ETHICAL CODE OF CONDUCT

ETHICAL CODE OF CONDUCT

ETHICAL CODE OF CONDUCT This Ethical Code of Conduct establishes and openly declares the basic ethical values of STV INVEST a.s. Holding, which STV INVEST a.s. acknowledges and fulfils in the relations with all its business partners, employees, as well as other natural and legal persons, organizations and institutions, which it encounters within the framework of its activities. STV INVEST a.s. Holding assumes responsibility for asserting these ethical values in places where it has demonstrable influence and the necessary competences. The Ethical Code of Conduct of STV INVEST a.s. Holding stems from internationally acknowledged standards of ethical conduct, at the same time fulfilling the requirements of the Ethical Code of Conduct of the Czech Ministry of Defence.

The aim of the STV INVEST a.s. Holding code is to declare the will of its companies and employees to abide by this code of conduct, not only in negotiations between the members of STV INVEST a.s. Holding, but also in their everyday practice and in the relations with other subjects creating the entrepreneurial environment, thus contributing to the cultivation of the entrepreneurial environment and intensification of transparency and partnership Members of STV INVEST a.s. Holding pledge to abide by the ethical code of conduct not only in their mutual relations, but also in the relations with their business partners. The ethical code. of conduct of STV INVEST a.s. Holding represents a moral pledge of each employee.

MEANING, OBLIGATIONS, SCOPE It establishes and declares the ethical values of STV GROUP a.s. (Hereinafter referred to as the Company) Company values are unambiguously applied to employees, business partners and other subjects with whom the company deals with The Company assumes responsibility for the fulfilment of these values in all areas in which it can assert demonstrable influence

SCOPE This Ethical Code of Conduct applies to companies within STV INVEST Holding, in which the Company is a sole shareholder, i.e : STV GROUP a.s. Poličské strojírny a.s. STV TRANS, s.r.o. STV ARMS, spol. s.r.o. STV MINING s.r.o. Manufacture and distribution of industrial explosives, drilling and blasting operations STV Technology, s.r.o. CZECH ARSENAL s.r.o. STV PRAHA, spol. s.r.o. Tropner s.r.o. STV Polska Sp. z o. o. Representation in Poland DAPMON, s.r.o. Representation in Slovakia STV TRADE Ltd. Representation in Bulgaria (Hereinafter referred to as STV INVEST a.s.)

This Ethical Code of Conduct is binding for all the employees, members of all bodies in STV INVEST a.s. Holding, as well as the representatives and all persons acting on behalf of STV INVEST a.s. Holding, or the individual companies of STV INVEST a.s. Holding. STV INVEST a.s. Holding expects all the concerned parties to respect and join this Ethical Code of Conduct.

8 ESSENTIAL VALUES Equality Security Environmental protection Respect and reliability Loyalty Conformity with law Openness and mutual informedness Entrepreneurial environment

1. Conformity with law In all the spheres of its activities, consistently abide by the generally binding, valid and effective legal regulations Consistently fulfil the concluded contracts, arrangements and obligations Achieve prosperity based on the principles of sustainable development Provide maximum guarantee regarding the quality of its products and services Payment discipline is regarded as the essential principle of business relations All the internal regulations of the STV INVEST a.s. Holding Group stem from the generally binding, valid and effective legal regulations. 2. Security Considers operational safety and protection of life and health as its main priority. Creates safe working Environment for all employees and persons legally active in its sites, and is very particular about regulations relating to occupational health and safety protection. Security is also important in relation to the customers, who are always informed about his products truthfully and in a non-misleading way, being especially notified of any eventual security risks.

3. Environmental protection Put forth maximum necessary effort to ensure the conformity of its activities with environmental legislation Implement the policy of activities providing for the protection of air, water treatment and waste management with the aim to achieve better parameters than those determined by valid standards Systematically create conditions for responsible long-term investment behaviour with the aim to increase both economic and environmental efficiency Provide maximum guarantees regarding the quality of its services and products 4. Respect and reliability Assert the principles of responsible and sustainable development. Carry out its activities as a long-term, fair, responsible and reliable partner, and treat with respect all the natural and legal persons, as well as other organizations and institutions encountered within the Framework of its activities Contribute to creating trustworthy and correct atmosphere in all its relations by way of its deeds.

5. Loyalty Perceive loyalty as an inherent part of relations with the employees Perceive loyalty namely as honesty and solidarity with STV INVEST a.s. Holding and its goals. The pledge of employees to protect the assets and rightful interests of STV INVEST a.s. Holding, and to refrain from causing property or moral damages to STV INVEST a.s. Holding. 6. Openness and mutual informedness Base all relations on mutual Informedness, open and transparent negotiations. Communicate about its activities and future plans in time, truthfully and openly An exception to open communication is represented by facts forming the trade secret of the STV INVEST a.s. Holding companies, as well as of its business partners, and information subject to non-disclosure liability.

7. Equality Put forth all the necessary efforts to ensure the conformity of its activities with the regulations governing human rights protection and preventing discrimination based on nationality, race, skin colour, gender, religion or social origin. The procedure of taking up positions and remuneration shall be strictly governed by professionality and results achieved. Men and women have equal conditions regarding remuneration. Ensure non-discriminating conditions towards all its employees, shareholders and customer, as well as towards others Act openly and provide all the relevant information useful for its members and partners, including the financial situation, performance, ownership and company management.

8. Entrepreneurial environment Act freely in business competition within the limits of internationally acknowledged rules of fair traide Create the atmosphere of trust and correctness with its attitude and behaviour in business relations Assert anti-corruption mechanisms to create healthy entrepreneurial environment

STV GROUP a. s. Hvězdova 2b 140 00 Prague 4 stv@stvgroup.cz