Code of Ethics of UMARUTTI s.r.o.

This Code of Ethics (hereinafter referred to as the "Code") establishes the fundamental ethical standards, principles of conduct, and responsible business practices for UMARUTTI s.r.o., located at Kozí 916/5, Staré Město, 110 00 Prague 1, Company ID: 41690885 (hereinafter referred to as the "Company"). The purpose of this Code is to create a solid framework for ethical decision-making and actions in all aspects of the Company's activities, to strengthen the trust of customers, business partners, and the public, and to actively build a corporate culture based on the highest degree of integrity. Given the nature of the Company's business, which includes wholesale trading in diamonds, precious metals, and the operation of the AreteApp platform, an unwavering commitment to ethics is a fundamental prerequisite for maintaining and enhancing its reputation and business success.

The Company hereby commits to the highest standards of ethics, professionalism, and responsibility in all its activities. This commitment is perceived as a cornerstone of all operations and goes beyond mere formal statements. Any misconduct in an industry with such high value and potential risks, such as trading in diamonds and precious metals, can have a significant impact on the credibility and continuity of the Company's business.

This Code is binding for all employees of the Company regardless of their position, as well as for members of statutory bodies and the managing director, Mr. Vladimír Kondratěnko. The Company also expects that the ethical principles of this Code will be respected to a relevant extent by its key business partners and suppliers. Extending these expectations to business partners signals the Company's effort to build and support an ethical supply chain, which is crucial in this industry for minimizing risks associated with, for example, conflict sources or unethical labor practices. The Company is aware that ethical misconduct in the supply chain can directly harm its own reputation and business, and therefore considers it essential not only to ensure internal compliance with the Code but also to actively influence its partners in accordance with modern principles of corporate responsibility.

The foundation of all Company activities and the behavior of its employees are the following key values:

• Integrity: To act honestly, truthfully, and transparently in all business relationships and transactions. This principle includes the obligation to provide accurate and unaltered information about the Company's products and services and to avoid any deceptive or fraudulent conduct.
• Honesty: To keep one's word, contractual obligations, and accepted duties.
• Fairness: To treat all employees, customers, suppliers, and other partners equally, without prejudice and discrimination. Decisions must be made based on objective criteria.
• Responsibility: To take full responsibility for one's decisions, actions, and their consequences, both individually and at the Company level.
• Respect: To respect the dignity, rights, cultural differences, and diversity of all individuals with whom the Company interacts, including employees, customers, suppliers, and members of the communities where the Company operates.

These values are not merely formal declarations but must be actively reflected in the daily actions and decisions of all individuals acting on behalf of the Company. Their specific application, such as integrity in terms of truthful and complete descriptions of diamond characteristics, enhances the clarity and binding nature of this Code.

Compliance with Legal Regulations and Internal Standards

Every employee and representative of the Company has the obligation to know and unconditionally comply with all applicable laws, regulations, and rules of the Czech Republic and potentially other jurisdictions where the Company conducts its activities. This commitment includes, among other things, labor law regulations, competition protection regulations, anti-money laundering regulations, tax laws, and personal data protection regulations.

In addition to external legal standards, all employees are required to comply with all internal guidelines, policies, and procedures of the Company. Key internal documents whose knowledge and compliance are essential include, in particular, the Terms and Conditions, the Terms of Use of the AreteApp platform, the AreteApp Privacy Policy, and the Company's internal AML policy. This Code of Ethics complements these documents and establishes a higher ethical standard that goes beyond mere compliance with legal obligations. Legal compliance is, however, considered a necessary foundation and minimum standard of ethical behavior. In case of any doubts regarding the interpretation of legal or internal standards, employees are required to consult the situation with their supervisor or the relevant department of the Company.

Management's Responsibility for Promoting an Ethical Culture

The management of the Company, including the managing director Mr. Vladimír Kondratěnko and other executives, plays a key role in promoting and maintaining an ethical culture. Management is committed to leading by example in adhering to this Code of Ethics and actively demonstrating its principles in their daily actions and decision-making. This so-called "tone at the top" is crucial, as without visible and consistent commitment from management, the Code could be perceived merely as a formal document without real impact on corporate culture.

It is the responsibility of management to actively communicate the importance of ethical behavior, ensure that the Code is understandable, easily accessible to all employees, and becomes an integral part of corporate processes. Management will also ensure the allocation of sufficient resources for regular employee training, implementation of ethical programs, and the functioning of mechanisms for reporting and addressing ethical misconduct.

Training and Raising Awareness of Ethical Standards

The Company will ensure regular and comprehensive training for all employees regarding the content of this Code of Ethics, relevant legal regulations (e.g., in the area of AML, data protection), internal policies, and procedures. The aim of the training is not only to familiarize employees with the rules but primarily to support their ability to make ethical decisions in practical situations.

The training will be tailored to different roles and responsibilities within the Company and will include practical examples, case studies, and discussions on ethical dilemmas relevant to the Company's activities, especially in the field of diamond and precious metal trading. Records of attendance at training sessions will be properly maintained. The training will not merely be a formal reading of the Code but an interactive process focused on understanding and internalizing ethical principles.

Record Keeping

The Company will maintain and preserve appropriate records documenting the implementation and compliance with this Code of Ethics and related policies and procedures. These records may include, for example, attendance lists from training sessions, materials used during training, records of conducted internal audits of ethical behavior, documentation related to investigations of reports of unethical conduct, and corrective actions taken.

All records will be maintained and stored in accordance with applicable laws of the Czech Republic, particularly regarding data protection and archival periods, and in accordance with the Company's internal rules. Diligent record-keeping is essential not only for internal control and continuous improvement of ethical programs but also as evidence for potential external audits, regulatory inspections, or other investigations.

Financial Integrity and Transparency

The Company places the highest emphasis on financial integrity and transparency in all its operations. All financial transactions must be accurately, completely, and timely recorded in the Company's accounting books in accordance with applicable Czech accounting standards, international accounting standards (if applicable), and all relevant tax and financial laws. It is strictly prohibited to create any false, misleading, or incomplete records, as well as to establish secret or unregistered funds or assets.

The Company will ensure a regular independent audit of its financial accounts by a qualified and independent auditor, or, if the nature and size of the Company allows and is in accordance with the law, an independent review of the financial accounts. The results of the audit or review will be taken with full seriousness, and any recommendations will be implemented.

The Company is committed to transparent reporting on its relevant business practices and financial results in accordance with applicable legislation and principles of good governance. The connection between financial integrity and the overall ethics of the Company is crucial, as financial discrepancies can often be symptoms of deeper ethical issues and can seriously damage the credibility and reputation of the Company.

Prohibition of Bribery and Corruption

UMARUTTI s.r.o. implements a zero-tolerance policy towards any form of bribery, corruption, extortion, or undue influence. This prohibition applies to all employees, directors, and representatives of the Company and to all their actions, whether directly or indirectly, in relation to public officials, representatives of state and private organizations, business partners, and any other third parties.

It is strictly prohibited to offer, promise, give, request, or accept any unauthorized benefits – whether financial (e.g., cash, loans, commissions) or non-financial (e.g., gifts, hospitality, services, job opportunities for family members) – with the aim of obtaining or retaining a business opportunity, securing an undue advantage, influencing business or official decisions, or as a reward for such influence.

Particular caution is required when providing and receiving gifts, hospitality, and other similar benefits. These must always be appropriate to the situation, transparent, in accordance with applicable legal regulations and the Company's internal rules. Gifts and hospitality must not be provided or accepted if they could be perceived as an attempt at improper influence. The Company may establish internal procedures for the approval and recording of gifts and hospitality (e.g., gift registry) exceeding a certain value.

The Company pays special attention to the issue of so-called "facilitation payments," i.e., small unofficial payments to government officials to expedite or secure routine administrative actions. Such payments are generally prohibited. If the applicable laws of a given country exceptionally allow such payments, the Company will still strive to eliminate them and ensure their strict control, documentation, and approval at the highest level.

Clearly defining what constitutes a bribe and an undue advantage is key to preventing ambiguities and ensuring compliance with this prohibition. All employees are required to familiarize themselves with these rules and, in case of any doubts, consult the situation with their supervisor or the relevant department.

Respect for Human Rights

UMARUTTI s.r.o. is fully committed to respecting and promoting all internationally recognized human rights in all its operations, business relationships, and communities affected by its activities. This commitment is in line with the Universal Declaration of Human Rights of the United Nations and other relevant international conventions and standards.

Respect for human rights includes, among other things, the prohibition of any form of discrimination, forced labor, and child labor. The Company further commits to ensuring fair and safe working conditions, freedom of association and collective bargaining within the law, and the protection of the privacy of its employees and business partners.

The Company will conduct due diligence to identify, prevent, mitigate, and account for any negative impacts of its activities on human rights, both within its own operations and within its supply chain. This process will include risk assessment, implementation of preventive measures, and, if necessary, corrective actions. Recognizing that human rights are not only an issue of working conditions but also encompass broader impacts of the Company's activities, such as on communities in resource extraction areas, is crucial. Connecting this commitment with due diligence processes in the supply chain is essential to minimize risks, such as "blood diamonds" or other forms of exploitation.

Responsible Sourcing and Due Diligence

UMARUTTI s.r.o. is committed to sourcing diamonds, precious metals, and all other materials used in its activities exclusively from legitimate and responsible sources. These sources must not be involved in financing conflicts, human rights violations, illegal activities, or other unethical practices and must comply with relevant international standards, including UN resolutions and principles of responsible sourcing of raw materials. This commitment is already partially declared in Article 9.1 of the Company's Terms and Conditions.

To this end, the Company implements and will continuously improve robust due diligence procedures throughout its supply chain. The aim of these procedures is to identify, assess, and manage risks associated with the origin of materials. Particular attention will be paid to risks related to:

• Armed conflicts and their financing.
• Serious human rights violations (including child labor, forced labor, inhumane treatment).
• Money laundering and financing of terrorism.
• Corruption and illegal payments.
• Negative impacts on the environment and local communities.

These procedures will be inspired by internationally recognized frameworks, such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

An integral part of due diligence includes rigorous "Know Your Customer" (KYC) procedures and anti-money laundering (AML) efforts. The Company will apply these procedures to all its business partners (suppliers and customers) to verify their identity, legality, and legitimacy of their business and, in justified cases, their ultimate beneficial owners. These procedures will be fully compliant with the Company's internal AML policy, the existence of which is mentioned in the Company's documentation. The AML/KYC processes will include ongoing monitoring of transactions for unusual or suspicious activities and their reporting to the relevant financial and investigative authorities in accordance with applicable legislation and the internal AML policy. All records related to KYC and transactions conducted will be carefully maintained for the period specified by law and internal regulations.

The Company explicitly commits not to knowingly purchase or sell conflict diamonds and will actively support the principles of the Kimberley Certification Scheme for the trade in rough diamonds as a key tool to prevent the trade in conflict diamonds, even without formal membership in initiatives promoting this system.

Effective implementation of due diligence and KYC/AML procedures is not seen merely as compliance with regulatory obligations but as an active contribution to the integrity and credibility of the entire diamond and precious metals trade industry. Through this approach, the Company builds a trustworthy ecosystem and protects itself and its partners from risks associated with illegal and unethical practices.

Ethical behavior of business partners

UMARUTTI s.r.o. recognizes that its ethical responsibility extends beyond its own operations and includes its supply chain. Therefore, the Company expects its suppliers, key business partners, and other collaborating entities to share and adhere to similar high ethical standards as defined in this Code. These expectations particularly pertain to areas such as respect for human rights, ensuring fair and safe working conditions, environmental protection, combating corruption and bribery, and transparent business practices.

The Company will strive to build long-term and mutually beneficial relationships with those business partners who demonstrate a clear commitment to ethical conduct and responsible business practices. Within its capabilities and reasonable influence, the Company will communicate its ethical expectations to its partners and support them in their efforts to meet these standards. This may include sharing information about best practices or engaging in dialogue about improvement opportunities.

The Company reserves the right to reassess or terminate business relationships with partners who repeatedly or seriously violate fundamental ethical principles or refuse to engage in constructive dialogue about remediation. A proactive approach to ethics in the supply chain is crucial for protecting the Company's reputation and contributing to positive changes across the industry. The Company may consider implementing a specific code of conduct for suppliers or incorporating relevant ethical clauses into contractual agreements with key partners.

Product integrity and truthful information

UMARUTTI s.r.o. is committed to the highest level of integrity of its products and to providing accurate, complete, truthful, and understandable information about all offered products, especially diamonds and precious metals. This commitment applies to information about their origin (to the extent possible and available from responsible sources), nature, quality, weight, purity, and any modifications that may affect their properties or value.

Particular emphasis is placed on accurate labeling and communication of the difference between natural diamonds and laboratory-created diamonds (synthetic). The Company will ensure consistent and clear differentiation between these two categories of products in all its communications, marketing materials, documentation (including invoices and certificates, if issued by the Company), and at the point of sale. This practice is in accordance with Article 9.3 of the Company's Terms and Conditions, which imposes the obligation of proper labeling of laboratory-created diamonds on its buyers as well. The goal is to ensure that customers (wholesale buyers) are always fully and clearly informed about the nature of the diamonds purchased and can accurately pass this information on.

The Company will also transparently inform about any known modifications to diamonds or other gemstones that have been made to change or enhance their color, clarity, or other properties, provided these modifications are not generally recognized practices of cutting. This information will be included in the offer of such a product.

Any form of misleading advertising, deceptive marketing practices, or distortion of information about products is strictly prohibited. All claims and statements regarding products must be substantiated and verifiable. Emphasis on product integrity and transparency in communication, especially concerning laboratory-created diamonds, is crucial for the Company not only from an ethical standpoint but also for maintaining trust in a market where this issue is becoming increasingly significant. Through this approach, the Company positions itself as a trustworthy and responsible partner in the industry.

The table below summarizes the key product information that UMARUTTI s.r.o. always provides to its customers to ensure maximum transparency:

Table justification: This table provides a clear and structured overview of the Company's commitments to transparency regarding key product characteristics. It facilitates understanding for both internal employees responsible for sales and marketing, as well as external partners and customers, and strengthens trust in the integrity of the products offered by UMARUTTI s.r.o.

Fair labor practices and working conditions

UMARUTTI s.r.o. is committed to creating and maintaining a work environment where all employees are treated fairly, with dignity and respect. This includes ensuring fair compensation for work performed, which will comply with applicable laws of the Czech Republic, relevant collective agreements (if any), and will be competitive within the industry and region.

The Company will strictly adhere to legal limits on working hours, including rules for overtime, and will ensure employees' rights to rest, daily and weekly breaks, and paid leave in accordance with the Labor Code. All employees will be provided with clear, understandable, and written employment contracts that will include all essential elements of the employment relationship, including job description, salary, working hours, and other working conditions.

Fair working conditions are not only an ethical imperative but also contribute to higher motivation, satisfaction, and loyalty among employees, which has a direct positive impact on the overall performance and success of the Company.

Prohibition of discrimination, promotion of diversity, equality, and inclusion

UMARUTTI s.r.o. strictly rejects and does not tolerate any form of discrimination in the workplace. Discrimination based on race, color, religion, gender, sexual orientation, gender identity, nationality, ethnic origin, age, disability, marital status, political beliefs, or any other legally protected or irrelevant characteristic is unacceptable. This principle applies to all aspects of the employment relationship, including recruitment, selection of employees, compensation, assignment of tasks, professional development, promotions, and termination of employment.

The Company is committed to creating a work environment based on mutual respect, where every employee has equal opportunities to utilize their abilities and to grow professionally. It will actively promote diversity, equality, and inclusion at all levels of the organization. It recognizes that a diverse team brings different perspectives, experiences, and skills that can enrich the corporate culture, foster innovation, and improve decision-making processes. Proactive support for diversity and inclusion is not only a fulfillment of an ethical requirement but also a strategic advantage that contributes to the long-term sustainability and competitiveness of the Company.

Prohibition of harassment and violence

UMARUTTI s.r.o. implements a zero-tolerance policy towards any form of harassment, bullying, intimidation, psychological pressure, or physical violence in the workplace or in connection with work performance. This includes, but is not limited to, sexual harassment, verbal attacks, threats, degrading treatment, or any other behavior that creates a hostile, intimidating, or offensive work environment.

The Company will ensure the establishment and communication of clear rules and procedures for the prevention, reporting, and resolution of cases of harassment and violence. A safe and confidential mechanism will be created through which employees can report such incidents without fear of retaliation. Every report will be taken seriously, investigated promptly and impartially, and if a violation is confirmed, appropriate corrective and disciplinary measures will be taken. It is crucial to create an atmosphere of trust where victims or witnesses will not be afraid to report incidents and know that the Company does not tolerate such behavior and will actively address it.

Prohibition of child and forced labor

UMARUTTI s.r.o. strictly prohibits and does not tolerate the use of child labor or any form of forced, involuntary, or slave labor. This prohibition applies unconditionally to the Company's own operations, and the Company is also committed to actively ensuring that these practices are not present in its supply chain.

The Company will comply with the minimum age for employment established by applicable laws of the Czech Republic and international conventions, particularly those of the International Labour Organization (ILO). Persons younger than the legally permitted age for the type of work will not be employed.

The commitment to eliminate child and forced labor will be actively verified within the due diligence processes in the supply chain, particularly when sourcing materials from geographical areas where these risks may be higher. Any findings or reasonable suspicion of the use of child or forced labor by a business partner will lead to an immediate investigation and potentially to the suspension or termination of the business relationship.

Freedom of Association

UMARUTTI s.r.o. respects the right of its employees to freely associate, including the right to establish or join trade unions and the right to collective bargaining, all in accordance with applicable laws of the Czech Republic and international conventions ratified by the Czech Republic.

The Company will not in any way hinder employees from exercising these rights, nor will it discriminate or retaliate against them for exercising these rights. If employees decide to establish a trade union or engage in collective bargaining, the Company will engage with their legitimate representatives in good faith. Even in an environment where union organization may not be common in small and medium-sized enterprises, respect for this fundamental labor right is an important ethical principle that the Company honors.

Occupational Health and Safety (OHS)

Ensuring a safe and healthy working environment for all employees is a priority for UMARUTTI s.r.o. The Company is committed to actively preventing workplace injuries, occupational diseases, and any other health impairments related to work performance.

To this end, the Company will:

• Strictly comply with all applicable laws, regulations, and technical standards in the field of occupational health and safety.
• Regularly identify, assess, and manage risks in the workplace and take appropriate preventive measures to eliminate or minimize them.
• Provide employees with necessary OHS training, inform them about potential risks and safe working practices.
• Provide suitable and certified personal protective equipment (PPE) free of charge where necessary, and ensure its proper use.
• Ensure the proper condition of workplaces, machines, equipment, and tools, and their regular maintenance and inspection.
• Have procedures in place for emergencies, including evacuation plans and first aid provisions.

OHS is not perceived merely as compliance with legal obligations, but as a manifestation of genuine care for the health, safety, and overall well-being of employees, which is a fundamental prerequisite for quality and productive work.

Protection of Company Assets and Information

Every employee of UMARUTTI s.r.o. has the obligation to protect the Company's assets from loss, damage, misuse, or theft. These assets include not only tangible goods (e.g., buildings, equipment, inventory) but also intangible assets such as intellectual property (e.g., software, databases, trademarks, know-how), financial resources, and the Company's reputation.

Particular emphasis is placed on the protection of confidential information. Employees are required to handle all confidential information of the Company, its customers, suppliers, and other business partners with the utmost care and discretion. Confidential information must not be disclosed to third parties without authorization or used for personal gain or other unauthorized purposes. This obligation also applies to information stored and processed within the AreteApp platform and is in compliance with applicable data protection regulations (GDPR) and trade secret protection. In the digital age, the protection of data and information is as important as the protection of physical assets, and therefore the Company implements appropriate technical and organizational measures to secure them.

Conflict of Interest

Employees of UMARUTTI s.r.o. are required to act always in the best interest of the Company and to avoid situations where their personal interests, the interests of their family members, or close persons may conflict with the interests of the Company, or where such a conflict could reasonably be perceived.

A conflict of interest may arise in various forms, such as participation in businesses that compete with the Company, financial investments in competing or supplier companies, accepting gifts or benefits that could influence the objectivity of decision-making, or employing family members without a transparent process.

Every employee is obliged to promptly and transparently declare any potential or actual conflict of interest to their direct supervisor or designated responsible person within the Company. The Company will then assess the situation and decide on further action to protect the interests of the Company and maintain the objectivity of decision-making. The existence of clear rules for reporting and resolving conflicts of interest is crucial for maintaining trust and integrity in all activities of the Company.

Environmental Management

UMARUTTI s.r.o. is aware of its responsibility towards the environment and is committed to minimizing the negative impacts of its activities on the environment and promoting sustainable practices in all aspects of its business. This commitment includes not only compliance with applicable environmental laws and regulations but also a proactive approach to protecting natural resources and preventing pollution.

The Company will implement and maintain an environmental policy and procedures aimed at:

• Identification and assessment of the environmental aspects and impacts of its activities.
• Setting goals and programs for the continuous improvement of its environmental profile.
• Prevention of air, water, and soil pollution.
• Protection of biodiversity and ecosystems in areas where it may operate (especially in the context of the supply chain).
• Increasing environmental awareness among its employees.

Environmental responsibility is becoming an increasingly important factor for customers, investors, and the broader public, and the Company perceives it as an integral part of its overall strategy and ethical framework.

Handling of hazardous substances, waste, and emissions

UMARUTTI s.r.o. will ensure the safe and responsible handling of any hazardous substances that may be used in its operations, in accordance with applicable legislation and best available practices. A precise inventory of these substances will be maintained, and all requirements for their storage, handling, and disposal will be adhered to.

The Company is committed to minimizing waste generation in all its activities. It will actively support the principles of waste management hierarchy, i.e., waste prevention, preparation for reuse, recycling, and other forms of waste recovery before final disposal. All waste will be sorted and disposed of responsibly through authorized persons and in accordance with applicable regulations. Even wholesale activities may generate waste, such as packaging materials, and the Company will strive to minimize them and ensure their environmentally friendly disposal.

The Company will also monitor and strive to reduce emissions to air, water, and soil that may arise from its activities, including greenhouse gas emissions associated with energy consumption and transportation. Improper handling of hazardous substances, waste, and emissions can lead to serious environmental damage and pose health risks, which the Company actively seeks to prevent.

Efficient use of natural resources

UMARUTTI s.r.o. is committed to the efficient and prudent use of natural resources, particularly energy, water, and other materials necessary for its operations. It will strive to reduce the consumption of these resources per unit of production or service and seek opportunities for their conservation and more efficient use.

This includes:

• Monitoring energy and water consumption and implementing measures to reduce their waste.
• Supporting the use of energy-efficient technologies and practices.
• Considering the use of renewable energy sources where technically and economically feasible.
• Minimizing the consumption of raw materials and materials and preferring recycled or sustainable alternatives when available and appropriate.

Conserving natural resources not only contributes to environmental protection but can also have a positive economic impact on the Company by reducing operating costs. This approach is in line with the principles of sustainable development and responsible business.

Reporting unethical behavior and protection of whistleblowers

UMARUTTI s.r.o. promotes a culture of openness and transparency and encourages all its employees, as well as external collaborators and business partners, to report any suspicion of violations of this Code of Ethics, applicable legal regulations, or the Company's internal directives. Establishing and maintaining trustworthy and secure reporting channels is crucial for preventing and detecting unethical behavior.

The Company has established an internal reporting system in accordance with Act No. 171/2023 Coll., on the protection of whistleblowers. Detailed information on how to submit reports, the procedures for handling them, and the protection of whistleblowers is available on the Company's website and/or upon request. For matters related to the use of the AreteApp and Diamond Studio platforms, an email address is available at [email protected]. This Code of Ethics fully integrates and refers to these already established procedures.

The Company is committed to protecting whistleblowers who act in good faith. Any form of retaliation, discrimination, or other negative treatment against a person who has made a report is strictly prohibited. The identity of the whistleblower will be protected to the maximum extent permitted by law and in accordance with internal procedures for handling reports. A functional and trustworthy whistleblowing system is seen as one of the most effective tools for detecting and preventing unethical behavior and for strengthening the ethical culture within the Company. It is crucial that this system is perceived by all as safe, fair, and effective.

Investigation and disciplinary proceedings

All reports of possible violations of this Code of Ethics, applicable legal regulations, or the Company's internal directives will be taken seriously and will be properly, impartially, and promptly investigated by the designated responsible person or committee, in accordance with the Company's internal procedures. The aim of the investigation is to objectively ascertain the facts and assess whether a violation has occurred.

If the investigation proves a violation of the Code of Ethics, appropriate and proportionate disciplinary measures will be applied against the responsible individuals. These measures may range from oral or written reprimands, financial penalties, reduction of personal evaluation, reassignment to different work, to termination of employment or contractual relationship, always in accordance with applicable labor law regulations and other relevant laws. In cases where the conduct may constitute a criminal offense or misdemeanor, the Company reserves the right to refer the matter to law enforcement authorities or other relevant state bodies.

A transparent, consistent, and fair process of investigation and application of disciplinary measures is essential for maintaining trust in the Code of Ethics and for demonstrating the Company's commitment to its enforcement.

Regular Review and Update of the Code

This Code of Ethics is not a static document, but a living tool that must reflect developments in legislation, business practices, ethical standards, and stakeholder expectations. For this reason, the Code will be regularly reviewed, at least once a year, or as needed (e.g., in the event of significant changes in the Company's activities or in the regulatory environment), by the Company's management.

The aim of the review is to ensure that the Code remains current, relevant, understandable, and effective in promoting ethical behavior and compliance within the Company. Relevant employees and possibly external experts may be involved in the review process. Any proposed changes or additions to the Code will be duly approved by the Company's management and subsequently communicated to all employees. Regular review and updates are key to maintaining the dynamics of the ethical culture and adapting to the constantly changing business and social environment.

Compliance with this Code of Ethics is a fundamental duty of every employee and representative of UMARUTTI s.r.o. Violations of this Code may lead to disciplinary measures, including possible termination of employment or contractual relationship, and in serious cases, legal action.

Every employee is obliged to thoroughly familiarize themselves with the content of this Code and, in case of any ambiguities or the need for consultation regarding its interpretation or application, to contact their direct supervisor or the designated contact person in the Company responsible for ethics and compliance.

This Code of Ethics of UMARUTTI s.r.o. comes into effect on.

In Prague on 25.05.2025

Vladimír Kondratěnko

Managing Director of UMARUTTI s.r.o.