This Code of Conduct defines the minimum requirements imposed on employees, suppliers to Infinity Business Center’s third-party intermediaries regarding their responsibilities by affected/involved parties and the environment. Infinity Business Center reserves the right to reasonably modify the requirements of the Code of Conduct. In this case, Infinity Business Center expects all employees and suppliers to accept these reasonable changes.

The employees, suppliers and/or third-party intermediaries of Infinity Business Center have taken note and respect the following:

1. Compliance with the legislation in force

o Comply with the laws of the applicable system(s) of law(s)

2. Improper Payments, Money Laundering, and Economic Boycotts

a) Prohibition of all forms of corruption and bribery, prohibition to grant, offer, promise, authorize, direct, pay, make, or receive any bribes, kickbacks, or payments of money or anything of value (directly or indirectly) to a government official or a private sector partner with the aim of influencing actions official or to obtain an unfair advantage.

b) Prohibition of all forms of money laundering, which involves disguising, channeling unlawfully obtained money, or transforming such money into legitimate funds.

The above prohibition applies to:

• Government and public sector, which includes public utilities, higher education, public healthcare entities, and public international organizations and their employees or officials
• Political parties or candidates for political office
• Business entities partially or wholly owned or controlled by government interests (often referred to as state-owned enterprises) and their employees or officials
• Privately held commercial companies and their employees
• Any other third party.
• Prohibition of giving money or anything of value, such as gifts, lavish or excessive entertainment, funding of personal travel such as sightseeing, contributions to charity, and employment opportunities, either directly or indirectly, to a government official or employee of a state-owned enterprise, or to the spouse, significant other, child, or other relative of any such person, for the purpose of influencing or rewarding an action or decision of the government or public sector employee or official or to gain any improper advantage.
• Prohibition of facilitation or facilitating payments, which are payments to an official to speed up or expedite routine government actions, including processing and approving applications and permits.

c) Prohibition of participation in any unsanctioned economic boycott and prohibition of providing information that could be construed to support any such unsanctioned boycotts.

3. Fair competition, antitrust legislation and intellectual property rights

• To act at all times in accordance with national and international competition legislation;
• not to agree with any competitors to fix or control prices, either directly or through third parties;
• wnot to agree to structure or orchestrate bids to direct a contract to a certain competitor or reseller, including abstaining from bids or submitting noncompetitive bids;
• not to boycott suppliers or customers;
• not to participate to market or customer allocation;
• not to limit the production or sale of products or product lines;
• refrain from discussing with competitors about prices, costs or profit margins; production volumes or bids, or quotes for a specific customer’s business.

o To respect the intellectual property rights of others

4. Dealing with the Government

o To strictly observe the laws, rules, and regulations that govern the acquisition of goods and services by any governmental entity of any country and the performance of government contracts. Activities that may be appropriate when dealing with nongovernment customers may be improper and even illegal when dealing with government.

o When dealing with any governmental entity, including public international organizations, to be responsible for knowing and complying with all rules that apply to government contracting and interactions with government or public sector employees and officials, including but not limited to the following:

• not to attempt to obtain, directly or indirectly, from any source, procurement-sensitive information that is not publicly available or otherwise authorized for disclosure by the government; confidential internal government information, such as pre-award, source selection information; or any proprietary information of a competitor, including, for example, bid or proposal information, during the course of a procurement or in any other circumstances where there is reason to believe that the release of such information is unauthorized.
• to ensure the submission of accurate invoices to the government and comply with all laws regarding invoicing and payments.
• not give or offer, either directly or indirectly, any gratuity, gift, favor, entertainment, loan, or anything of monetary value to any government or public sector employee or official except as may be permitted by applicable law.
• to establish and maintain appropriate internal controls to ensure compliance with all applicable laws concerning prohibitions on offering anything of value to government and public sector employees or officials.
• not provide, attempt to provide, offer, or solicit a kickback, directly or indirectly, to obtain or reward favorable treatment in connection with any transaction.
• not pay or enter any agreement to pay, directly or indirectly, a contingent fee to any party for the purposes of obtaining a government contract or influencing government action.
• not receive any contingent fees or participate in any influence/referral fee program on any transaction involving a government or public sector end user (this includes, but is not limited to, public higher education, public healthcare, and utility entities).

5. Lobbying of Government Officials

o To be responsible for understanding when the activities may legally be considered lobbying in a particular jurisdiction and for complying with all applicable laws.

6. Trade Compliance Laws and Regulations

o To comply fully with all applicable international or global trade laws and regulations.

o To be responsible for understanding how the international or global trade laws and regulations apply and for conforming to these laws to ensure no technology, data, information, program, and/or materials resulting from services (or direct product thereof) will be imported or exported, directly or indirectly, in violation of these laws, or will be used for any purpose prohibited by these laws and regulations.

7. Conflicts of interest

o To avoid any conflicts of interest that could negatively influence business relations.

8. Respect for fundamental human rights regarding employees

o To promote equal opportunities and treatment for employees, regardless of skin colour, ethnicity, nationality, social context, disabilities, sexual orientation, political or religious beliefs, gender or age

o To respect the personal dignity, privacy and rights of each individual

o To refuse to hire or dispose of forced labour against the will

o To refuse to tolerate any unacceptable behaviour towards employees, such as mental cruelty, sexual harassment or discrimination

o Prohibit behaviour that involves gestures, language or physical contact, with a sexual, coercive, threatening, abusive or exploitative nature

o To ensure fair remuneration and to guarantee the application of the legal minimum wage at the national level

o To respect the maximum number of hours stipulated in the applicable legislation

o To recognize, to the extent that this is possible from a legal point of view, the right of free association of employees and not to favour or discriminate between members of employee organizations or trade unions

9. Prohibition of child labour

o Not to employ workers under the age of 15 or, in countries that are subject to the exception of developing countries within the ILO Convention 138, not to employ workers under the age of 14

10. Health and safety of employees

o To assume responsibility for the health and safety of its own employees

o To control the dangers and take the best possible measures against occupational accidents and diseases

o Provide training and ensure that employees are informed about health and safety issues

o Establish or use a reasonable health and safety management system at the workplace

11. Environment protection

o To act in accordance with applicable statutory and international standards regarding environmental protection

o Minimize environmental pollution and continuously improve environmental protection

o Establish or use a reasonable environmental management system.

12. Supply chain

o Make every effort to promote this Code of Conduct among its suppliers

o To respect the principles of non-discrimination with reference to the selection and behaviour towards suppliers