Code of Ethics and Conduct

1) Purpose and coverage

The Code of Ethics and Conduct sets common standards for employees, managers, contractors, affiliates and consultants. It applies to all business activities, including interaction with clients, partners, regulators and government agencies, and is used in any channels: in person, online, in instant messengers, social networks, at events.

• strengthen a culture of trust and responsibility;
• reduce legal, reputational and operational risks;
• provide clear rules applicable to daily work.

2) Our values (decision basis)

1. Honesty and transparency - do not distort facts, do not hide conflicts of interest.
2. Respect and dignity - zero tolerance for harassment and discrimination.
3. Customer focus and security prioritize quality, fairness, and data protection.
4. Responsibility - keep our word, admit mistakes, correct the consequences.
5. Legality and compliance - we comply with the law and internal policies even under commercial pressure.

3) Equal opportunities, inclusion and non-discrimination

Discrimination on any grounds protected by law is prohibited.
Decisions on hiring, payment, promotion - only on competencies and results.
Reasonable conditions and accessibility for people with disabilities are mandatory.
Regular training on inclusion and ethical engagement.

4) Banning harassment and bullying

Any form of sexual harassment, threats, bullying, humiliation is unacceptable.
Quick and confidential resolution of complaints; protection against reprisals for bona fide communications.
Training managers in correct de-escalation and conversations.

5) Conflicts of interest

What is it: situations where personal gain or external connections can affect official decisions.

• Annual declaration of possible conflicts; event declaration in case of changes.
• Recusal from decisions if relatives, own projects, affiliated companies are affected.
• Prohibition of "hidden" shares from suppliers/affiliates without disclosure and approval.

Examples of conflicts: part-time work at a competitor; Purchases from a relative's company gifts for speeding up approvals.

6) Gifts, hospitality and hospitality

Symbolic signs of attention are permissible in reasonable limits and without the expectation of counter benefits.
Cash, gift cards, "luxury" trips without a business purpose are prohibited.
All exceptions - only with prior written approval and entry in the register.
For interaction with government agencies, there are stricter rules (up to a complete ban).

7) Anti-corruption norms

Zero tolerance for bribery, kickbacks, "lubrication" and bypassing tender procedures.
Due diligence of third parties (affiliates, agents, consultants) is required.
Contractual anti-corruption clauses, right of audit, prohibition of sub-intermediaries without agreement.

Immediate messages to the channel of informants at the "red flags."

8) Honesty in products and communications

Advertising and offers - without misleading promises and hidden conditions.
Manipulations of indicators, statistics, reviews and reporting are prohibited.
For iGaming - transparency of rules, responsible practices, respect for vulnerable groups.

9) Privacy and data protection

We observe the principle of minimization: we collect only what is needed, store as much as required.
We protect personal and trade secrets technically and organizationally; prohibition of external transfer without legal grounds.
The use of AI/analytics is ethical and legal, taking into account privacy risks.
Any suspicious activity or leakage - immediately into the incident channel.

10) Use of company assets and information security

Assets (hardware, software, licenses, access) are used strictly for their intended purpose.
Unauthorized copies of software, password sharing, bypassing control systems are prohibited.
MFA, password policy, timely update and blocking of accounts upon dismissal are required.
Offline data (paper media) - under physical protection and with destruction control.

11) Communications and social networks

Public comments on behalf of the company - only by authorized persons.
In personal accounts, avoid disclosing confidential information and conflicting statements on behalf of the brand.
Follow copyright and content license rules.

12) Compliance with laws and regulations

We comply with data protection, consumer protection, labor, tax, antitrust, export and sanctions regimes.
In disputable situations - contacting lawyers/compliance before the action.
In different countries - compliance with local norms and restrictions of marketing/advertising.

13) Responsible Play (for iGaming)

Age restrictions, self-exclusion, limits, transparent rules, and probability of outcomes.
Banning targeting of vulnerable groups, honest communication about risks and RTP.
Timely response to signs of problematic player behavior.

14) Intellectual Property and Insider Information

Respect for copyright, software licenses, content and brand assets.
Prohibition on the use/transfer of non-public commercial information for personal purposes.
Coordination of open-source contributions, publications and public speaking if company/client secrets are affected.

15) Environmental and social responsibility

Use resources wisely, reduce waste, choose sustainable suppliers.
Supporting employee and local community wellbeing initiatives.
Ethical supply chain requirements.

16) Reporting Violations: Channels and Protection

Available confidential channels (including anonymous) 24/7: trunk, internal portal/bot, Compliance/DPO address.
Any repression of conscientious informants is prohibited.

Confirmation of receipt - within 7 days; preliminary assessment - in 30 days; Total/Status - 90 days or earlier

17) Investigation and disciplinary action

Investigations are carried out by an independent group with confidentiality and the principle of "strictly necessary to know."

Measures range from training and prevention to termination of the contract and transfer of materials to law enforcement agencies.
The "chain of custody" of evidence is fixed; an impersonal post-report is prepared to improve processes.

18) Roles and Responsibilities (RACI Matrix)

19) Metrics and performance monitoring

Training coverage (% of employees completed the course on time).
Number and structure of messages by category, average response time.
Percentage of confirmed conflicts of interest and closed CAPA measures.
Results of internal audits and independent audits.
Survey of the "trust index" to whistleblower channels.

20) Practical checklist for the employee

1. Can I explain my action to the client/regulator/press?
2. Is there personal gain or hidden influence here?
3. Does the action comply with the law and policies (code, anti-corruption, privacy)?
4. Does the action harm the company's reputation and user trust?
5. If in doubt, I consult with the manager/compliance before the action.

21) Acknowledgement of familiarization

All employees and relevant contractors annually confirm familiarization with the Code and training. Violation of the Code is regarded as a disciplinary offense.

22) Related Documents

Whistleblower policy and personnel protection

Anti-Corruption Standards and ISO 37001

Gift and Conflict of Interest Policy

Privacy and data protection policy

Information Security and Incident Management

Responsible Gaming Policy (for iGaming)

Communications and Social Media Guide

Output

The Code is not a "book of prohibitions," but a practical tool: it helps to quickly make ethical decisions, protects employees and customers, and business - from legal and reputational risks. Regular updates, training, clear message channels and personal responsibility of everyone are key to a sustainable ethical culture.