not use child labour. The term “child” refers to any employed person of the age below 15 (or 14 were permitted so by federal law), that has not completed mandatory education or has not yet reached the minimum age for employment in the country, taking into consideration the higher threshold. We support use of legitimate apprenticeship programmes that are in line with any laws and regulations applied to such apprenticeship programmes.

Freedom of association

NEOS and its business partners comply with all legal rights of the employees to join or refrain from joining labour organisations, including unions. The partners have the right to establish favourable business conditions and maintain effective communication programmes for their employees as a means of promoting positive employee relations with a view to employees considering third party representation not necessary.

Conflict of interest

A conflict of interest occurs when personal interests of an employee or the interests of a third party compete with the interests of Neos. Employees should avoid conflicts of interest whenever possible.

However, if such a situation has occurred or an employee faces a situation that may involve or lead to a conflict of interest, they are advised to disclose the matter to their immediate supervisor and/or a member of the Management and/or company Board, as soon as reasonably possible with a view to resolving the situation in a fair and transparent
manner.

Antitrust and competition

Neos conducts its business in multiple countries, and we adhere to all laws and regulations that prohibit unlawful restraint of trade, usually referred to as antitrust or competition laws. These laws are designed to protect consumers and competitors against unfair business practices and to promote and protect healthy competition. Neos commits
rigorously to observing applicable antitrust or competition laws of all countries or organizations.

Bribery and corruption

Neos condemns any form of bribery and corruption. Our employees must never, either directly or through intermediaries, offer or promise any personal or improper financial or other advantage in order to obtain or retain business or other advantage from a third party. Nor must they accept any such advantage in return for any preferential treatment of a third party.

Gifts, meals and entertainment

Neos employees shall not be influenced by receiving favours nor shall they attempt to improperly influence others by providing favours. Employees may only offer or accept reasonable meals and symbolic gifts which are appropriate under the circumstances. In case of doubt as to the appropriateness and value of gifts, meals and entertainment, employees are advised to consult with their immediate supervisors and/or members of the Management and/or company Board or apply the most restrictive practice with a view to avoid even the appearance of improper dealings.

Gifts shall specifically not include money, loans, kickbacks or similar monetary advantages.

Improper Payments

Neos strictly adheres to policy of no improper payments. Our employees are prohibited from receiving, offering, promising, authorizing, directing, or making any bribes, kickbacks, or payments of money or anything of value to improperly obtain business or any other advantage for Neos as a company or for themselves.

The above prohibition applies whether such payments go to:

– Government or public international organization employees or officials
– Political parties or candidates for political office
– Business entities partially or wholly owned by government interests
– Privately-held commercial companies
– Neos employees
– Or any other third party.

Neos strictly prohibits giving money or anything of value directly or indirectly to a government official for the purpose of corruptly influencing a government deal. This prohibition includes corruptly giving money or anything of value to any third party where there is reason to believe that it will be passed on to a government employee or official.

Dealing with the government

Neos strictly observes the laws, rules, and regulations that govern the acquisition of goods and services by any governmental entity of any country and the performance of government contracts. This is also expected from our business partners.

Neos employees who deal with any governmental agency, including international organizations, are responsible for learning and complying with all rules that apply to government contracting and interactions with government officials and employees. Neos employees take special care regrading activities when dealing with government officials as they may be acceptable or appropriate when dealing with non-government clients. Inappropriate activities can result with penalties which can have severe impact on Neos business, but also can include civil and criminal fines and imprisonment.

Neos employees will not attempt to obtain procurement sensitive government information, confidential internal government information, such as pre-award, source selection information, or proprietary information of a competitor, including, for example, bid or proposal information, during the course of a procurement or in any other circumstances
where there is reason to believe the release of such information is unauthorized.
Neos employees must strictly observe all laws and regulations regarding classified information, and specially so in case when dealing with government bodies.

Always, and specifically when dealing with government bodies, Neos employees will conduct according to guidelines given in above paragraphs dealing with bribery, corruption, influencing with gifts and in other manners, and all positive guidelines provided in this document.

Lobbying of government officials

Neos deals with government bodies through government officials, in a way that complies to here given guidelines. Our interactions with the government are governed by lobbying laws and regulations. Lobbying is any activity that attempts to influence laws, regulations, policies, and rules, but in certain jurisdictions can also cover procurement and business development activity. These laws can apply to elected officials as well as appointed officials and generally government employees. The company may have an obligation to register and/or report the company’s lobbying activities under applicable law. These include activities by Neos employees and outside consultants or advisors on government relations. Neos employees are responsible for knowing when their activities may be considered lobbying and in case of doubt should consult the Neos management and/or the Board for guidance.

Money laundering

Money laundering is the process by which persons or businesses attempt to conceal the origin and ownership of the proceeds of illegal activity such as fraud, theft, drug trafficking, or any other crime. It may also involve the use of legitimately derived funds to finance terrorism.

Neos is committed to minimising the risk of being used as a vehicle for such illegal activity. To that end Neos will comply with all anti-money laundering laws and regulations in force and strive to do business with reputable business partners who conduct lawful business activities and whose funds come from legitimate sources.

Economic Boycotts

Neos and its business partners do not participate in any business activity with any country that is under economic boycott and/or sanctioned by the EU, USA and/or Croatian government or under US sanctions. Neos employees are prohibited to undertake any business activity with a company or government in a country that is the object of an boycott as stated above, as well as any “blacklisted” company.

Monitoring of compliance

NEOS and its business partners introduce into their business documentation and practices required for proving compliance with the principles of positive business conduct and allow access to such documentation to all competent authorities.

What to do in case of concern

Neos employees have multiple options for reporting allegations of misconduct. Depending on the circumstances, these include:

– Mentor (if applicable),
– Immediate supervisor/manager,
– Human Resources office,
– Company Management,
– Company Board.

1 October 2011
The Board of Neos d.o.o.

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