At Betvar a.s., we believe that long-term success is achievable only if our business is founded on strong ethical principles, transparency, and respect for all our employees, partners, and customers.

Our corporate culture is built upon four key areas that guide our approach to daily activities: the Code of Ethics, Anti-Corruption Regulations, Gender Standard, and Whistleblowing.

The Code of Ethics builds upon the behavioral standards and conduct expectations for employees of BETVAR a.s., as established by the Labor Code and other legal regulations, as well as internal policies of BETVAR a.s. and fundamental principles of decency.

It is a set of specific rules designed to uphold standards of proper behavior among employees and to inform our customers about the conduct they can expect from our staff.

Not morality, but decent behavior is what we need.

Oscar Wilde

We take the fight against corruption seriously, which is why we have implemented clear rules for all our employees. These are outlined in the Anti-Corruption Regulations and aim to identify and define areas where corruption could potentially arise. This internal document is aligned with the Code of Ethics of BETVAR a.s.

As employees and management of the company, we are collectively and without exception obligated to adhere to the rules set forth in these Anti-Corruption Regulations.

1 BRIBES

We neither give nor accept bribes in any form.

2 GIFTS

Gifts are given and accepted only under the following conditions:
Demanding any gift or other “benefits” in connection with job performance at BETVAR a.s. is PROHIBITED.

Accepting or giving a gift is permissible only transparently and unconditionally as a regular and socially acceptable expression of friendship or gratitude, without any intention of indebting the recipient.

Exceptions to the general prohibition are as follows:
– Minor promotional items (calendar, diary, company pen, etc.) with a maximum value of 500 CZK
– Promotional items such as goods or products used for marketing purposes, marked with the company logo, and used in connection with the company’s marketing. Any gifts or promotional items that do not meet these conditions will be returned to the donor.

3 CORPORATE HOSPITALITY

Corporate hospitality is permissible only in the following cases:
• Professional meetings for employee development • Business breakfasts, lunches, dinners, provided they are genuine work meetings and do not exhibit features that are contrary to the company’s Code of Ethics • Meetings related to the presentation of services or professional development programs for employees.

When organizing corporate hospitality, it is important to consider the appropriateness of the venue and costs in the context of the event’s purpose. All corporate hospitality events with estimated costs per person exceeding 2500 CZK must be reported to and pre-approved by the employee’s supervisor.

4 REPORTING OBLIGATION

All suspicions must be reported and investigated.

• The identity of any person reporting corrupt behavior is protected.
• Reports should be made by the employee in any form to their direct supervisor.
• Employees are required to inform suppliers, business partners, and all third parties they work with or plan to work with about the rules contained in this document.

Whistleblowing at Betvar a.s. represents an important mechanism for identifying and addressing potentially harmful, unethical, or illegal practices within the company. Our priority is to maintain a transparent and ethical work environment where employees do not need to fear reporting their concerns or suspicions about misconduct.

Betvar a.s. provides a clearly defined process for reporting such practices, which includes confidentiality and protection of the whistleblower’s identity. The goal of this process is to ensure that anyone who reports suspicions of inappropriate conduct in good faith will not face retaliatory measures. Whistleblowers can report internally through defined channels or externally if they believe that internal solutions would not be effective or safe.

INTERNAL REPORTING CAN BE DONE IN THE FOLLOWING WAYS:

ELECTRONICALLY
Email: Reports can be submitted electronically via the email address: oznamovatel@betvar.cz

IN PERSON OR BY PHONE
In person to the relevant individuals at: Nákupní 995, Jesenice

JUDr. Jana Pánková
LEGAL COUNSEL
Tel.: +420 702 181 979