STEPTO DOO BEOGRAD – CODE OF ETHICS

STEPTO DOO BEOGRAD, located at Bulevar Vudroa Vilsona 6, 13th floor, apartment no. 01, registration number: 21742953, tax ID: 112803663 (hereinafter referred to as "STEPTO") has vital interest in the good reputation of the company and positive lasting relationships with all of its suppliers and customers. Maintaining the Code of Ethics by the company is a voluntary moral obligation, which recommends how employees should treat the company as such, how they should treat their colleagues, suppliers, customers and all state administration agencies and the general public. We are aware that the listed ethical principles reflect on the entire company, on the shared company values presented by its individual employees and the way they treat their surroundings when they represent the company as such. We are convinced that if our business activities are to be successful, we must think of the economic as well as social and ecological principles and to include a social and ecological scope to our business activities besides generating profit.

1. ANTITRUST AND COMPETITION

We diligently comply with rules for fair competition practice.

Every company employee prevents and eliminates situations, which could lead to the violation of fair competition rules.

We stand against all activities, which could lead to cartel agreements, exchange of information with the competition, or agreements, which would lead to an artificial increase in prices as well as agreements on end prices in various competitions and so forth.

2. IMPROPER PAYMENTS, MONEY LAUNDERING, AND ECONOMIC BOYCOTTS

We always stand against money-laundering and the financing of terrorism and strongly disagree with all acts, which could lead to such activities.

We are a regularly audited company with regularly disclosed economic results.

Any time an employee is suspicious that a counterparty is attempting to use STEPTO products or services for an illegal purpose, such as money-laundering or any other illegal practices, they are obligated to immediately inform their supervisor of the matter.

3. MAINTAINING BUSINESS AND LEGAL REGULATION

We keep our accounts in such a way that it always contains true and accurate information about the management, pay taxes properly and on time and avoid any actions that could be considered tax evasion. STEPTO considers the payment of other statutory mandatory payments to be a matter of course.

All matters related to business relationships, offers and other activities for reasons of fulfilling business and company goals are strictly governed by valid laws of the Republic of Serbia.

We strictly refuse any type of behavior, which could lead to the violation of these laws.

We undertake to comply with all legitimate legislative requirements set forth for our company conducting its business in Republic of Serbia and to maintain its valid laws.

We also require conduct that is fully compliant with the law from our suppliers and customers.

If a company employee uncovers any violation of laws of the Republic of Serbia, they are obligated to immediately inform their supervisor of this matter.

4. LOBBYING OF GOVERNMENT OFFICIALS

We consider contact with members of public administration just as confidential as contacts with other business partners.

If an employee obtains confidential information on corrupt activities of members of state and public administration, that employee is obligated to immediately inform their supervisor and must cooperate during the investigation to uncover the corruption.

We strongly stand against requests for bribes or other such activity, which could be perceived as corrupt, and we also reject any behavior of our employees, which could be perceived as corrupting.

We strongly refuse such conduct and behavior of employees, which could be considered as trying to exert influence, and we also reject any type of gift giving that could lead to the change of opinion or attitude of the receiving counterparty.

5. TRADE COMPLIANCE LAWS AND REGULATIONS

STEPTO, and our individual employees and responsible persons always perform quality and professional work so that customers are satisfied. The company provides high quality services for which it is fully responsible.

The goal of STEPTO activities is always comprehensive fulfillment of customer requirements. We offer customers services that benefit them. It also strives to ensure long-term customer relationships. We communicate openly with them and responds flexibly to their needs and requirements.

We act so as not to harm customers. In the event that there is a risk of harm to the interests of customers, STEPTO informs of this fact in a suitable form so that customers know about this risk.

6. RELATIONSHIPS WITH CUSTOMERS AND SUPPLIERS

We act consistently and fairly in all our business relationships – with customers, suppliers – and always protect their rights.

We run our company based on principles of openness, fairness, and responsibility.

We are always open during negotiations and we always share relevant information with our employees, suppliers, and customers including company financial health, company performance, ownership, and management.

We always strive to cultivate the good name, trustworthiness and reliability with business partners, employees and all other parties involved.

It is strictly forbidden to accept other forms of financial profit, which could influence decision-making in business matters to the detriment of the company or damage the company’s good name with business partners and all other parties involved.

We always defend the good name of our suppliers and customers in front of third parties.

7. POSITIVE BUSINESS ENVIRONMENT

We act according to national and international free trade regulations during competitive tenders.

We always maintain confidentiality and act fairly.

We strictly keep business secrets confidential.

We consistently maintain and fulfill all our obligations based on concluded contracts and business negotiations.

We consider abiding by all valid laws as the basic foundation of successful business.

We provide a full guarantee on the quality of our products and services.

8. HUMAN RIGHTS

We never participate on the violation of basic human rights and freedoms.

STEPTO completely rejects child and forced labor, nor does it practice any form of exploitation or slavery or practices that would restrict the free movement of workers.

We try to support those who are socially disadvantaged using suitable methods.

We prevent direct and indirect discrimination based on sex, sexual orientation, ethnicity, race, citizenship, nationality, language, health, religion, faith, marital status and other circumstances that could be used as grounds for discrimination in our working legal relationships.

Each employee shall be thoroughly informed and educated on all aspects of sexual abuse, harassment, and any other forms of abuse in the workplace. This includes mandatory training sessions, access to comprehensive resources, and clear reporting procedures.

9. RELATIONSHIPS WITH EMPLOYEES

Our priority is to build good relationships at the workplace, to respect our employees and maintain good relationships between everyone, to keep them informed and provide fair and rightful remuneration and bonuses.

We strive to improve the qualifications of individual employees.

We continue to build a dignified and adequate working environment.

We refuse to tolerate any type of discrimination or processes that violate rights and good inter-personal relationships.

We always look out for a good “work-life balance” of each employee.

We inspire our employees to act fairly, politely and hold them personally accountable for cultivating the good name of our company.

10. ARTIFICIAL INTELLIGENCE

Even though we utilize AI in our business operations, we are committed to ensuring that its use never violates human rights nor misuses the technology. We affirm our dedication to the responsible use of AI, ensuring it serves as a force for good in our business practices and beyond.