Code of Ethics of UMARUTTI s.r.o.

This Code of Ethics (hereinafter the “Code”) sets out the fundamental ethical standards, principles of conduct, and responsible business practices for UMARUTTI s.r.o., with its registered office at Kozí 916/5, Staré Město, 110 00 Prague 1, Company ID No.: 41690885 (hereinafter the “Company”). The purpose of this Code is to create a solid framework for ethical decision-making and conduct 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 level of integrity. Given the nature of the Company’s business, which includes wholesale sales of diamonds, precious metals, and operation of the AreteApp platform, an unwavering commitment to ethics is a fundamental prerequisite for maintaining and strengthening its reputation and business success.

By this Code, the Company subscribes to the highest standards of ethics, professionalism, and responsibility in all its activities. This commitment is regarded as a cornerstone of all operations and goes beyond a mere formal declaration. Any misconduct in an industry of such high value and potential risks as the trade in diamonds and precious metals may have a material impact on the credibility and continuity of the Company’s business.

This Code is binding on all employees of the Company regardless of their position, as well as on members of the statutory bodies and the managing director, Mr. Vladimír Kondratěnko. The Company also expects that the ethical principles of this Code will, to a relevant extent, be respected 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 to minimize risks associated, for example, with conflict sources or unethical labor practices. The Company is aware that ethical misconduct in the supply chain may directly harm its own reputation and business, and therefore considers it necessary not only to ensure internal compliance with the Code, but also to actively influence its partners in line with modern principles of corporate responsibility.

The following key values form the basis of all the Company’s activities and the conduct of its employees:

• 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 misleading or fraudulent conduct.
• Honesty: To keep one’s word, contractual commitments, and accepted obligations.
• Fairness: To treat all employees, customers, suppliers, and other partners equally, without prejudice or discrimination. Decisions must be made on the basis of objective criteria.
• Responsibility: To accept 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 comes into contact, 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 day-to-day conduct and decision-making of all persons acting on behalf of the Company. Their specific application, for example integrity in the sense of a truthful and complete description of the characteristics of diamonds, increases the clarity and enforceability of this Code.

Compliance with legal regulations and internal standards

Each employee and representative of the Company is obliged to know and unconditionally comply with all applicable laws, decrees, and regulations of the Czech Republic and, where applicable, other jurisdictions in which the Company conducts its activities. This commitment includes, among other things, labor-law regulations, competition-law 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 directives, 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 sets a higher ethical standard that goes beyond mere fulfillment of legal obligations. Legal compliance is, however, considered a necessary foundation and the minimum standard of ethical conduct. In the event of any doubts regarding the interpretation of legal or internal standards, employees are obliged to consult the situation with their supervisor or the relevant department of the Company.

Management responsibility for promoting an ethical culture

The Company’s management, including the managing director, Mr. Vladimír Kondratěnko, and other managers, plays a key role in promoting and maintaining an ethical culture. Management undertakes to lead by example in complying with this Code of Ethics and to actively demonstrate its principles in its day-to-day conduct and decision-making. This so-called "tone at the top" is essential, because without a visible and consistent commitment from management, the Code could be perceived only as a formal document without real impact on the corporate culture.

It is the duty of management to actively communicate the importance of ethical conduct, to 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 operation of mechanisms for reporting and addressing ethical misconduct.

Training and raising awareness of ethical standards

The Company shall ensure regular and comprehensive training for all employees regarding the content of this Code of Ethics, relevant legal regulations (e.g., in the areas of AML and personal data protection), internal policies, and procedures. The aim of the training is not only to familiarize employees with the rules, but above all 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 of ethical dilemmas relevant to the Company’s activities, especially in the area of trading in diamonds and precious metals. Records of participation in training sessions will be duly maintained. The training will not be merely a formal reading of the Code, but an interactive process focused on understanding and internalizing ethical principles.

Record-keeping

The Company shall maintain and retain appropriate records documenting the implementation of and compliance with this Code of Ethics and related policies and procedures. Such records may include, for example, training attendance sheets, materials used during training, records of internal audits of ethical conduct carried out, documentation relating to investigations of reports of unethical conduct, and corrective measures adopted.

All records shall be maintained and retained in accordance with the applicable laws of the Czech Republic, in particular with regard to personal data protection and retention periods, and in accordance with the Company’s internal rules. Consistent record-keeping is essential not only for internal control and continuous improvement of ethical programs, but also as evidence for any external audits, inspections by regulatory authorities, 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 recorded accurately, completely, and in a timely manner in the Company’s accounting books in accordance with applicable Czech accounting standards, international accounting standards (where applicable), and all relevant tax and financial laws. The creation of any false, misleading, or incomplete records, as well as the establishment of secret or unrecorded funds or assets, is strictly prohibited.

The Company shall ensure regular independent audits of its financial accounts by a qualified and independent auditor, or, where the nature and size of the Company allow and where consistent with the law, an independent review of the financial accounts. The results of the audit or review shall be taken with full seriousness and any recommendations shall be implemented.

The Company undertakes to report transparently on its relevant business practices and financial results in accordance with applicable legislation and principles of good governance. Linking financial integrity with the Company’s overall ethics is essential, as financial irregularities can often be a symptom of deeper ethical issues and can seriously damage the Company’s credibility and reputation.

Prohibition of bribery and corruption

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

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

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

The Company pays particular attention to so-called "facilitation payments", i.e., small unofficial payments to public officials in order 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 nevertheless seek to eliminate them and will ensure their strict control, recording, and approval at the highest level.

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

Respect for human rights

UMARUTTI s.r.o. is fully committed to respecting and supporting all internationally recognized human rights across all its operations, business relationships, and the communities affected by its activities. This commitment is consistent with the UN Universal Declaration of Human Rights 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 limits of the law, and the protection of the privacy of its employees and business partners.

The Company will carry out due diligence in order to identify, prevent, mitigate, and account for any negative impacts of its activities on human rights, both within its own operations and throughout its supply chain. This process will include risk assessments, the implementation of preventive measures, and, where appropriate, remedial steps. Awareness that human rights are not only a matter of working conditions but also include broader impacts of the Company’s activities, for example on communities in raw material extraction areas, is key. Linking this commitment with due diligence processes in the supply chain is essential to minimizing risks such as "blood diamonds" or other forms of exploitation.

Responsible sourcing and due diligence

UMARUTTI s.r.o. undertakes to source diamonds, precious metals, and all other materials used in its activities exclusively from legitimate and responsible sources. These sources must not be involved in the financing of conflicts, human rights violations, illegal activities, or other unethical practices and must comply with relevant international standards, including UN resolutions and the 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 entire supply chain. The purpose 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 terrorist financing.
• 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 consists of robust "Know Your Customer" (KYC) procedures and anti-money laundering (AML) measures. The Company will apply these procedures to all its business partners (suppliers as well as customers) in order to verify their identity, the legality and legitimacy of their business and, where justified, their beneficial owners. These procedures will be fully aligned with the Company’s internal AML policy, the existence of which is referenced in the Company’s documentation. The AML/KYC processes will include ongoing monitoring of transactions for unusual or suspicious activity and, where applicable, reporting to the competent financial and investigative authorities in accordance with applicable legislation and the internal AML policy. All records relating to KYC and executed transactions will be carefully retained for the period required by law and internal regulations.

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

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

Ethical conduct of business partners

UMARUTTI s.r.o. recognizes that its ethical responsibility extends beyond the boundaries of its own operations and also includes its supply chain. Therefore, the Company expects its suppliers, key business partners and other cooperating entities to share and adhere to similarly high ethical standards as defined in this Code. These expectations relate in particular 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 appropriate influence, the Company will communicate its ethical expectations to its partners and will support them in their efforts to meet these standards. This may include sharing information on best practices or engaging in dialogue on opportunities for improvement.

The Company reserves the right to reassess or terminate business relationships with partners who repeatedly or materially violate fundamental ethical principles or refuse to engage in constructive dialogue on remediation. A proactive approach to ethics in the supply chain is key to protecting the Company’s reputation and contributing to positive change across the entire sector. The Company may consider introducing a specific supplier code of conduct or incorporating relevant ethical clauses into contractual arrangements 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 products offered, in particular diamonds and precious metals. This commitment applies to information about their origin (to the extent possible and based on available information from responsible sources), nature, quality, weight, clarity, and any treatments that could affect their characteristics or value.

Particular emphasis is placed on accurate labeling and communication of the difference between natural diamonds and laboratory-created (synthetic) diamonds. The Company will ensure consistent and unambiguous differentiation between these two product categories in all 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 also imposes an obligation on its buyers to correctly label laboratory-created diamonds. The aim is to ensure that customers (wholesale buyers) are always fully and clearly informed about the nature of the diamonds purchased and can correctly pass this information on.

The Company will also transparently disclose any known treatments of diamonds or other precious stones that have been carried out to alter or enhance their color, clarity or other characteristics, where such treatments are not generally recognized cutting practices. This information will be stated as part of the offer for such a product.

Any form of deceptive advertising, misleading marketing practices or misrepresentation of product information is strictly prohibited. All claims and statements relating to products must be substantiated and verifiable. The emphasis on product integrity and transparency in communication, especially in relation to laboratory-created diamonds, is key for the Company not only from an ethical perspective, but also to maintaining trust in a market where this issue is becoming increasingly important. Through this approach, the Company positions itself as a trustworthy and responsible partner in the sector.

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

Rationale for the table: This table provides a clear and structured overview of the Company’s commitments to transparency regarding key product characteristics. It facilitates understanding both for internal employees responsible for sales and marketing and for 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 working environment in which all employees are treated fairly, with dignity and respect. This includes ensuring fair remuneration for work performed, in compliance with applicable laws of the Czech Republic, relevant collective bargaining agreements (if any), and competitive within the given industry and region.

The Company will strictly comply with statutory limits on working hours, including overtime rules, and will ensure employees’ right to rest, daily and weekly breaks, and paid leave in accordance with the Labour Code. All employees will be provided with clear, comprehensible, and written employment contracts containing all essential terms of employment, including job description, wage level, working hours, and other working conditions.

Fair working conditions are not only an ethical imperative, but also contribute to higher employee motivation, satisfaction, and loyalty, 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 workplace discrimination. Discrimination based on race, skin color, religion, sex, 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, employee selection, remuneration, assignment of work tasks, professional development, promotion, and termination of employment.

The Company is committed to creating a working environment based on mutual respect, where every employee has equal opportunities to apply 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 corporate culture, foster innovation, and improve decision-making processes. Proactive support for diversity and inclusion is not only the fulfillment of an ethical requirement, but a strategic advantage that contributes to the Company’s long-term sustainability and competitiveness.

Prohibition of harassment and violence

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

The Company will ensure the establishment and communication of clear rules and procedures for the prevention, reporting, and handling 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, promptly and impartially investigated, and, if a breach is confirmed, appropriate remedial and disciplinary measures will be taken. It is crucial to create an atmosphere of trust in which victims or witnesses will not be afraid to report incidents and will know that the Company does not tolerate such behavior and will address it actively.

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 also commits to actively striving to ensure that these practices are not present in its supply chain either.

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

The commitment to eliminating child and forced labor will be actively verified through due diligence processes in the supply chain, especially when sourcing materials from geographic areas where these risks may be higher. Any finding or reasonable suspicion of the use of child or forced labor by a business partner will lead to an immediate investigation and, where appropriate, to the suspension or termination of the business relationship.

Freedom of association

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

The Company will not in any way prevent employees from exercising these rights, nor discriminate against or penalize them in any manner for exercising them. If employees decide to establish a trade union organization or engage in collective bargaining, the Company will negotiate in good faith with their legitimate representatives. Even in an environment where trade 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 upholds.

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 undertakes to actively prevent workplace accidents, occupational diseases, and any other health damage related to the performance of work.

To this end, the Company will:

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

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

Protection of the Company’s assets and information

Every employee of UMARUTTI s.r.o. is obliged to protect the Company’s assets against loss, damage, misuse, or theft. These assets include not only tangible assets (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 good name and 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, nor used for personal gain or for other unauthorized purposes. This commitment also applies to information stored and processed within the AreteApp platform and is in accordance with applicable personal data protection regulations (GDPR) and the protection of trade secrets. In the digital age, protecting data and information is just as important as protecting 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 at all times in the best interests of the Company and to avoid situations in which their personal interests, the interests of their family members, or close persons could 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, for example through participation in a business that competes with the Company, through financial investments in competing or supplier companies, through accepting gifts or benefits that could influence the objectivity of decision-making, or through employing family members without a transparent process.

Each employee is obliged to promptly and transparently declare any potential or actual conflict of interest to their direct supervisor or the designated responsible person within the Company. The Company will then assess the situation and decide on further steps so that the Company’s interests are protected and the objectivity of decision-making is maintained. The existence of clear rules for reporting and addressing conflicts of interest is key to maintaining trust and integrity in all of the Company’s activities.

Environmental management

UMARUTTI s.r.o. is aware of its responsibility towards the environment and undertakes to minimize the negative impacts of its activities on the environment and to promote 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 focused on:

• Identifying and assessing the environmental aspects and impacts of its activities.
• Setting objectives and programs for the continuous improvement of its environmental profile.
• Preventing air, water and soil pollution.
• Protecting biodiversity and ecosystems in areas where its activities could have an impact (especially in the context of the supply chain).
• Raising environmental awareness among its employees.

Environmental responsibility is becoming an increasingly important factor for customers, investors and the wider public, and the Company considers it 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. An accurate inventory of these substances will be maintained and all requirements for their storage, handling and disposal will be complied with.

The Company undertakes to minimize waste generation across all its activities. It will actively promote the principles of the waste management hierarchy, i.e., waste prevention, preparation for re-use, recycling and other recovery methods prior to final disposal. All waste will be sorted and disposed of responsibly through authorized entities and in accordance with applicable regulations. Wholesale activities may also generate waste, such as packaging materials, and the Company will strive to minimize such waste and ensure its environmentally sound disposal.

The Company will also monitor and strive to reduce emissions to air, water and soil that may arise as a result of 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, in particular energy, water and other materials necessary for its operations. It will strive to reduce the consumption of these resources per unit of output or service and seek opportunities for savings and more efficient use.

This includes:

• Monitoring energy and water consumption and implementing measures to reduce 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 other materials and giving preference to recycled or sustainable alternatives where available and appropriate.

Saving natural resources not only contributes to environmental protection, but may also have a positive economic impact on the Company by reducing operating costs. This approach is consistent with the principles of sustainable development and responsible business conduct.

Reporting unethical conduct and protection of whistleblowers (Whistleblowing)

UMARUTTI s.r.o. supports a culture of openness and transparency and encourages all its employees, as well as external collaborators and business partners where applicable, to report any suspicion of a breach of this Code of Ethics, applicable laws or the Company’s internal policies. Establishing and maintaining trustworthy and secure reporting channels is key to preventing and detecting unethical conduct.

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

The Company undertakes to protect whistleblowers who act in good faith. Any form of retaliation, discrimination or other adverse treatment against a person who has submitted a report is strictly prohibited. The whistleblower’s identity 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 regarded as one of the most effective tools for detecting and preventing unethical conduct and for strengthening the ethical culture within the Company. It is essential that this system be perceived by everyone as safe, fair and effective.

Investigations and disciplinary proceedings

All reports of a possible breach of this Code of Ethics, applicable laws or the Company’s internal policies will be treated with full seriousness and will be duly, impartially and promptly investigated by a designated responsible person or committee, in accordance with the Company’s internal procedures. The purpose of the investigation is to objectively establish the facts and assess whether a breach has occurred.

If the investigation proves a breach of the Code of Ethics, appropriate and proportionate disciplinary measures will be applied against the responsible persons. These measures may range from an oral or written warning, through financial penalties, a reduction of personal remuneration, reassignment to other work, up to termination of employment or the contractual relationship, always in accordance with applicable labour-law regulations and other relevant laws. In cases where the conduct could constitute a criminal offence or an administrative offence, the Company reserves the right to refer the matter to law enforcement authorities or other competent public authorities.

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

Regular review and updating of the Code

This Code of Ethics is not a static document, but a living instrument that must reflect developments in legislation, business practices, ethical standards and the expectations of stakeholders. For this reason, the Code will be reviewed by the Company’s management on a regular basis, 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).

The aim of the review is to ensure that the Code remains current, relevant, understandable and effective in promoting ethical conduct and compliance within the Company. Relevant employees and, where appropriate, 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 updating are key to maintaining the momentum of an ethical culture and to adapting to an ever-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. A breach of this Code may lead to disciplinary measures, including possible termination of employment or the contractual relationship, and in serious cases also to legal action.

Each employee is obliged to become thoroughly familiar with the content of this Code and, in the event of any ambiguities or the need for consultation regarding its interpretation or application, to contact their direct supervisor or the designated contact person within the Company responsible for ethics and compliance.

This Code of Ethics of UMARUTTI s.r.o. shall enter into force on the date of.

In Prague on 25/05/2025

Vladimír Kondratěnko

Managing Director of UMARUTTI s.r.o.