At CloseOut FSM d.o.o. Beograd (Vračar) (“Company“), we are committed to upholding the highest standards of integrity, transparency, and accountability. This Code of Conduct establishes the ethical principles, values, and professional expectations for all employees, directors, and third parties acting on behalf of the Company. 

This Code applies to: 

• All employees and directors of the Company and its subsidiaries. 

• Third parties (e.g., consultants, suppliers, agents) acting on behalf of the Company. 

All individuals covered by this Code are expected to act with professionalism, respect, and compliance with applicable laws and internal policies. 

1. Compliance with Laws and Regulations 

We are committed to full compliance with all applicable national and international laws and regulations.  

Employees must: 

• Abide by all relevant laws, industry standards, and internal policies. 

• Act in good faith and avoid any activity that could lead to legal or ethical violations. 

• Fulfill all contractual obligations fairly and transparently. 

Violations of the law or this Code may result in disciplinary action, up to and including termination. 

• Reporting concerns and Whistleblower Protection 

Employees are encouraged to report any suspected violations of this Code, Company policies, or the law.  

Reports can be made: 

• Anonymously or personally, in writing or orally. 

• With strict confidentiality and without fear of retaliation. 

• Through designated reporting channels outlined in internal policies. 

The Company strictly prohibits any form of retaliation against individuals who report concerns in good faith. Reports will be investigated in a respectful, professional manner as promptly and confidentially as possible.   

Violations of this Code of Conduct and other company policies are taken seriously. There are consequences for violating company policies, which may include discipline up to and including termination of employment. 

2. Ethical Conduct  

Employees are expected to: 

• Conduct business fairly, honestly, and with integrity. 

• Avoid conflicts of interest between professional and personal affairs. 

• Treat colleagues, customers, and partners with respect, fairness, and dignity. 

• Promote an ethical workplace culture, with managers serving as role models. 

• Protect confidential information and respect data privacy regulations. 

Any breach of ethical conduct will be subject to appropriate disciplinary measure 

3. Work environment 

We are committed to a safe, inclusive, and fair workplace. The Company does not tolerate discrimination, harassment, bullying, or mobbing based on race, ethnicity, religion, gender, sexual orientation, marital status, or political views. 

Employees have the right to: 

• Fair and lawful wages, benefits, and working conditions. 

• A workplace free from forced labor, child labor, or human trafficking. 

• Participate in trade unions and collective bargaining. 

• Report any workplace concerns without fear of retaliation. 

Work hours shall comply with applicable labor laws, with a standard workweek of 40 hours and any additional hours adhering to legal overtime limits. 

Decisions concerning employees, including recruiting, hiring, training and evaluation, are based exclusively on individual merit and performance and cannot be influenced by race, ethnicity, religion/belief, sexual orientation, marital status or political view.  

A healthy and safe working environment shall be provided for all employees, in accordance with international standards and national laws. Appropriate health and safety information and training shall be provided to all employees.  

More information regarding work environment, employees can find on our Employee Rulebook.  

4. TRUST 

– Company’s asset 

Company assets, including computers, mobile phones, and other equipment, are provided for business use only unless otherwise authorized. Employees must: 

• Protect assets from theft, loss, or damage. 

• Avoid unauthorized personal use of Company property.

• Follow IT security guidelines to prevent cyber threats.

– Confidential information 

All business-related information must be handled with strict confidentiality. Employees must handle this information with confidentiality and disclose it only on a need-to-know basis or if specifically authorized.  

Employees must sign a Non-Disclosure Agreement (NDA) as part of their employment. 

 – Intellectual Property 

The Company retains ownership of intellectual property created during employment. 

Employees must respect and protect trademarks, patents, and copyrights belonging to the Company. The obligation to preserve intellectual property continues even after the employment with the Company ends.  

More details on intellectual property rights are provided in the Intellectual Property Policy.  

– Data privacy 

Personal data must be processed fairly, lawfully and carefully in a way that protects privacy.  

Employees must: 

• Process personal data lawfully and protect the privacy of customers, partners, and third parties. 

• Handle data only on a need-to-know basis and in accordance with data protection laws. 

• Report any suspected data breaches immediately. 

The Company provides employees with notices regarding how personal data is collected, used and stored.  

– Anti-bribery  

All employees must conduct business in an honest and ethical manner.  

The Company maintains a zero-tolerance policy on bribery and corruption. Employees must not: 

• Offer, give, or accept bribes, kickbacks, or anything of value in exchange for business advantages. 

• Engage in unethical dealings with government officials or private entities. 

• Accept excessive gifts, meals, or entertainment that could be perceived as improper. 

Violations of anti-bribery laws may result in criminal charges and disciplinary action. 

5. FAIR COMPETITION AND CONFLICT OF INTEREST 

• Employees must comply with competition laws and avoid anti-competitive agreements (e.g., price fixing, bid rigging). 

• Business dealings with suppliers must be conducted fairly, transparently, and without favoritism. 

• Employees must disclose any actual or potential conflicts of interest in writing to their manager. 

The Company will review conflict-of-interest disclosures and communicate decisions in writing. 

6. INSIDE TRADING AND FINANCIAL INTEGRTIY 

Employees must not use non-public, material information for personal financial gain. Inside information must be kept confidential and disclosed only when legally permitted. 

All financial records must be accurate, truthful, and in compliance with accounting standards. Employees must cooperate with internal and external auditors and report any suspected financial fraud. 

7. FINAL PROVISIONS 

Failure to comply with this Code may result in disciplinary action, including but not limited to: 

• Verbal or written warnings. 

• Suspension or termination of employment. 

• Legal action in cases of serious misconduct. 

The CEO of the Company has adopted this Code of Conduct, and all employees are expected to uphold these principles in their professional conduct. 

For further details, employees should refer to the Employee Rulebook and other relevant Company policies. 

By following this Code, we create a responsible, ethical, and successful workplace.