I. GENERAL PROVISIONS
Art. 1. This Code of Conduct establishes the rules of conduct for the employees of EXALTO Ltd and aims to set standards for ethical and professional behavior in all aspects of their activities, to prevent the possibility of bureaucratic practices, corruption, and other illegal actions, thereby increasing public trust in their professionalism and morality and affirming the company's authority.
Art. 2. (1) The work of EXALTO Ltd employees is subject to the principles of legality, loyalty, professionalism, responsibility, and accountability.
(2) EXALTO Ltd employees perform their duties competently, objectively, and conscientiously, strictly complying with the requirements set out in their job descriptions and the legislation of the Republic of Bulgaria, and through their overall conduct, they contribute to increasing the trust of the company's clients and the interest of potential new clients.
(3) Given the public status of EXALTO Ltd , all company employees, depending on the functions they perform, are subject to established corporate governance rules, strictly observing the company's internal acts, performing their duties accurately and professionally, and striving to improve the efficiency of their work in the interest of clients and the company.
(4) EXALTO Ltd employees follow a code of conduct that does not harm the company's prestige, not only when performing their duties but also in their public and private lives.
II. RELATIONS WITH SHAREHOLDERS, INVESTORS, FINANCIAL AND OTHER MEDIA, THE FINANCIAL SUPERVISORY COMMISSION, AND THE REGULATED SECURITIES MARKET
Art. 3. (1) When performing their duties, EXALTO Ltd employees treat every client of the company, as well as any person showing interest in the company, with courtesy and respect, explaining their rights in detail within the scope of their function or directing them to the appropriate competent employee.
Art. 4. (1) The Client Relations Director, as an employee of EXALTO Ltd , whose main function is to maintain effective communication between the company's management body and its clients.
(2) The Client Relations Director of EXALTO Ltd performs their duties impartially and without prejudice, treating all company clients based on the principle of equality, regardless of their nationality, racial or ethnic origin, age, gender, political or other beliefs.
III. PROFESSIONAL CONDUCT
Art. 5. (1) EXALTO Ltd employees perform their duties professionally and responsibly, ensuring that their personal interests or external factors do not influence the quality of the assigned work.
(2) All employees arrive at work on time, in a condition that allows them to perform their duties and responsibilities, without consuming alcohol or other intoxicating substances during working hours, and use this time solely for performing the assigned work with the necessary quality and within the specified deadlines.
Art. 6. (1) Exallto EOOD employees are obliged to observe the established hierarchy of internal organizational relations, strictly complying with internal acts, the orders of their immediate supervisor and the company management, and not hindering other workers and employees from performing their duties.
(2) Exallto EOOD employees are not obliged to execute unlawful orders issued in the established manner if they contain obvious legal violations.
(3) Exallto EOOD employees discuss problems encountered in the course of work with their immediate supervisors or the company's management body.
Art. 7. (1) Exallto EOOD employees do not allow themselves to be placed in financial dependence or other obligations by external persons or organizations, nor do they seek or accept gifts, services, money, or other benefits that could influence the performance of their duties.
(2) Exallto EOOD employees cannot accept gifts or benefits that could be perceived as a reward for performing work that falls within their duties.
Art. 8. (1) When performing their duties, Exallto EOOD employees safeguard the technical means and materials entrusted to them with due care and do not allow their use for personal purposes. In case of loss or damage to entrusted property, employees are obliged to promptly inform their immediate supervisor.
(2) Exallto EOOD employees do not disseminate confidential information and protect the company's good name; all information, including that containing personal data within the meaning of the Personal Data Protection Act, to which they have access in their capacity as company employees, is used solely for the performance of their duties while complying with information protection rules.
Art. 9. The Client Relations Director of the company performs their duties with the care of a good merchant in a manner they reasonably believe is in the interest of all company clients, using only information they reasonably consider reliable and complete, while demonstrating loyalty to the company.
IV. PERSONAL CONDUCT
Art. 10. (1) When performing their duties, as well as in their public relations outside the workplace, Exallto EOOD employees adhere to conduct that does not harm personal dignity or the company's authority.
(2) Exallto EOOD employees maintain decency and a business appearance in their attire, appropriate to their professional position.
Art. 11. Exallto EOOD employees cannot participate in activities that are incompatible with generally accepted principles of ethical conduct and could harm their professional authority or the company's prestige.
Art. 12. Exallto EOOD employees, depending on the positions they hold, cannot engage in activities specified in legislation as incompatible with their duties and responsibilities as company employees, nor receive income from such activities.
1. RELATIONS BETWEEN EMPLOYEES
Art. 13. (1) In their relations with colleagues, Exallto EOOD employees show respect and fairness, not allowing behavior that harms the dignity and rights of individuals, nor any form of discrimination.
(2) Exallto EOOD employees respect their colleagues' opinions and respect their right to privacy.
(3) All company employees comply with their hierarchical subordination within the established internal structure, not allowing abuses of their position, expressed as pressure or harassment in any form towards subordinate employees.
Art. 14. When professional or service conflicts between colleagues cannot be resolved by themselves, they seek assistance from their immediate supervisor.
VI. CONFLICT OF INTEREST
Art. 15. (1) A conflict of interest exists when the personal interests of employees, their close relatives, or persons with whom they have close personal or business relationships differ from the interests of the company.
(2) Exallto EOOD employees strive to avoid any situations giving rise to a conflict of interest, and upon the occurrence of such situations, make the necessary efforts to cease them, notifying their immediate supervisor.
(3) When assigned a task whose performance could lead to a conflict between their duties and personal interests, Exallto EOOD employees should promptly notify their supervisor.
Art. 16. (1) Exallto EOOD employees cannot use their position to pursue their own personal or family interests.
(2) Exallto EOOD employees do not participate in any transactions that are incompatible with their position, functions, and duties.
(3) Exallto EOOD employees who have left the company must not abuse information that became known to them in connection with the position they held or the functions they performed.
VII. INSIDER INFORMATION AND CONFIDENTIALITY
Art. 17. (1) Insiders are all persons who work for Exallto EOOD under an employment or civil contract and have permanent or incidental access to insider information relating directly or indirectly to the company.
(2) To prevent the possibility of insider information abuse, all insiders are obliged to comply with provisions regarding the storage and non-dissemination of such information.
Art. 18. (1) Exallto EOOD employees are obliged to protect the data and personal information of all persons that became known to them during or in connection with the performance of their duties.
(2) All company employees refrain from disseminating and using for personal interests information of a confidential nature for Exallto EOOD.
VIII. EXECUTION
Art. 19. In case of non-compliance with the conduct standards in this Code, employees bear disciplinary responsibility in accordance with the Labor Code.
Art. 20. Upon initial assumption of office, the Head of the Human Resources Department is obliged to familiarize the employee with the provisions of this Code.