Code of Ethics and Business Conduct

1. Introduction, Commitment, and Scope

This Code applies to Nevdom, to all of its employees, to anyone engaged to provide services to the Company (contractors, consultants, subcontractors), and to any further resellers acting on the Company's behalf, regardless of the country in which we operate. Each such person must read this Code and act in accordance with it.

We are committed to acting honestly and transparently and to avoiding even the appearance of impropriety. We expect everyone acting on Nevdom's behalf to apply these standards in every business decision.

2. Compliance with Laws and the Higher-Standard Principle

We comply with all laws applicable to our activities — Slovak, European, as well as US and other international laws to the extent they apply to us as a company operating in the Oracle ecosystem. For us, compliance means not only observing the letter of the law but also meeting the ethical responsibilities that come with doing business.

Where local law is less restrictive than this Code or the Oracle Partner Code, we follow the stricter standard, even if our conduct would otherwise be lawful. Where local law is more restrictive, we always, at a minimum, comply with that law.

3. Antitrust and Competition Law

We compete solely on the quality of our services. We enter into no agreements with competitors and take part in no coordination whose object or effect would be: fixing or controlling prices; rigging or allocating tenders and bids (including "courtesy" bids or abstaining from bidding); boycotting suppliers or customers; dividing markets or customers; or limiting production or sales.

We do not exchange competitively sensitive information with competitors regarding prices, costs, margins, volumes, bids, or quotes for a specific customer. For this purpose, a competitor includes Oracle's direct sales, other Oracle partners, and any entity competing with us for a business opportunity.

We are cautious about practices that may unlawfully restrain competition — for example, below-cost (predatory) pricing, exclusive dealing, tie-in or bundled sales, minimum resale-price agreements, and discrimination between comparable customers. In this area we comply with Articles 101 and 102 of the Treaty on the Functioning of the EU, the Slovak Act on the Protection of Competition (Act No. 187/2021 Coll.), and — because they reach conduct relating to imports and exports — US antitrust laws. If any Oracle employee ever solicits prohibited conduct, we report it to Oracle's Legal Department.

4. Anti-Corruption, Anti-Bribery, and Anti-Money-Laundering

We apply zero tolerance to bribery and corruption. We never offer, promise, authorize, give, or accept bribes, kickbacks, or anything of value — directly or indirectly, including through third parties — to improperly win business or any advantage.

We interpret "anything of value" broadly: it covers not only money but also gifts, excessive hospitality or entertainment, payment of personal travel, charitable donations made to influence, and offers of employment. This prohibition applies to everyone: government and the public sector (including public utilities, public higher education, public healthcare, and international organizations) and their officials; political parties and candidates; state-owned enterprises and their staff; private companies and their staff; Oracle employees; and any other third party. We apply stricter limits toward the public sector — including the family members of the officials concerned.

We do not make facilitation payments to speed up routine government actions (such as processing permits or approvals). In the area of money laundering, we do not disguise, channel, or legitimize unlawfully obtained funds, and we maintain transparent and traceable financial flows. We comply with the corruption provisions of the Slovak Criminal Code (Act No. 300/2005 Coll.), the Slovak Anti-Money-Laundering Act (Act No. 297/2008 Coll.) and the EU AML framework, as well as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010.

5. Economic Sanctions and Boycotts

We respect applicable international and national sanctions regimes. We take part in no economic boycott that is not sanctioned by the US Government, and we provide no information that could be construed as supporting any such unsanctioned boycott. We likewise comply with EU, UN, and other applicable sanctions programs.

6. Dealing with Government and the Public Sector

We apply stricter standards to dealings with government and the public sector than to commercial customers, because conduct that may be acceptable in a commercial context can be improper or even illegal toward the public sector.

We never seek non-public procurement-sensitive information, confidential internal government information (such as pre-award or source-selection materials), or a competitor's protected information (such as the contents of its bid). We ensure the accuracy of invoices to the public sector and comply with all invoicing and payment rules. We give public-sector officials no gift, gratuity, favor, entertainment, loan, or anything of value, except as clearly permitted by law, and we maintain appropriate internal controls to enforce this. We pay no kickbacks and accept no contingent (success/referral) fees on transactions whose end user is a public-sector entity (including public universities, public healthcare, and utilities).

We comply with the Slovak Public Procurement Act (Act No. 343/2015 Coll.) and, were we to supply commercial products to the US Government, with the applicable US rules, including GSA Multiple Award Schedule (MAS) requirements where relevant. We also follow Oracle's specific rules on how partners may be compensated on public-sector transactions.

7. Lobbying

We do not lobby government on Oracle's behalf. We do not use Oracle's consultants or lobbyists for such purposes, and Oracle does not use ours. We are aware that in some jurisdictions the legal definition of "lobbying" can also cover procurement and business-development activity, and in such cases we comply with all applicable lobbying rules.

8. Business Courtesies (Extended and Received)

When extending any business courtesy, we ensure it is reasonable, ordinary, proper, and lawful and could not be construed as a bribe or an attempt to secure unfair preference. A practical test is the disclosure test: if public disclosure of the courtesy could embarrass Nevdom, the recipient, or Oracle, we do not extend it.

Likewise, we accept courtesies, gifts, or hospitality only where they are modest and proper and could not reasonably be construed as an attempt to secure favorable treatment.

9. Financial Integrity and Business Practices

We document every Oracle-related transaction (and the relevant order forms) accurately and completely in our books and records; we enter into no side agreements, whether oral or written. We create and maintain no undisclosed or unrecorded funds or assets; documents must not be improperly altered or signed by anyone lacking authority. We maintain proper internal financial controls, spend funds responsibly and within authorized approvals, and retain records in accordance with the law and retention rules.

Every request for a nonstandard discount must be accurate and commercially justified, and every approved discount or benefit is used solely for its disclosed and authorized purpose. We never structure a transaction to create margin for an undisclosed or unapproved purpose (for example, to reward a customer, an Oracle employee, or a third party).

We do not engage in "pre-loading" or "channel stuffing": we place an order with Oracle or an Oracle Value Added Distributor (VAD) only after we hold a corresponding end-user order for the same programs, hardware, credits, cloud services, and/or services. We promptly report to Oracle's Legal Department any request by an Oracle employee to do otherwise.

10. Intellectual Property and Confidentiality

We respect the intellectual property of Oracle and of third parties. We do not use Oracle's intellectual property, proprietary or patented technology, documentation, or other materials without written permission or outside the scope of work performed for Oracle, and we never reproduce copyrighted software without authorization.

We safeguard confidential information — we do not transfer, publish, use, or disclose it other than as necessary to perform our work for Oracle or as directed or authorized by Oracle. Materials containing confidential information are stored securely and shared internally only on a need-to-know basis.

We treat as confidential, among other things: source code and software or inventions and developments (at any stage) created or licensed by or for Oracle, marketing and sales plans, competitive analyses, product roadmaps, non-public pricing, potential contracts or acquisitions, business and financial plans and forecasts, internal processes, and prospect, customer, and employee data.

11. Data Protection

When processing personal data, we comply with the General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and the Slovak Personal Data Protection Act (Act No. 18/2018 Coll.). We process personal data on a lawful basis, to the extent necessary (data minimization), ensure appropriate security, and respect the rights of data subjects.

12. Securities and Insider Trading

If we obtain material non-public information through our relationship with Oracle, we do not trade in Oracle's securities (or those of any company the information concerns) and we do not pass such information to anyone ("tipping"). These restrictions also apply to our immediate family members.

We treat information as "material" if a reasonable investor would consider it in a decision to buy, hold, or sell, or if it could affect the price (for example, financial results and forecasts; mergers, acquisitions, joint ventures, or divestitures; the award or loss of a major contract or partnership; key management changes; changes in dividends, share buybacks, securities offerings, or credit transactions; changes of auditor or audit qualifications; significant litigation or investigations; or the gain or loss of a major customer or supplier). Information is "non-public" if it has not yet been released to the market (for example, through a press release or a regulatory filing). In this area we comply with US federal and state securities laws and the EU Market Abuse Regulation (MAR, Regulation (EU) No 596/2014).

13. Trade Compliance

We comply with all applicable US and international laws governing the import, export, re-export, and use of US-origin commodities, software, and technical data, wherever located. We ensure that no technology, data, software, or service deliverable is exported, imported, or used in violation of these laws or for a prohibited purpose. We respect sanctions and dual-use controls (the EU Dual-Use Regulation 2021/821 and EU/UN/US sanctions programs).

14. Conflicts of Interest

We avoid situations that could cast doubt on our ability to act with full objectivity in distributing Oracle products and services, and we keep our loyalty free of conflicts of interest. We disclose to Oracle any actual or potential conflict involving Oracle or its employees, together with all relevant details (and internally within Nevdom).

15. Contracting and Fair Competition

We compete for every business opportunity honestly and ethically, we understand and honor our contractual commitments, and we ensure that every statement, communication, and representation to customers concerning Oracle is accurate and truthful.

16. Advertising and Marketing

We engage in no unfair or deceptive practices. We make no false or misleading statements about our products and services or those of Oracle, we do not falsely disparage Oracle's competitors, we make no unsubstantiated claims, and we do not use trademarks (Oracle's or others') in a way that confuses customers as to the source of a product or service.

17. Equal Opportunity and Anti-Harassment

We affirm equal employment and business opportunities regardless of any protected characteristic — in particular race, religious creed or belief, national or ethnic origin, color, sex or gender, gender identity or expression, age, disability, health or mental condition, pregnancy, marital status, genetic information, political affiliation, veteran status, sexual orientation, union membership, or any other characteristic protected by law. We do not tolerate harassment in any form and maintain a workplace free from harassment. In this area we comply with the Slovak Anti-Discrimination Act (Act No. 365/2004 Coll.) and EU equal-treatment law.

18. Human Rights and Working Conditions

We uphold the human rights of workers and treat people with dignity and respect. Employment is freely chosen — we do not tolerate child labor, forced labor, human trafficking, or slavery in our operations or supply chain. We comply with applicable wage and labor laws (the Slovak Labour Code, Act No. 311/2001 Coll.) and prohibit physical abuse, harassment, and discrimination on any protected ground.

19. Environment, Health, and Safety

We comply with applicable environmental laws and work to reduce our consumption of materials, energy, and water and to reduce, reuse, and recycle waste. We provide a safe and healthy work environment and comply with applicable occupational health and safety law (Act No. 124/2006 Coll.), taking adequate steps to prevent workplace hazards, accidents, and injuries.

20. Duty to Cooperate and Audit Support

We cooperate with Oracle's onboarding and due-diligence processes — providing truthful and accurate information about our company structure, the potential existence of conflicts of interest, and our legal compliance — and we provide cooperation with any audit Oracle is entitled to under any Oracle PartnerNetwork or Distribution Agreement we may enter into. We acknowledge that Oracle may request additional information at any time and that untruthful or inaccurate responses may lead to termination of our rights.

21. Reporting Violations and Whistleblower Protection

We expect everyone to report, in good faith, any actual, apparent, or potential violation of this Code or of the law — including conduct by an Oracle employee.

Nevdom internal channel: reports may be submitted to [email protected]. The person responsible for receiving and handling reports is the Company's managing director. We handle reports with the greatest possible confidentiality and apply no retaliation against good-faith reporters, consistent with the Slovak Whistleblower Protection Act (Act No. 54/2019 Coll.), transposing EU Directive 2019/1937.

Oracle channels (for Oracle-related matters): Oracle Integrity Helpline +1.800.679.7417 (toll-free, 24/7); for entities or employees in the EU, the EU Helpline 866.455.1215; and Oracle's online form at compliance-helpline.com/oracle.jsp (anonymously where the law permits; a third party operates both the helpline and the form). Certain restrictions may apply to reports from the EU.

22. Enforcement and Consequences

We take violations seriously. A violation of this Code may lead to disciplinary action up to termination of employment or engagement and — consistent with Oracle's rules — may be grounds for the immediate termination of distribution agreements and the cancellation of any pending fees, under applicable law.

23. Governance, Availability, and Review

We publish and make this Code available, brief those acting on the Company's behalf about it, and — scaled to the size of the Company — conduct training and periodic reviews of compliance. We keep this Code current and date and version each revision.