ANTI-CORRUPTION PROGRAM OF SYNER, ltd.

1. Introduction

SYNER's anti-corruption programme (hereinafter referred to as the "Programme") is aimed at promoting an anti-corruption climate both within SYNER, s.r.o. (hereinafter referred to as the "Company") and its business partners. The Programme is a part of a set of measures of the Company which, in accordance with the provisions of Section 8(5) of Act No. 418/2011 Coll. on the Criminal Liability of Legal Persons (ZTOPO), are intended to effectively prevent criminal activities related to the Company's business. The programme is based on the Company's Code of Ethics, which it further develops in the issue of preventing corrupt behaviour and extends to the issue of cultivating relations with the Company's business partners.

SYNER, s.r.o., applies zero tolerance in relation to bribes and other forms of illegal conduct aimed at distorting free competition as a permanent value and rule of its business. It expects its employees, managers, statutory bodies, as well as its suppliers and business partners to comply with all applicable laws and regulations, in particular those that address corruption and competition violations - see hl. X., Part 3 and hl. VI., Part 3, Act No. 40/2009 Coll., Criminal Code (hereinafter collectively referred to as "corruption").

2. Objectives, General principles

The objective of the Programme is to minimize the motivation of all employees, managers, as well as the statutory and controlling bodies of the Company to engage in corrupt and other illegal conduct and to raise awareness that if they resort to corruption or participate in creating a corrupt environment, they will be detected and punished.

The Programme also aims to influence the Company's business partners to adopt a zero-tolerance philosophy towards bribery and other forms of illegal conduct aimed at distorting free competition.

The tasks related to creating and strengthening the anti-corruption climate in the Company are divided into the following sections:

• Preventive education process to promote an anti-corruption climate,
• Corruption risk management,
• The Company's control system for promoting an anti-corruption climate,
• The system for reporting suspected corruption.
• The preventive training process for supporting the anti-corruption climate in the Company is addressed in the form of regular trainings conducted at least once a year by an attorney with experience in criminal law - Mgr. Václav Čechtice, based in Liberec, Dr. Milady Horákové 580/7, ev.no. ČAK 15159. The training will be carried out for individual departments of the Company, where the risk of contact with corruption-related violations is the highest (production, technical, commercial and financial departments). The Company's management and statutory bodies will be trained separately.
• Corruption risk management consists of risk identification, risk analysis and follow-up of the Company's control system. Corruption risk analysis consists of continuously determining the likelihood of corruption occurring, both outward from the Company and inward from the Company. In the case of corruption from within the Company, the usual result is damage to the Company of a quantifiable financial magnitude, but usually without the risk of the Company being sanctioned under the ZTOPO. In contrast, corruption directed outwards from the Company can be assumed to be motivated by a motivation to enrich the Company, which means that it is an unlawful act "for the benefit" of the Company, which entails a significant risk of the Company being sanctioned under the ZTOPO. Such a criminal sanction may well exceed the extent of the intended benefit that could be achieved by the corrupt conduct. The analysis of the risk of corruption within the Company is carried out mainly by the directors of the individual departments of the Company or by the employees designated by them. The analysis of the risk of corruption directed outside the Company must be carried out not only by the directors of the individual departments of the Company or their designated employees, but also by the anti-corruption control department of the parent company SYNER Group a.s., or by a third specialised person designated by the parent company for this purpose (hereinafter referred to as the "anti-corruption department"), as part of the performance of the service contract concluded between the Company and the parent company.
• The Anti-Corruption Department continuously identifies and assesses the risks of corruption and its potential impact on the Company. In doing so, it draws on available information on the Company's current contracts, major contractual relationships, as well as information from the system set up to receive reports of suspected corruption.
• As part of the anti-corruption climate, the Company will establish a system to facilitate the reporting of suspected corruption, both internally and externally, while guaranteeing the anonymity of the whistleblower. Employees of the Company, its contractors, or others may use pre-arranged communication channels to report to the Company's anti-corruption control room.

Each of these four parts of the anti-corruption climate performs clearly defined tasks, the cumulative result of which is an annual report that will be submitted to the Company's highest authority for review.

3. Consequences of breaching the programme

Serious action will be taken against any employee, officer or statutory body found to have violated the values and rules set out in this Programme. Such violation will be classified as a breach, serious breach or violation of work obligations in a particularly egregious manner, depending on its severity, with all the consequences arising from the relevant legislation (in particular the Labour Code).

The Company reserves the right to bind our contractors to the values and rules set forth in this Program and we reserve the right to terminate the contractual relationship with those who fail to comply with their commitment to the Program.

Any contractor or third party who believes or suspects that an employee of SYNER, s.r.o., or anyone acting on its behalf, may have engaged in illegal or otherwise improper conduct is strongly encouraged to report the matter to SYNER Group a.s., the parent company, or to use the information system under development to guarantee the anonymity of the whistleblower. In this regard, please contact the SYNER Group a.s. Ethical Conduct team at:

4. Cancelled internal documentation

With the issue of this document, the following is cancelled: ON A5 z1

5. Final provisions

The provisions of previously issued by-laws, insofar as they conflict with this standard, shall cease to be valid on the effective date of this standard.

6. Scope of validity

The rules, procedures and responsibilities of employees set out in this document apply throughout the entire scope of SYNER, s.r.o.'s activities.

This Program has been approved by a decision of the management meeting of SYNER, s.r.o. and may be amended only by a new decision of the management.