Code of Conduct

1. CSG Aerospace insists on high ethical standards based on honesty, trust, transparency, openness, integrity and accountability for its employees and partners, in addition to compliance with legal requirements.

1. CSG Aerospace has joined Transparency International's anti-corruption program for the security technology sector and its employees are required to familiarize themselves with the requirements of this program and to act in the spirit of this program in their activities.

1. CSG Aerospace's general responsibility for the implementation of CSG Aerospace's anti-corruption program rests with management, and the anti-corruption program is implemented by CSG Aerospace's Chief Human Resources Officer, who has direct access to management regarding the anti-corruption program and is responsible for the continued implementation of the Company's ethics and anti-corruption agenda. He is also responsible for monitoring and evaluating the implementation of CSG Aerospace's ethics and anti-corruption program as well as establishing a formal process for addressing allegations of corruption.

1. CSG Aerospace strictly rejects and prohibits any corrupt behaviour among its employees, in the event that corruption is proven against the perpetrator, it claims compensation for the damage it has caused to the company, immediately terminates the employment relationship with the perpetrator as a rule and, in accordance with its legal obligation, immediately reports the corrupt behaviour to the Police of the Czech Republic, which may initiate criminal prosecution.

1. CSG Aerospace prohibits any actions by employees in conflict of interest. It follows that CSG Aerospace employees may not participate in CSG Aerospace's supplier or customer relationships for goods and services, either directly or indirectly, and may not personally benefit from such relationships from any entity other than CSG Aerospace. As a precautionary measure, an employee should report the risk of conflicts of interest arising from, for example, family or friends serving on the boards of directors of companies that are suppliers or customers of the Company, or holding shares in such companies, to CSG Aerospace's Human Resources Manager.

1. In the event of a reasonable suspicion of conduct that is grossly unethical, corrupt, disruptive to workplace safety, environmental protection, or damaging to CSG Aerospace's reputation, the employee or anyone with credible knowledge of such conduct should report the conduct through CSG Aerospace's Ethics Hotline. However, reports should not be made that are petty, without evidence, or even untrue with the intent to personally harm someone. Such suggestions are the full responsibility of the whistleblower and may be sanctioned as they undermine trust and standard working relationships within the company and ultimately contravene the Code of Ethics.

1. CSG Aerospace employees, especially members of the Sales and Marketing Department, are required to inform external partners, especially suppliers, of CSG Aerospace's anti-corruption program, or those parts of it that apply to external partners.

1. CSG Aerospace's salespeople are required to consider corruption risks in the process of evaluating business opportunities and negotiating business cases. These are determined in particular by whether the customer is from the public or private sector, the position of the customer's country of origin in Transparency International's global anti-corruption ranking and the procurement method (competitive or single-entity approach).

1. CSG Aerospace's business partners are required to investigate from public sources available in the media and on the Internet whether there are proven cases of corruption in relation to CSG Aerospace's external partners and to take this into account when making business decisions, including the possibility of not engaging or terminating relationships with partners where corruption has been identified.

1. As part of building good relations, particularly in the business area, CSG Aerospace provides standard services to its partners, including the possibility of reimbursing CSG Aerospace partners for the cost of their stay and providing gifts and courtesies. However, it is prohibited to provide partners with unreasonably luxurious accommodations, unethical and expensive entertainment services, or to give them gifts that are clearly unreasonable in value. Such conduct is considered potential corruption in relation to CSG Aerospace partners. Similarly, CSG Aerospace's managers and employees, particularly in its sales department, are prohibited from accepting such grossly inappropriate services or luxury gifts. In the event of such conduct by a partner, a CSG Aerospace employee is required to report the matter to a supervisor.

1. In some foreign markets, facilitation payments may be required by public officials, which are legal under local law. CSG Aerospace is strictly prohibited from providing facilitation payments. The definition of facilitation fees does not include commercial commissions to private sector partners, e.g. under licensing or agency agreements.

1. Sponsorship gifts that are purposely tied to any public or private sector business opportunity are prohibited. This rule similarly applies to donations to political parties and movements.

1. The aim of the Code of Ethics is not only to apply it in CSG Aerospace, but also to promote the anti-corruption agenda and honest business to the public and the business sector in the country and in foreign markets.

This Code of Conduct shall enter into force on 1st January 2020.
Aleš Klepek
Chairman of CSG AEROSPACE, a.s.