CODEX OF ETHICS POLICY of HEXANOVA SP. Z O.O.

All employees of Hexanova Sp. z o.o. and Hexanova Science Sp. z o.o. as well as other
subsidiaries or cooperating entities, hereinafter referred to as Hexanova or the Company, are obliged to always act in a fair manner and to fully comply with all laws and regulations regarding the Company’s operations.

For this purpose, Hexanova has developed a set of rules for conducting business and
compliance with legal provisions, described in the Ethics Rules, which apply to all employees, management and the Board.

The principles of Ethics are a development of our values and reflect our commitment to
conduct our business in an ethical and lawful manner. Hexanova expects its employees to implement and respect the letter and spirit of our commitment to behave in a fair manner. Each employee is a representative of Hexanova outside the organization and in contacts with clients. The manner in which a representative performs his duties can have a significant impact on the image, reputation and brand that is one of the Company’s most important assets.

For this reason, Hexanova expects all its employees, agents and subcontractors (and their
representatives) to comply with the Company’s Ethics Principles while conducting their operational activities and performing their official duties. All employees should familiarize themselves and their representatives / subcontractors with the Code of Ethics and make sure that they understand and follow them.

The Ethics Rules are periodically updated on our public website www.hexanova.pl and, to the
extent appropriate to the circumstances in which employees conduct their operations.

ETHICS POLICY

All employees are required to act in full compliance with applicable laws in force in the country when doing business with and / or on behalf of the Company. In addition to the specific obligations set out in the contracts that employees enter with the Company, all employees are without any restrictions:

• Observe all applicable anti-corruption laws
• Observe all applicable environmental protection regulations, including production, transport and storage.
• Provide only true information in talks with representatives of regulatory authorities and government officals.
• Act honestly and perform their obligations under the contracts they have concluded with the
Company.
• Honestly and accurately record and report all commercial information and comply with all applicable laws.
• Protect and make responsible use of Hexanova’s material and intellectual values, in particular assets,
materials and equipment, when they obtain the Company’s consent for their use.
• Use the resources and IT systems provided by Hexanova (including e-mail) only for the purposes of operating activities approved by the Company.

Hexanova strictly prohibits employees and subcontractors and their representatives from using the IT resources and systems provided by the Company to create, obtain, store, print or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and / or sending any false, offensive or malicious correspondence through the resources and information systems provided by the Company.
• Comply with all Hexanova requirements regarding procedures for the use of passwords, protection of confidentiality and privacy, and maintaining security as a condition for gaining access to the internal computer network. All data stored or transmitted using equipment belonging to the Company or rented and / or leased by the Company should be treated as data owned by Hexanova. Hexanova can monitor all cases of use of the Company’s network and systems (including e-mail) and / or check all data stored or transmitted using the Company’s network.
• Observe the intellectual property rights of Hexanova and other entities and persons, in particular copyrights, rights to patents and trademarks and trade secrets. Use software and hardware as well as their content only in accordance with the applicable licenses or terms of use.
• Speak to the press on behalf of Hexanova only after obtaining express written consent from the Company.
• Employees must never offer bribes, pay for positive consideration of the case, enter into barter arrangements for goods or services, and use other forms of incentives to clients to obtain or maintain sales.
• Avoid irregularities and conflicts of interest as well as situations that may create the appearance of irregularities or conflicts of interest.
• All employees recognizing and respecting cultural differences should not discriminate when hiring, rewarding, providing training, promotion, termination of employment and retirement due to race, nationality, religion, age, disability, gender, marital status, sexual orientation , membership in a trade union or political affiliation.
• Provide a safe and healthy working environment and fully comply with all applicable laws, regulations and standards regarding health and safety at work; take appropriate actions to minimize the effects of hazards existing in the work environment.

REPORTING OF DOUBT BEHAVIOR OR POSSIBLE VIOLATIONS

Persons wishing to report dubious behavior or possible violations of this Code of Conduct for Workers may use one of several ways to report such problems offered by Hexanova. The Company encourages solving problems regarding the principles of conducting business and compliance with the law together with the Company’s employee on the principles of understanding and respecting the position of the parties.
Sometimes this way of solving problems is impossible or inappropriate. In such cases, please contact the following e-mail address at: etyka@hexanova.pl.
Access to the content of the above Only members of the Hexanova Board of Directors have messages. Hexanova will not tolerate practices of punishment and retaliation on persons who have asked for advice in good faith or reported dubious behavior or possible violations.

Hexanova will draw consequences from employees who violate the Ethics Policy by terminating cooperation with an employee and enforcing reparation of violations.
Thank you for following these rules and we count on mutually beneficial cooperation with all
employees and subcontractors who meet the highest ethical standards.
Management Board of Hexanova Sp. z o.o.
Date of revision: 2019-03-04