[Preamble]

Anti-corruption management is of fundamental importance for sustainable development and the values upheld by Tel-Ster Sp. z o.o. (hereinafter: the "Company"). Actions in this area translate directly into the Company's image as a stable and responsible employer and business partner conducting its activities in a transparent manner, with respect for universal norms of business ethics and integrity. Bearing the above in mind, we have adopted and strictly adhere to the principle of "zero tolerance for corruption," while simultaneously maintaining compliance with legal regulations applicable to our Company and voluntary commitments regarding the fight against corruption. Our priority in anti-corruption management is the elimination of factors that increase the risk of corruption within our business activities, thus adhering to the principle of "prevention first."

[Policy Objective]

§ 1. The objective of this Policy is to define the general framework for the functioning of the system for counteracting corruption threats and preventing conflicts of interest in the Company, in particular to strengthen the awareness of employees, representatives, and stakeholders of the Company in the area of adopted ethical standards.

[General Principles]

§ 2.

1. The provisions of this Policy apply to all employees of the Company and persons representing it in contacts with business partners and public authorities.

2. The Company conducts its business with respect for the law, in a responsible, transparent, reliable, and honest manner, caring for its image as a stable and responsible employer and business partner conducting activities with respect for universal norms of business ethics and integrity.

3. In the implementation of its activities, the Company is guided by the following principles:

1) lack of tolerance for manifestations of corruption or other unethical practices carried out to achieve financial or personal benefits;

2) elimination of factors increasing the risk of corruption;

3) prevention of the occurrence of conflicts of interest;

4) full commitment to activities related to the maintenance, monitoring, and continuous improvement of the system for counteracting corruption threats;

5) creating appropriate attitudes toward corruption threats among employees, persons representing the Company, and contractors.

[Prohibited Corrupt Conduct]

§ 3. It is strictly forbidden to undertake, participate in, promote, or incite any activities of a corrupt nature:

1) bribery – i.e., any activities related to accepting, promising, or giving any financial or personal benefits (directly or indirectly) in order to obtain another benefit, in particular for another person to act in bad faith or to break the principle of impartiality; a benefit shall be understood as any objects, goods, or actions that lead to obtaining any financial or personal gains, improving the situation of the person obtaining them or a person associated with them; benefits may be of a financial nature (e.g., gifts, money, meals, invitations to cultural or entertainment events, a loan granted on preferential terms) or a personal nature (e.g., providing training, promotion in the media, acceptance for an internship, vocational training, offering employment or cooperation, awarding a medal);

2) paid protection (influence peddling) – i.e., undertaking mediation in settling a matter by invoking influence in a state or local government institution, an international or national organization, or in a foreign organizational unit disposing of public funds, or by creating a belief in another person or confirming them in the belief of the existence of such influence, in exchange for a financial or personal benefit or the promise thereof; paid protection shall also be understood as: granting or promising to grant a benefit in exchange for mediation in settling a matter in a state or local government institution, an international or national organization, or in a foreign organizational unit disposing of public funds, consisting of unlawfully influencing a decision, action, or omission of a person performing a public function in connection with the performance of that function;

3) inadmissible preferential act – i.e., an act leading to the privileging of a contractor, provision, or service, performed against the interests of the Company in exchange for granting or promising to grant a financial benefit;

4) abuse of powers – i.e., an action exceeding the scope of competence or an action inconsistent with legal provisions, the articles of association, official duties, or the interest of the Company, in exchange for granting or promising to grant a financial benefit;

5) failure to fulfill duties – i.e., failure to undertake an imposed obligation or improper fulfillment thereof in exchange for granting or promising to grant a benefit;

6) acceptance of a benefit – i.e., accepting a benefit directly (e.g., in the form of banknotes handed over) or indirectly, i.e., accepting information that a benefit has been granted in another way (e.g., transferred to a bank account or to a third party); the mere fact of accepting a benefit constitutes a crime;

7) acceptance of a promise of a benefit – i.e., accepting a proposal made by a person who declares to grant a financial or personal benefit in the future;

8) conditioning the performance of an official act – i.e., implying in any form, yet sufficiently clear and understandable to the other party, that an act will be performed only when a benefit is received or a promise of its receipt is made;

9) demanding a benefit – i.e., a firm, decisive, or categorical demand for something in exchange for the performance of relevant official acts; the difference between conditioning the performance of an official act and demanding a benefit is that conditioning an act can only occur before undertaking that act, while the demand for a benefit may appear at any stage of implementation – before, during, and after the official act;

10) nepotism – i.e., giving another person an unjustified advantage over equivalent entities, e.g., job candidates, in exchange for a private benefit or other favors rendered to the decision-maker; favoring family members or friends;

11) cronyism – also known as protectionism, i.e., a phenomenon of a corrupt nature related to the abuse of power by influential persons in order to achieve a specific social position or material benefit; mutual support of a group of people connected not only by blood ties (kinship) but also by intimacy or membership in a specific group;

12) thwarting or hindering a public tender – i.e., entering into an agreement with another person acting to the detriment of the property owner or the person or institution for which the tender is being conducted, in exchange for granting or promising to grant a financial benefit.

[Reporting Obligation]

§ 4. Everyone, in particular an employee or a person representing the Company, participating in an event bearing the hallmarks of corruption, witnessing it, or having information about such an event, is obliged to report it immediately.

[Whistleblower Protection]

§ 5. 1. The Company provides persons reporting actual or suspected corrupt events with dedicated, confidential communication channels ensuring, among others, the protection of personal data and protection against retaliation.

2. In the event of a suspected violation of this Policy, explanatory proceedings will be initiated to establish the facts and assess whether a violation has occurred. In the event of revealing a violation of the law, the Company shall report it and cooperate in the investigation with the relevant public authorities.

[Conflict of Interest]

§ 6. 1. All Company employees, cooperating persons, and persons representing the Company are obliged to perform their official duties in accordance with the principle of objectivity and impartiality, avoiding situations of conflict of interest.

2. A conflict of interest is understood as a situation in which one possesses such a private interest (e.g., performing work for another entity or conducting business activity) or there are such family, financial, or social ties that influence or may influence the impartial and objective performance of official duties.

3. Company employees, cooperating persons, and persons representing the Company should avoid situations in which their action (e.g., invoking personal connections, giving expensive gifts) or omission could lead to a conflict of interest on the part of clients or contractors.

[Business Gifts]

§ 7. Offering or accepting business gifts (hereinafter also "gifts") is a common way for business partners to express courtesy and respect toward each other. Therefore, the exchange of gifts in purely business relationships is, in principle, allowed if the gift is consistent with legal regulations and accepted business standards of conduct.

[Business gifts not requiring the consent of a supervisor]

§ 8. It is acceptable to receive and keep a gift up to the value of PLN 200 gross (hereinafter referred to as the "threshold value"), provided that the gift and its value constitute generally accepted business practices, the giver will not be suspected of an improper way of conducting business, and the circumstances referred to in § 12 do not occur.

[Business gifts requiring the consent of a supervisor]

§ 9. 1. The consent of a supervisor to accept a business gift is required if the value of the gift exceeds the threshold value specified in tax regulations (PLN 200 gross).

2. The consent of a supervisor to accept a business gift with a value not exceeding the threshold value (PLN 200 gross) is required if these are subsequent gifts from the same donor within the last 12 months, and their total value exceeds twice the threshold value.

[Estimation of Gift Value]

§ 10. In case of doubt by the recipient as to the value of the gift, they are obliged to estimate this value with due diligence, or alternatively, ask the donor to provide this value.

[Principles for Accepting Gifts]

§ 11. When deciding on the appropriateness of accepting a gift, the following should be taken into account in particular:

1) its expected value, in comparison with the value of gifts given as part of typical business practices;

2) the possible total approximate value of gifts already received in the current year from a given contractor;

3) possible legal restrictions and good customs (principle of legalism);

4) the principle of the donor's honest intentions:

a) the gift is not given while the recipient is participating in a decision-making process of which the donor or a person associated with them will be the beneficiary;

b) the donor does not aim to influence the objectivity of the recipient's business decisions;

c) the gift is intended solely to build or strengthen business relationships or to show courtesy;

5) the principle of proportionality:

a) the adequacy of the business gift relative to the position or function held by the recipient;

b) the gift is related to a specific occasion and is given sporadically;

c) the value of the gift is consistent with accepted standards in the given circumstances;

d) the gift does not impose any obligations on the recipient and does not create such appearances;

6) the impact of the gift on building positive business relationships for the Company.

[Unacceptable Business Gifts]

§ 12. It is unacceptable to accept a business gift if the gift is given in circumstances indicating an expectation of reciprocity or creating an obligation to make business decisions, or if at least one of the following conditions occurs:

1) the gift is in monetary form (in the form of cash or another means of payment, including cryptocurrency) or a cash equivalent (e.g., a check, gift voucher, gift card, etc.);

2) the gift is in the form of a sponsored trip or leisure travel;

3) the gift is inappropriate (in particular due to its value).

[Return of Gifts]

§ 13. Persons offered a gift inconsistent with the requirements described above should, in principle, refuse to accept it at the time of presentation. If refusal is impossible or, in a justified assessment, could expose the Company to negative consequences, after accepting the gift, the supervisor must be informed immediately, and subsequently, the gift should be placed at the disposal of the Company for charitable purposes.

[Final Provisions]

§ 14. The Policy shall enter into force on the day specified in the resolution of the Management Board.