Code of Ethics

Preamble

Železiarne Podbrezová a.s. (hereafter ŽP or "the company") is an important manufacturing company, which is among the leading producers of steel tubes in Europe. Its history dates back to 1840 and it has excelled in every period as the company was able to face many obstacles and still maintain an excellent position among the metallurgical industry. Since its inception, Železiarne Podbrezová has had a governing philosophy that the success and prosperity of the company depends primarily on its people. On a long term basis careful attention is devoted to organizing professional development of the young generation. Considerable attention is paid to the social, cultural and sports activities of its employees.

Železiarne Podbrezová a.s. declares commitment to ethical principles and respects generally accepted rules, laws and business principles in day-to-day activities of their business. All subsidiaries also undertake to conduct their business activities ethically and legally, in compliance with the principles and vision of the parent company.

The Code of Ethics is a set of principles, standards and requirements that are binding on anyone who chooses to work for a company, who adopts core values and complies with established rules and meets common goals.

This code has been approved by the company management and being followed and enforced by company personnel.

Purpose and aim of the Code of Ethics

The company code of ethics is based on the value common to the entire company and imposes the company expectations from employees and also its obligations to them. The Code addresses various aspects of human behaviour and defines its general areas, not only on the company ground.

Correctness, stability, security, trust and reputation constitute the most important values of the company. Each of us is involved in the creation, promotion and protection of these values. It is how everyone demonstrates their respect to associates, superiors, subordinates, customers, suppliers, and all other partners of the company they come into contact with

Four reasons of implementing ethical codes at workplace

- to transmit corporate culture to new employees, all society and competitors,

- to inform new employees about the rules, standards and principles of behaviour,

- to direct employees in decision-making in work activities, in human interactions and in business contact

- to represent the brand and spread the good name of the company in the business environment and the general public

1. Safety and health protection

A permanent concern of top management of the company is healthcare and safety at work. We are trying to create an hygienically harmless, safe working environment and eliminate as far as possible, risk factors that endanger the health of employees. Outside the workplace, we care about the high level of social and healthcare of our employees.

We create internal company rules in compliance with the laws in place in Slovakia and apply them to workplaces as a priority in order to improve the safety and health of each employee. Every employee is familiar with the security system of our company, and is responsible (for himself and other fellow workers) for knowing and complying with all applicable safety and health protection regulations.

Employees may not bring, store and use alcoholic beverages, other narcotics and psychotropic substances on the company's premises while on duty or coming to work under their influence.

2. Protection of goodwill and company property

Every employee represents in the public not only himself but also our company. We expect them to behave in a manner that does not harm the company's reputation and interests.

Every employee is required to protect the intellectual property, as well as the tangible property of the company. Misuse of information, damage or alienation of the company's property is considered for gross violation of the work discipline.

3. Environmental Protection

We respect the applicable technological and environmental standards and we take care of the environment protection in all our activities. All employees are required to comply with the applicable environmental protection regulations that are related to their working positions.

In the environmental field, we are working on environmental protection and environmental programs in our region.

4. Development of human resources and region development

We create and maintain jobs in and outside the region, contributing to economic growth and raising the living standards of the region and society as a whole. We provide the regions inhabitants employment security, we take steps to stabilize and to increase the professionality of our employees.

We recognize the importance of building a business brand and identifying employees with the company. We therefore support their professional and personal development covering the maintenance and development of their skills.
In working relationships, the company observes the Labour Code, as well as all other generally binding legal standards, the Collective Agreement and the Company management Program.

We hire and deploy workers without discrimination of individuals taking into account qualifications, expertise, practice, personality assumptions and loyalty. We appreciate the loyalty of our employees for which we reward them on their work and life anniversaries.

Through sponsorship and donation, we support healthcare in our region, cultural, educational and infrastructure development.

5. Interpersonal relationships at the workplace

The Company expects every employee to adhere to high ethical standards, promote ethical behavior and be honest and straightforward in dealing with one another and apply the principles of team spirit. Employees understand that they are one team, fighting for the same company goals, therefore they are willing to cooperate, each other in work and inform about important facts.

An employee may not initiate any form of threats, hostilities or insults on the basis of a different race, color, religion, gender, nationality, age, status, disadvantage, or political opinion. Sexual harassment in the form of any sexual attempts at reconciliation is forbidden at work.

A senior employee behaves with esteem, respect, excludes any form of discrimination, humiliation or misuse towards his . In order to resolve conflicting situations, he acts as an impartial arbitrator contributing to social climate in the workplace.

6. Relationships with customers and suppliers

We build long-term relationships with customers and company suppliers, based on mutual trust, honesty and openness. We respect the culture and traditions of suppliers and customers, regardless of their origin.

We undertake to comply with agreed terms and conditions.

We take care of customers' needs, requirements and desires, and address them with quality, delivery dates and the price of the products offered and the associated services. We take care to ensure that our products are of high quality and safe and that they comply with national and international standards. We provide the customer with true and understandable information about our products and services.

We undertake all possible efforts to continuously upgrade our products, production process and product distribution.

7. Conflict of interests

During the working hours, all employees are exclusively engaged in activities that result from their job description, their work contract or an agreement on work done outside employment.

Employee must refrain from any action that could lead to conflicts of interest between employee and the company.

Employee may engage in business activities that are identical to the subject of the Company's activities only with the prior written consent of the Company's management.

Final provisions

This code is binding on all Company employees. Failure to comply with this policy is considered to be a violation of the ethical standards and the job discipline and are assessed and sanctioned in accordance with the company's internal regulations and generally binding legal norms of the Slovak Republic.

The employee is obliged to report a breach of the Code of Ethics to his / her direct superior or personnel department. The announcement can be made orally, in writing, by telephone or email. The relevant superior is required to assess the content of such notice and refer it to the HR Director. Incorrect false announcement with intent to harm a person is considered to be a violation of the Code of Ethics.

The Code of Ethics supplement and extend the rules, principles and standards defined by some internal regulations and company documents. It sets limits that should not exceed, defines the limits and principles of behavior, with an emphasis on values recognized by the company, on relationships both inside and outside.

Podbrezová, date 01. 01. 2018