CODE OF ETHICS

SCOPE

The Code applies to all employees of the Company. It is based on the Company’s rules and values. The Company always strives to conduct its operations in legal, ethical and responsible way with regard to employees, customers and partners. Therefore, we expect all our stakeholders, including suppliers, to adhere to similar or higher standards and conduct their business ethically.

Core values that we adhere to in our daily operations:

1. Communication

We communicate to establish clear, fair and ethical relationships.

2. Respectfulness

Respectfulness is a core foundation on which relationships within the Company’s team and work with clients and partners are built. We respect the opinion of each employee, we treat our clients and partners respectfully. The principles of mutual respect and understanding are fundamental in the Company.

3. Reliability and responsibility

In the Company, we committed to a collective responsibility for any actions taken by the team. There are no omissible issues in relations with clients and colleagues. Fulfillment of any obligation creates trust, non-fulfillment destroys it. To build relationships in the team, to assume responsibility, it requires from team member to understand the scope of responsibility within the the obligations assumed.

4. Safety

We aim to provide safety and balance for our employees, customers, and partners both now and in the future.

5. Commitment to make things better

We commit to improve every product we make for each of our customers regardless of the size of their company.

6. Sustainable development

We strive to ensure our development is in line with the highest social and environmental standards.

All employees must learn the Code of Ethics and follow it in daily operations.

Non-compliant operations by any employee may be considered a gross violation of discipline and the Company’s rules.

All reports of the Code violation is confidential. The Company will not tolerate retaliation against any employee who reports of a violation of the Company’s ethical principles in good faith.

FAIRNESS

The Company will endeavour to be fair and equitable in all of its business and financial affairs. We will always be honest and transparent and expect our partners and suppliers to act accordingly.

INDIVIDUAL RESPONSIBILITY AND ACCOUNTABILITY

At the Company, we value individual responsibility and accountability and allow all of our employees and contractors to work without undue restriction or sanction. We will hold ourselves accountable to the highest ethical and professional standards and measure ourselves against these. We expect all of our employees and contractors to do the same.

FINANCIAL REPORTING

The Company operates a policy of financial transparency in all of its operations and expects all of its suppliers and partners to do the same.

HUMAN RIGHTS

Our relationships with employees and stakeholders are based on respect for human rights, dignity and fairness for all. We encourage all our stakeholders to respect human rights in accordance with the Universal Declaration of Human Rights in all countries of operation.

NON-DISCRIMINATION

The Company does not embrace or tolerate any form of discrimination. We value the diversity of our staff. Diversity is based on equal opportunity for all, and we do not discriminate our employees in recruitment and career on race, religion, nationality, colour, gender, identity, age, marital status, or disability that is not related to work.

WORK SAFETY

The Company provides appropriate work safety in accordance with applicable legislation. All workplaces, equipment and processes do not endanger the health of employees. Introduction and training on work safety are provided. There is free access to a first aid kit, drinking water, rest rooms, emergency exits, adequate lighting and fire-fighting facilities.

CONFIDENCE

At the Company, we protect the right to privacy of our employees. Our employees’ data and information will remain confidential and will not be used without their consent, except as permitted or required by law.

WAGES AND WORKING HOURS

The Company guarantees to pay wages not lower than government-set minimum wages. The remuneration of employees is formed on the basis of current legislation on wages, as well as overtime pay. Compliance with the working hours duration rules, as well as the rules of the maximum permissible working hours per week, is ensured. The operation scheme provides an appropriate rest during work for the safety and health needs of employees.

COLLECTIVE BARGAINING

The Company adheres the right and freedom of the workers to associate and to choose their own representatives, while ensuring that these employees are not subjected to any discrimination. The right to collective bargaining on working conditions is also recognized.

WORK EVALUATION AND CAREER

The Company ensures equal opportunities for the employees based on evaluation, motivation, and career development:

• we embrace the communication, mental, organizational and technical skills of each employee as our main strategic resource, and we are committed to nurture and appreciate their development, because it forms our main asset;

• we provide every employee with the opportunity to perform better, contributing to the continuous improvement of professional competence and developing the ability to work in a team, thereby to comprehend the Company’s mission;

• we promote the responsible participation of employees in the Company’s activities, and invite them to operate actively to feel their participation in Company’s development and, accordingly, to realize themselves as professional;

• we appeal to our employees to ensure and to promote the responsible use of energy and materials when performing work operations.

EMPLOYEE’S CONDUCT

The Company and its employees must adhere all rules of conduct with business partners, suppliers and colleagues, and must respect their personality and privacy. All employees are obliged to behave transparently, fairly and respectfully, as well as to cooperate addressing issues that may arise. The attitude to other employees and stakeholders must be kind regardless of gender, age, race, colour, identity, religion, disability or nationality. The employees and Company’s management are due to maintain a working environment free from discrimination or humiliation.

EMPLOYEE’S INTERACTIONS WITH COLLEAGUES

The employee has to encourage relationships with colleagues based on mutual respect, trust, and adherence to professional ethics. The employee must:

• be a person of high moral and ethical standards in profession, kind, honest and fair;

• demonstrate tolerance to and acceptance of alternative opinions, ethnic and cultural norms and religion of colleagues, respect their opinion and beliefs;

• be kind and friendly to colleagues, respect the work and experience of each team member;

• assist to and share working experience with young colleagues, and nurture their ethics;

• respect mentors and senior colleagues;

• demonstrate professional and corporate solidarity, contribute to positive publicity of the Company in every way;

• adhere to the moral and ethical traditions adopted in the Company;

• be a person of ethical behavior not only in the team, but in wider society also.

CONFLICTS OF INTEREST

The Company operates a policy for the declaration of conflict of interests and asks all employees and trustees to declare any interests they might hold in companies associated with, investing in, partnering with or supplying services to LTD “FABRIKA ZDOROVO”. The Company also expects all partner organisations and suppliers to declare any conflict of interest concerning their organisation, staff or associates they might be aware of.

ENVIRONMENTAL RESPONSIBILITY

The Company concerns environmental issues. Mitigation of climate changes, protecting the environment and the efficient use of natural resources are important for the Company. We believe that the Company could make a significant contribution to these, especially in the social and environmental context of its activities, both in the short and long term. Such a contribution may concern both the use of natural resources and the direct impact of Company’s operation in a form of harmful emissions and any kind of waste the Company generated. In this regard we:

• ensure full and complete compliance with legal requirements regarding environmental issues;

• constantly look for effective innovative solutions in the environmental field, including solutions in products for our customers and appropriate offers to our suppliers;

• promote a boost of generally accepted standards of environmental responsibility;

• advocate the responsible use of natural resources we consume in our operations, including implementation of the environmental policy and gradual decrease of energy use;

• aim to select and source the facilities and materials (equipment, tools, raw materials, packaging, additives, etc.) that do not harm the environment, local residents, or our employees;

• strive to implement the maintenance and optimization strategies on the product design stage to make our operations safer and more environmental friendly while to optimise use of raw materials.

Volodymyr Dasiuk,
Director, LTD «FABRIKA ZDOROVO»

Reviewed: 28/07/2025

Next review: before 28/07/2026