Code of Professional Conduct

Purpose and Applicability

The Code of Professional Conduct of CONSULTIA S.R.L. and CONSULTIA DIGITAL S.R.L. describes the shared values and minimum standards for ethical business conduct that all company personnel must follow.

The Code aims to:

• Increase service quality by creating a proper ethical climate for professional activity
• Prevent practices that do not conform to ethical and professional conduct norms and that could harm the company's activity and image

Applicability: The Code is mandatory for all Consultia personnel, regardless of position, hierarchical level, or duration of the individual employment contract. It is also expected that all persons acting on behalf of or providing services to Consultia, as well as business partners, apply similar rules and standards.

The Code takes effect as of 02.02.2022.

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Values and Principles of Conduct

Professionalism

Employees are obligated to carry out their duties with responsibility, competence, efficiency, correctness, and conscientiousness.

Social Responsibility

Consultia develops a culture of social responsibility based on: business ethics, respect for employees' rights, social and economic equity, environmentally friendly technologies, fairness in labor relations, and transparency toward clients and authorities.

Integrity

Consultia's professionals form a team with correct and honest conduct, demonstrating consistency and alignment between actions, values, principles, and legal rules. Behavior toward partners and toward society must be impeccable.

Individual Responsibility

Personnel are responsible for knowing and complying with this Code. Violation of the norms may lead to the liability of the guilty party in accordance with the Internal Regulations.

Loyalty to the Company

Employees defend Consultia's reputation and refrain from any acts or deeds that could harm its image or legitimate interests.

Objectivity

Personnel are characterized by impartiality and do not allow professional judgment to be influenced by prejudice, conflicts of interest, or other unwanted influencing factors. Management ensures equal opportunity and treatment regarding career development for subordinate personnel.

Transparency

Consultia and its personnel maintain an open and constructive dialogue with all stakeholders, based on respect and professionalism.

Non-Discrimination

Consultia, its personnel, and its business partners will not display discriminatory attitudes toward any person, regardless of race, sex, religion, sexual orientation, political affiliation, or other discriminatory criteria. Equal opportunity and a fair conduct environment are promoted.

Respect

Personnel will demonstrate respect in their interactions with other people, both in professional activities and in personal life.

Compliance with Current Legislation

Consultia's activity is carried out exclusively in compliance with current legislation. Personnel are obligated to comply with the legal regulations of their field of activity and with the Internal Regulations.

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Specific Ethical Norms

Correct Information

Personnel will ensure correct and complete information is provided to partners, within the limits prescribed by law, and will not express personal opinions or statements inconsistent with reality regarding the company's activity.

Combating Corruption

Consultia promotes a zero-tolerance policy toward corruption and fraud, reviewed periodically.

• Personnel will not use the duties of their position for purposes other than those related to fulfilling their job duties
• Gifts, services, favors, invitations, or any other advantages that could influence the exercise of duties are neither solicited nor accepted
• This prohibition extends to any advantages intended for the individual personally or for the benefit of family, friends, or persons with whom business relationships exist

Avoiding Conflicts of Interest

• Personnel will not engage, directly or indirectly, in business relationships that would affect the correct and conscientious performance of their job duties
• Decisions may not be influenced by the personal interests of the employee, their spouse, ascendants, descendants, relatives up to the fourth degree, or third parties
• Any possible conflict of interest must be declared in writing as soon as it arises, including in the case of management personnel
• Personnel involved in decision-making processes will complete a self-declaration stating they are not in a conflict of interest

Equality and Diversity

Consultia respects and guarantees equal and non-discriminatory treatment in its relations with personnel, partners, collaborators, and clients. Personnel are obligated to refrain from acts of discrimination based on nationality, sex, origin, race, ethnicity, health status, age, religion, or political beliefs.

Protecting the Organization's Assets

• Personnel are obligated to protect the company's assets and resources and to prevent damage, destruction, or unauthorized use
• Using the company's assets and resources for personal benefit is prohibited
• Any waste, misuse, destruction, or theft must be reported immediately to management
• Upon termination of the employment contract, personnel are obligated to return everything belonging to the company (physical and electronic documents)
• The company's intellectual property will not be transferred without management's consent

Confidentiality

• Throughout the duration of the individual employment contract and after its termination, personnel will not disclose data or information they became aware of during the performance of the contract
• Disclosing information that could be used to affect fair competition is prohibited
• The confidentiality obligation remains in effect even after the professional relationship ends
• Consultia guarantees the confidentiality of client information and will not disclose data to third parties, except where required by law

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Harassment

Abuse, threats, intimidation, or physical, verbal, or sexual harassment are not tolerated. Personnel must maintain decent and appropriate conduct.

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Money Laundering

Consultia will not take part in money laundering activities and undertakes to develop and implement policies and mechanisms to combat such practices, in accordance with European and international directives and standards.

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Internal and External Relations

Relationship with Personnel

• Personnel behave civilly and show respect toward superiors, colleagues, subordinates, and clients
• Relationships based on responsibility, mutual respect, collaboration, and professional support are promoted
• Management must be a model of ethical and professional behavior
• Communication channels are open bidirectionally — from management to personnel and vice versa
• Personnel will refuse requests for intervention that would affect the lawful conduct of activities

Relationship with Partners and Clients

• Consultia promotes open and fair competition, with contractual relationships conducted honestly and lawfully
• Personnel provide equal treatment to all partners and clients, without favoritism based on friendship or personal sympathy
• No attempt is made to obtain personal advantages through the use of confidential information

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Enforcement of the Code and Sanctions

Compliance with this Code is mandatory for all Consultia personnel. Non-compliance is considered a disciplinary offense and is sanctioned in accordance with legal provisions and current internal regulations.

In the event of reports concerning a violation of the Code (from within or outside the company), the company's Disciplinary Committee will conduct administrative investigations in accordance with current legislation.

Company management is obligated to develop and adopt policies to combat fraud and corruption and money laundering, and to assess the degree of their implementation.