Relevant to all companies within the Sportisimo s.r.o. corporate structure (hereafter “Sportisimo”)

I. This Code of Business Conduct and Ethics (“Code of Conduct”) is enacted by Sportisimo as by-law no.1/2015 under the internal Work Rules & Regulations in compliance to Section 306 of the Czech Republic Labour Code and is therefore imperative to all Sportisimo employees.

II. This Code of Conduct sets out basic guiding principles for employees governing their conduct towards customers, colleagues and third parties, in relation to the relevant legal enactments and moral, ethical and trade conduct.

III. Non-compliance with the principles set out by the Code of Conduct may result in disciplinary action up to and including discharge.
IV. Independent third parties have the right to report any violation of the Code of Conduct and to hereafter receive a reply with an account of the disciplinary action taken, if applicable. Nevertheless, Sportisimo must not disclose any information that would intervene with the statutory rights of employees or third parties, including protection of honour, reputation and privacy.

V. By violating the policy outlined in the Code of Conduct the respective employee becomes liable towards Sportisimo, however, does not generate a liability of Sportisimo or of the employee towards independent third parties or institutions.

VI. This Code of Conduct takes effect April 1, 2015 and is valid for 10 years.

VII. This Code of Conduct will be published and promoted publicly as appropriate, so that:
i. all Sportisimo employees all familiar with the Code of Conduct;

ii. all business associates, customers and independent third parties have the chance to become familiar with the Code of Conduct.
VIII. The content of the Code Of Ethics reads as follows:

1) Basic Principles And Values
Employees must follow applicable laws, internal Work Rules & Regulations, general principles of etiquette and this Code of Conduct at all times.

Our Values:
• professional attitude
• customer fixation
• reliability
• loyalty
• mutual respect and support

An employee is acting as a representative of the company when dealing with a customer or third party and therefore acts consistently with our values, acts always in the best interest of Sportisimo and does not disclose confidential and non-public information.
An employee respects their manager’s directions and immediately informs them if an extraordinary situation arises at any time, on the side of the customer, contractor or an independent third party.

2) Protection Of Company Property 
All employees are liable to protect the company property. Company property is defined as all material assets, facilities, resources and goods, as well as financial and intellectual property including trade secrets and confidential information. In order to protect the property it must be safeguarded in an appropriate manner. Each employee is required to safeguard the outlined property in a manner appropriate to his/her position. A third party must not be given access to the company’s computers for instance. Furthermore, Sportisimo’s records, accounts and financial statements must be maintained in appropriate detail, must conform both to applicable law and to the Company's system of internal controls.
3) Use Of Sportisimo Resources
Company resources including cash, work force, software, cars or electronic devices must not be used outside of the usual scope of business activities.

4) External And Media Communication 
Only authorized Public Relations representatives are allowed to make public statements on behalf of Sportisimo. Without prior authorization employees should not speak on behalf of Sportisimo on any public platforms, including media and the internet.
5) Personal Data Protection
Sportisimo complies with all relevant data protection laws. Some of our features and services require that we collect, process and store personal information to some extent. Therefore we put special effort into adopting relevant technical and organizational means to protect personal data from unauthorized access.

6) Confidential Information Policy
Employees may encounter non-public information that reflects Sportisimo’s business activities (such as expansion plans, proposed supplier changes, etc.) or confidential information about Sportisimo itself. Such “insider information” must not be used without authorization. Furthermore, employees must abide the relevant Law on the Protection of Economic Competition and must not enter into any formal or non-formal agreements with competitors.

7) Conflicts Of Interests
Each employee must avoid any situation that may create a conflict between their personal or their relatives’ interests and the interests of Sportisimo, which may arise at a meeting with business partners, associates or third parties. If an employee’s position allows him to potentially exert influence over a matter of business, he/she is required to disclose all potential conflicts to their manager, including all financial, proprietary or other relevant interests (such as a business or personal relationship with a customer, supplier, etc.).

8) Gifts And Rewards – Anti Corruption Policy
It must be ensured at all times that business activities (including customer contact) are judged objectively and without any interfering interests. Therefore, employees must not provide or accept any gifts, provisions, loans, vacations, services, entertainment nor any other favours with an estimated value over 1000 CZK in exchange for a favourable decision or to secure a favourable treatment for themselves or third parties. Under no circumstances is it allowed for employees to receive cash with the prior objective. If an employee is offered a gift outside the above limits, they must promptly report it to their manager. Any waivers of the code must be approved by the manager beforehand (see app.1 – Notice of Gifts and Services).

9) Discrimination And Harassment
Dignity, cordiality and mutual respect are key aspects of our code of communication, between coworkers, third parties and customers. We strictly refuse all forms of discrimination on the basis of race, sex, age, nationality, ethnic background, ideology, sexual orientation, religion, social background or handicap. From our employees we expect mutual respect and full co-operation.

10) Health And Safety
All employees are required to comply with Work Health and Safety Regulations at all times and to immediately report any shortcomings they might come upon.

11) Point Of Contact
For any questions regarding the Code of Conduct or in order to report a violation employees should speak to their manager. Alternatively, they may as well contact the designated compliance representative. Given their nature, all such queries or claims are regarded as strictly confidential.