The purpose of this policy is to set standards of conduct and minimize the risk of bribery. The company Jaroslav Kačmár – HasPO and its employees are committed to practice a responsible way of behaving and direction, in accordance with the law, regulations and other requirements. We are fully committed to a strong anti-corruption culture and policy that is in line with all anti-corruption laws of the Slovak Republic and the laws of foreign countries and to ensure that no bribes or corrupt payments, incentives, etc. they are not anyone who works for us or on our behalf, performed, offered, sought after or acquired.

Slovak Criminal Code no. 300/2005 Coll. Distinguishes the following forms of corruption:

1. Accepting a bribe (§328) If a person, directly or through an intermediary, accepts or promises a bribe for himself or for another person to act or refrain from acting, in breach of his obligations arising from his employment, profession, position or function, he shall be punished by imprisonment for two years to five years.

2. Bribery (§332) If a person promises, offers or provides a bribe to another person directly or through an intermediary to act or refrains from acting in breach of his obligations arising from his employment, profession, position or function, or for that reason promises, offers or provides a bribe directly or through an intermediary another person shall be punished by imprisonment for up to three years.

3. Indirect corruption (§336) it is based on the acceptance of a bribe by a person who is to influence another person by his influence in order to confer on the bribeer certain advantages consisting in a breach of his obligations arising from employment, occupation, function or position, or on bribery of such other person.

ENTERTAINMENT, CHARITY AND GIFTS

Gifts and entertainment are a legitimate part of corporate culture and should be conducted in accordance with this policy. If the gifts are inappropriate, they may be considered a bribe or a conflict of interest. In all circumstances, a check should be performed when accepting and giving any form of gifts and entertainment on behalf of Jaroslav Kačmár – HasPO. All charitable donations are recorded in writing.

POLITICAL INDEPENDENCE

Jaroslav Kačmár – HasPO does not provide any subsidies to political parties or politically oriented associations.

RESPONSIBILITY AND SCOPE

This anti-corruption policy applies to all employees, independent representatives, contractors, consultants, business partners and all other parties who work with our company. It is the responsibility of all parties mentioned above to ensure the prevention and detection of bribes, and all reports submitted to it must be in line with this policy.

Jaroslav Kačmár – HasPO

In Košice on 04.07.2011