CODE OF CONDUCT IN RELATIONS WITH EXTERNAL ENTITIES OF REAL TRADE PRAHA a.s.

To meet all requirements of customers and modern times, we assert professional approach, reliability, ability to provide a comprehensive range of services and responsibility.

The subject of activities REAL TRADE PRAHA a.s. (hereinafter referred to as the “Company”) is the domestic and foreign procurement of high-quality military technology – in this field we provide military vehicles, weapons and weapon systems throughout the world. A characteristic feature of foreign trade in military material is, in particular, the ability to secure supplies of individual pieces of technology, such as weapons, large-calibre weaponry, ammunition, bombs, missiles, tank technology, toxicology equipment, aircraft, helicopters and spare parts for the aforementioned technology as well as complex deliveries in relatively large quantity in the required quality, including sets of spare parts to ensure maintenance and repairs of the technology.

Specific services are provided by REAL TRADE PRAHA a.s. also for museums and collectors of military technology, to whom it supplies military equipment that is disabled, in full compliance with the legal regulations of individual countries.

The result of the responsible approach of the company is adoption of an internal compact system of rules, procedures and regulations, the purpose of which is the compliance of the required behaviour of employees and other persons with fundamental human rights, general ethical values, morals, legal rule and internationally recognized standards. The Code of Conduct is a part of the aforementioned system and as such it applies to all employees of the Company, including members of the Company’s bodies and external entities such as consultants, suppliers or agents representing the company (hereinafter the “Personnel”).

This Code expands the rules incorporated in the Company’s Code of Ethics. The first part of the Code of Conduct is devoted to the Company’s relationships with external entities. The second part of the Code of Conduct is devoted to the requirements for business partners, or, as the case may be, it sets out the rules of conduct that the Company requires from its suppliers, business partners, etc.

REAL TRADE PRAHA a.s. does not tolerate at all any acts of its Personnel that could be considered illegal, corruptive, unethical, unfair or immoral. The Company considers such conduct as reprehensible and unacceptable within the set image of behaviour and conduct.

PART I.

COMPANY’S RELATIONS TO EXTERNAL ENTITIES

PUBLIC AUTHORITIES

In performing their working duties, the Company’s Personnel come to a greater extent in contact with public authorities, in particular within the Company’s specific activities in the field of weapons, ammunition and security materials, as well as licensing proceedings in connection with foreign trade in military materials. Public authorities means for the Company not only officers or representatives of various administrative authorities, but also representatives of bodies responsible for criminal proceedings, the armed forces of the state, etc. (hereinafter collectively referred to as the “Officials”).

When acting in the interest or within the scope of the Company’s activities with the Officials, the Company’s Personnel are obliged to act in accordance with the basic principles of decency, honestly and with dignity, respect and esteem. Negotiation before such authorities always takes place at the highest level, in the proper and appropriate attire, in an orderly and decent manner.

When dealing with the Officials, the Personnel are strictly prohibited from using any form of conduct, behaviour or expressions that could be considered untrue, purposeful, unethical or illegal. When communicating with the Officials, the Personnel shall always ensure that all information provided to the Officials is always complete, accurate, true and clear. Any conduct that could be construed as fraudulent or violent completely contradicts the Company’s corporate policy, as well as the basic principles that the Company declares. Particularly condemned and rejected behaviour is any manifestation of bad will in the form of physical and psychological violence.

All Personnel are obliged to proceed in negotiations with the Officials in accordance with the Company’s anti-corruption programme or, where appropriate, they are always obliged to act not to make an impression that they are willing or open to any possibility of corrupt practices. In particular, it is completely contrary to the interests and corporate policy of the Company to offer or, on the contrary, accept any benefits, services, favours or rewards, and both financial and tangible/intangible gifts or benefits. Conduct of the Personnel that could in any way disparage, reverse or influence the decision of an Official is particularly reprehensible for the Company. Every gift or reward, even a small one, is completely prohibited and forbidden, if it could make an impression that the conduct of the member of Personnel is only malicious, purposeful or inappropriate, and at the same time such a benefit or reward has the ability to influence the behaviour of entities.

Small gifts, expressions of gratitude or promotional materials may only be accepted and offered by the Personnel if they do not contradict good morals, and if refusing them would mean a violation of the principle of decent behaviour.

The Company is completely reluctant to engage in any conduct that could be construed by anyone as fraud, extortion, deception, threats, bodily injury or any other improper conduct.

All Personnel are always obliged to only specify in all documents submitted to the public authorities the correct, clear and accurate information and facts; they are always obliged to take the necessary care and diligence to avoid submitting documents that would not really correspond to the facts and the factual standing of the company; they are not entitled to conceal any information or abuse mistake or lack of knowledge.

SUPPLIERS AND BUSINESS PARTNERS

All Personnel are obliged to follow the basic principles of decent behaviour when communicating and dealing with the Company’s business partners.

In entering into business contacts with partners and suppliers, the Company and its Personnel always promote and proclaim the correct, professional and honest approach. The choice of contractual partners is subject to the principles of equality, being the result of a sound and natural competition. Suppliers are assessed in the selection procedure independently, without the influence of personal or family relationships, or only on the basis of obtaining an illegal or unsupported benefit of the person. The basic principles of evaluation of the individual suppliers particularly includes quality, price and payment conditions, delivery term, quality system and environmental management system in place.

The Company and its Personnel always pay attention to anti-corruption principles incorporated in the Company’s anti-corruption programme. In no event shall the Company’s employees be entitled to abuse their powers, resources or influence to provide any undue advantage to suppliers, to the Company or to themselves, or to adversely affect the Company’s goodwill and reputation in any manner in the future.

The Company complies with the rules of economic competition – the Company always acts towards its competitors in the field of domestic and foreign trade markets in accordance with the law and common business practices. Completely intolerable and condemned are illegal consequences of non-competitive conduct, which particularly include in the Company’s opinion the hallmarks of unfair competition, such as abuse of defamation to harm competitors, use of misleading promotion that does not correspond to or grossly distorts the reality, giving or taking bribes, wrongful comparison of products with the competing product with the aim to corrupt and reverse the customer’s decision, harassing customers in an inadequate manner, etc.

The Company respects the rule of “pacta sunt servanda” – contracts are to be observed, which is manifested in particular by the honest approach to creditors. The Company treats them decorously and equally. Any conduct of the Personnel that could harm a creditor, abridge the creditor’s right, mislead the creditor or result in reduction or destruction of the Company’s own property is considered as completely contrary to the interests and corporate policy of the Company. The Company absolutely rejects any unfair acts towards creditors that would result in abridging their rights or inability to perform the Company’s obligations.

CUSTOMERS

The Company’s aim is to have professional and positive relationships with its customers. The Company requires that its Personnel in communicating with customers at all levels always act professionally, competently, with respect, dignity and esteem, always proclaiming a behaviour that is fully in line with the basic ethical and moral values. In doing so, the Personnel are required to take into account the interests and needs of customers.

When communicating with customers, the Company’s Personnel act so that they shall not damage the Company’s goodwill and reputation, they always choose a pressure-free style in negotiations, their communication is decent and honest, dignified and qualified.

The Company shall ensure that all Personnel only use true, complete and accurate information when communicating with customers, so as not to provide misrepresented or false information or to mislead anyone, not to apply corrupt practices, and not to offer, provide or accept any benefits.

In the event that the Company or its Personnel dispose of the customer’s property, all Personnel are obliged to take extra care so that the property is not damaged, stolen or lost when handling it. The customer’s property is duly identified, monitored and then returned to the customer in accordance with the Company’s internal regulations.

PART II.

RELATIONS OF THE EXTERNAL ENTITIES TO THE COMPANY

The basic values of the Company incorporated in the rules and obligations set out by the Company’s internal regulations are so important for the Company that the Company enforces their observance also by its suppliers and other external entities. Compliance with ethical and moral values is a valuable asset and a matter of course for the Company, reaching the same level as the protection and observance of legal provisions.

The approach of other companies to the observance of basic ethical and moral rules and the legal order is taken for a granted by the Company to the extent that further cooperation with external entities is conditioned by such approach. Not only the compliance with the said rules by the Personnel is the basic principle, but also the active enforcement of the rules by the external entities.

By joining business or other negotiations with the Company by an external entity, such entity confirms that it shall adhere to the rules set forth in this Code, that the statements made herein are true, and that it undertakes to observe the rules and principles. Moreover, the external entity undertakes to subject cooperation with its subcontractors to compliance with the basic principles set out in this Code.

BASIC ETHICAL AND MORAL VALUES, LEGAL RULES AND LAWS

The external entity declares that:

It has been established in accordance with the legal rules of the country of its registered office, and meets all requirements of the respective country to perform its activities,
It has no debts and arrears of taxes due to public authorities, and duly performs its information, reporting and tax obligations,
It has not been convicted in connection with any professional activity, for which the entity entered into negotiations with the Company

and undertakes to:

Comply with the applicable legal regulations of the countries where it conducts business, which relate to its business activities, the functioning of the Company, management of property, etc.
Comply in particular with all administrative and tax regulations,
Provide only true, complete and accurate information when dealing with the Company. The external entity is equally responsible for all submitted documentation or papers.
Respect in its activities the fundamental human rights and values which have a historical tradition in the European society, and are incorporated in the fundamental legal regulations, particularly in the field of prohibition of child or forced labour, prohibition of discrimination and other demeaning treatment,
Employ the Personnel and comply with the working conditions for the Personnel in accordance with the applicable legal regulations, as well as actively combat, disallow and not enforce illegal employment and illegal work,
Provide equal opportunities for people regardless of their race, colour, gender, nationality, religion or ethnicity

CONFLICT OF INTEREST, ANTI-CORRUPTION RULES AND ECONOMIC COMPETITION RULES

The external entity declares that:

It properly keeps accounting records in accordance with the applicable regulations and standards, does not give any gifts, good turns, favours, services, discounts or other privileges in order to obtain an advantage or attention, or to influence the decisions made by a third party,
It has adopted internal rules preventing the possibility of conflicts of interest, both between its employees and in connection with business negotiations between the Company and the external partner,
All ordered and delivered goods have not been acquired and will never be acquired by committing a crime or as a reward for a crime

and undertakes to:

Comply with anti-corruption legal regulations,
Always carefully and conscientiously verify the origin of all their goods and never hide or conceal their origin.
Comply with the economic competition rules, in particular avoid a conduct that could be considered as an unfair competition or illegal act.

OCCUPATIONAL SAFETY AND ENVIRONMENTAL PROTECTION

The external entity declares that:

It complies with all legal regulations concerning the occupational safety and health of employees and environmental protection, particularly with regard to handling of dangerous and chemical substances,
It has taken the preventive measures necessary to ensure the right conditions in the field of occupational safety and health and its continuous improvement,

and undertakes to:

Actively ensure maintaining safe and healthy working environment,
Exert every effort to most effectively minimize the negative impacts of its business activities on the environment.

CONFIDENTIALITY

The external entity declares and undertakes to protect the confidential information it receives when dealing with the Company, and to prevent its misuse by third parties.

COMPLIANCE PROGRAMME

The external entity declares that:

It notes that the Company is subject to the compliance programme, which aims to prevent the occurrence of undesirable situations by means of an internal system of rules, principles and processes. Under this programme, the Company discloses what actions and behaviour of all persons involved in the functioning of the Company, including external entities, are binding for the Company,
It notes that the conduct of its employees contradicting the basic principles and rules set out in the Code of Ethics and this Code of Conduct, as well as the Anti-Corruption Programme published on the website, is not binding for the Company, as the aforementioned absolutely contradicts the Company’s main ideas; it is in absolute contradiction to the main principles and policy of the Company and as such it is condemned and not tolerated by the Company,

and undertakes that:

In the event of a breach by a Company’s Personnel of any rule or fundamental principle set out in the Code of Ethics, the Anti-Corruption Programme or this Code of Conduct, to report this information to the Company immediately,
In the event that the Company’s member of Personnel abuses their powers or violates the aforementioned rules, the Company shall immediately terminate negotiations with such an employee and, if necessary, shall direct further negotiations to their supervisor.

Options to whistleblow undesired conduct of a member of Personnel to a statutory body, CEO or a department head senior to the employee include the following:

By phone,
In writing,
Electronically,

to the contacts provided on the Company’s website.

PART III.

FINAL PROVISIONS

The Code of Conduct for external entities is binding on all external entities of the Company, from the moment they become or should have become familiarised with them.

If an external entity violates this Code, or there is at least a reasonable suspicion that the external entity has violated this Code of Conduct, or if the external entity refuses its obligation to provide cooperation and to cooperate in clarifying a case or a suggestion, the Company reserves the right to terminate business cooperation with the external entity in question effective immediately.

In the event of a breach of the Code of Conduct, the Company reserves the right to take further legal action, in particular to claim damages.

The Company also requests compliance with all requirements of this Code of Conduct by external entities that in any way participate in cooperation with the Company (subcontractor, supplier of individual components, etc.).