I. Introduction

Link Group and its employees assume responsibility and obligation to comply with applicable regulations, laws, and also to act in accordance with the established ethical standards.

Link Group’s priority is to conduct business in a manner consistent with all laws and in a professional, transparent, responsible and trustworthy manner.

This Code of Business Ethics (the “Code”) reflects the basic ethical and legal standards that Link Group adheres to in all aspects of its business. For all employees of the organisation, regardless of the form of their employment (the „employee”), it is a model of proper conduct in relations with other employees, customers, contractors and business partners.

Compliance with the provisions of this Code is intended to help Link Group with:

a) preventing the occurrence of behavior which is unlawful or contrary to ethical standards;

b) meeting the requirements concerning occupational safety;

c) developing attitudes among employees consistent with the values ​​of the organization;

d) avoiding conflicts of interest;

e) protecting the good name of Link Group, its employees, customers and business partners;

f) mitigating a risk of imposing financial penalties on Link Group.

II. Responsibility of Link Group Employees and Management.

Each Link Group employee is responsible for:

a) complying with the law and acting in accordance with the law;

b) being familiar with and understanding the principles of this Code and procedures related to the position held;

c) participating in training organized by Link Group;

d) acting in a safe, ethical manner and in accordance with the principles of Link Group;

e) reporting irregularities and possible violations of the law and the requirements of this Code;

f) cooperating in investigations or audits carried out by authorized representatives of Link Group;

g) caring for the good name of Link Group.

The management of Link Group is also committed to the development

and promotion of a culture of ethics through:

a) creating a friendly and responsible work environment;

b) counteracting all forms of discrimination and exclusion;

c) detecting potential and actual violations of the Code;

d) encouraging employees to anonymously report concerns and violations;

e) ensuring that staff is adequately protected in case any irregularities are reported;

f) the ability to listen to and respond to problems reported by employees;

g) providing support in understanding and implementing the principles of this Code.

III. Work Standards at Link Group

Link Group cares about work standards and mutual relations, which are a key commitment of both the organization and its employees. The aim of the organization is, inter alia, ensuring a friendly work environment free from discrimination and unequal treatment and ensuring safe conditions for work.

Link Group also undertakes to:

a) employ only employees with the required work permits;

b) use only legal forms of hiring employees;

c) maintain a friendly atmosphere at the workplace;

d) conduct business activities with respect for human rights;

e) have a respect for diversities;

f) ensure equal access to work irrespective of gender, sexual orientation, religion, social origin or race;

g) ensure working conditions corresponding to the occupational health and safety requirements;

h) provide equal opportunities for promotion for all, based on the criteria of seniority as well as possessed skills and experience;

i) create opportunities to expand knowledge and acquire new skills;

j) ensure freedom of expression;

k) counteract any form of discrimination against employees;

l) ensure a detailed and reliable investigation of all reported violations of the law and standards followed by the organization;

m) respect the privacy of employees and protect their personal data;

n)  ensure the right to rest.

IV. Privacy and Data Confidentiality

Out of concern for the comfort and safety of employees, customers and business partners, Link Group respects the principles of privacy and data confidentiality. In particular, Link Group:

a) processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and national regulations – “GDPR”);

b) collects and stores only the data necessary to conduct its business;

c) does not disclose personal data to any entities and unauthorized persons;

d) stores personal data for the period required by law;

e) provides each person with the right to access their personal data and to obtain other information specified in the provisions of the GDPR.

V. Corruption, Conflict of Interest, Money Land Terrorist Financing.

Link Group does not accept any form of corruption. The market position of the organization is built thanks to an honest and reliable approach to customers, contractors and business partners.

Link Group operates in accordance with all applicable laws and regulations, and therefore employees may not engage in activities that may be considered as corruptive behavior. Therefore, it is forbidden to accept or give any tangible or intangible benefits – both in relation to public and private sector entities.

Link Group does not accept any form of material or non-material support from the assets belonging to Link Group for politicians, political parties and organizations associated with them.

Whenever any attempt to commit corrupt actions is noted or whenever there are any suspicions regarding the said conduct, each employee is obliged to immediately inform his immediate superiors in order to review them and take appropriate measures.

Link Group does not accept activities that may lead to a conflict of interest. Any decisions made by employees, customers or business partners should be based on facts, without being unduly influenced by personal interests. Any person who has information about a potential or actual conflict of interest is required to report it promptly in accordance with the provisions of this Code.

Link Group complies with applicable anti-money laundering and terrorist financing laws and maintains records, including financial statements, in accordance with applicable regulations.

Link Group does not establish and have any relations with persons and entities listed on the sanction lists.

All employees are obliged to promote the principle of ethics and honesty in business relations.

VI. Final Provisions

Each employee is required to submit a declaration of compliance with the principles set out in this Code.

Any failure to abide by the Code may result in a disciplinary action against the employee.

This Code may be amended provided that employees are informed in advance about the changes and about the effective date of the amended version of the Code.

Any deviation from the application of this Code requires a prior approval of Link Group management.

This Code is effective from. …… ..