Fostering Fair Relations

Code of ConductHauska & Partner International Communications Group

Hauska & Partner International Communications Groupwww.hauska.net

Austria, ViennaTel. +43 2236 26114

Croatia, ZagrebTel. +385 1 4500 222

Czech Republic, PragueTel. +420 221 592 450

Serbia and Montenegro, BelgradeTel. +381 11 3287 397

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Leo HauskaPresident, Hauska & Partner Group

Change is thekey word of ourcentury. Thatincludes dramaticsocietal changestak ing p lacearound the globethat open upquestions aboutcorporate andp e r s o n n e lva lues . Th i s

change also brought about dynamicdevelopment of our industry. Today weknow about the power of communicationsand relationship management and potentialimpact they have on our work and thesociety. We are aware of our capabilitiesin driving this change. Over the last decadeswe have learnt how to manage stakeholderrelations strategically and we support ourclients in achieving their goals throughprofessional relationship management.

The transformation of our society includeschanging the role of the civil society andincreasing expectations towards companies,especially transnational ones. Our clientsare faced with new challenges emergingfrom different angles and are everincreasingly asked to integrate social andenvironmental concerns in their businessoperations and in their interaction withstakeholders. With our expertise instakeholder relations we are able to assistour clients in fulfilling this task by managingand directing their social responsibility.

To be active in this field for us means tobe at the forefront. Our corporate valuesfocus on excellence, passion andresponsibility. Therefore, we see it as ourobligation to also be a step ahead in thisf ield and to contribute to furtherdevelopment of CSR and relatedmanagement practices. Besides that, weare also affected as a company and, as aninternational SME, face specific challenges

relating to effective and efficient CSRManagement. Therefore, two questionshave become important for us right fromthe start: How can we support our clientsand assist them in their challenges in thebest possible way and, what do we haveto do in taking over social responsibility asa corporation?

As CSR is not a project, but rather aprocess, two main aspects which havearisen characterize our approach towardsthis issue: First, it is a matter of our values,our intention and our willingness to embarkupon this direction. Second, this processrequires a thoroughly planned system forongoing development and improvement, aclearly defined way of managing andsupervising it as well as carefully evaluatingthe progress in this regard together withour stakeholders. This code of conduct isthe basis for the both. It is our first step inthis direction and more is to follow. However,even before you go through these pages,

we invite you - as a reader of these lines- to join us in our efforts and work togetherwith us. For us it is more than duty. Weenjoy going this way. As a service industrywe have to serve the society. This is whywe will also go with passion towardsexcellence in responsibility management.

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Daria Mateljak BartulinManaging Director, Hauska & Partner Croatia

For centuries ourcivilization hass t r u g g l e d t ocreate citizens,families, forms ofb u s i n e s spartnerships, ort h e w h o l es o c i e t i e s t ou n d e r s t a n d ,a c c e p t a n dembrace the

concept of abiding by the Law. It took wars,revolutions and dramatic societal changesuntil people began to practice lawcompliance. Even today, in many cases,reluctantly so. It is not in human nature torespect the imposed laws and regulations.The time, however, has come, when abidingby the Law is not enough. What makes atrue difference is whether people, organizedgroups of people or businesses decide togo beyond the barrier of imposition andforced compliance (at least philosophically)

and have courage to step into the territoryof chosen improvement. Even betterdefined, the territory of socially rewardingand enriching contribution to the ownorganization and people who are tied to itin all forms of relations. In other words - wehave a choice to do things better and to dothem in a different way. Today, in mycountry, Croatia, this takes managerial andprofessional courage. Tomorrow, I stronglybelieve, it will be the only desired way ofprofessional living.

Code of Conduct, therefore, is not a set ofrules that prescribes some imposedboundaries on the group of people whodecided to share their professional lives. Itis much beyond that - a choice to be better,to bring difference to ourselves, oureconomic and social prosperity and ourpersonal careers. Doing business in a post-transition country brings along specificchallenges. Hauska & Partner team inCroatia takes great pride in doing ourconsulting work in the way that is not only

law-abiding, but also brings difference in astep forward to a better operating, moreefficient, more fair and more prosperoussociety.

Our objectives are not only to bring betterstandards to consulting business, but alsoto become a leader in the SME field. Hauska& Partner corporate values are deeply inbuiltin the mindset of our employees -management and juniors alike. Being aconsul tant bears many d i f ferentresponsibilities and we take this burdenwith the unique joy that only a great desirefor success can bring. Our ultimate objectiveis to help our clients reach their businessgoals. This means that we identify with ourclients completely. The same identificationto the profession is a prerequisite for ouremployees.

Therefore, the Code of Conduct is alighthouse on a foggy night on the ruffledseas that shows us where our mainland is.This Code stems from beliefs, integrity and

values of our employees and from the visionof our management. We do our businesswith excellence, in a reliable way,contributing to the society and with passionand dedication. Our values were bornefrom our personal beliefs, we pledged themto our company and we live by them. Thisis what and how we work with our clientsand our partners. This is how we wish tomake our society a better place.

Our civilization is only superficially gettingmore complex. We, at Hauska & Partnertake things very simply. Living our valuesin our everyday business and building ourrelations on the sound cornerstones ofopenness, fairness and contribution.

Our Code of Conduct is one leading lighton our way to achieve our business andprofessional goals. It is not a book of rules.It is a book of our character. It is what weare and what we respect.

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Introduction

We believe that Hauska & PartnerInternational Communications underpinsprofessional and personal qualities wedevote to the development of long termand trustful relat ionship with ourstakeholders. Our professional and personalqualities equally apply to every countrywhich we operate in.

This code is both contemporary and

visionary. It encompasses our presentendeavors with our commitment to futureaccomplishments. It is also our roadmapon which we have placed signposts forethical behavior.

In our consulting role we act as a dailyobserver of all relevant local, regional andglobal developments in the world ofbusiness, politics and society in general.

In these developments the issues of goodcorporate governance and responsiblebusiness behavior became central in thedebate on the role of business in the modernsociety.

In the process of addressing these issueswe have looked inwards and at the sametime have questioned the cases whichbecame universally quoted examples ofirresponsible company behaviors. Howcome that companies with codes of conducthave failed in providing an adequatemanagement and employee practices, wasour ultimate question, upon which we haveplaced a particular emphasis.

We have therefore evaluated our businessand organizational settings, our keystakeholders and the society in general inorder to develop coherent and realistic codewhich would truly represent who we are,how we are and how we relate to increasedsociety expectations regarding responsiblebusiness practices.

This code applies to both our managementand our employees. Our primaryresponsibility is to achieve sustainablegrowth for our clients and ourselves. Weare all responsible for sustaining ourprofessional and personal qualities byopenly addressing all the issues that mightor already pose an ethical dilemma in ourdaily operations and for resolving themadequately.

This code is also a basis for developingbooks of rules and regulations, specificrules and procedures to assure fullcompliance, which will accentuate localdifferences.

Adherence to the code will be ensured byregular training on the code, annual auditsand assessments and by fosteringsupportive corporate culture. We have alsonominated person who is responsible foroverall ethical program implementation onthe level of the group and person for everycountry.

this code is bothcontemporaryand visionary

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Core purpose & values

Hauska & Partner values emerged fromindividual values of our shareholders,management and employees. Upon thesevalues we have built our corporate cultureand all our business operations rest uponour values. All actions that we undertakeexternally as consultants or internally as adeveloping team that always strives for thebetter are entwined with the meaning ofthe values that we chose are the mostrepresentative of how we wish to live, shareknowledge and do business.

ExcellenceWe constantly strive to provide the bestconsulting and to incorporate the higheststandards and the best-developed skills inour daily actions. Excellence reflectsconstant growth in knowledge andleadership in action. This means that:

We employ people who constantly wishto develop professionally and whocontribute to excellence

Our team demands the respect of highest

standards of quality

We invest in our growth, developmentand raise our competence daily

To our clients we provide tailor-madesolutions that can in the best way assistthem to achieve their business goals

We are innovative and contribute to thedevelopment of our profession

ReliabilityWith our behavior we deserve to be trustedand entrusted with assets and intangiblevalues. We care for stability and act in themanner to provide protection, help, adviceand consultancy so that we take intoaccount our stakeholders’ rights andinterests. This means that:

We fulfill our responsibilities towards ouremployees, shareholders, clients, societyand other stakeholders

Our employees can rely on the companyand their colleagues for stability ofemployment, income, professional growth

and challenging work

Our clients entrust us with their problemsand issues and believe in our capabilitiesto help them solve these issues andachieve their business goals

We are behave in a responsible mannertowards our profession, our communityand the society

ContributionOur purpose is to provide the bestconsultancy to our clients, safe employmentto our team and good framework for theirprofessional development, prosperity to ourshareholders, tangible and intangiblebenefits to the society, constantly addingin value, scope, quality and strength. Tocontribute means to give with adding qualityand value. We are dedicated to:

Contributing to our clients’ wealth, notonly by providing excellent requestedservice, but also reaching further andproactively coaching, teaching andeducation to the clients in the domain ofour expertise

Contributing to our employees’ quality oflife, by enabling them to achieve theirhighest potential, respecting theirprofessional ambitions and providing ahealthy, desirable environment for theirdaily work

Contributing to the quality of ourprofession by innovation, businessdevelopment, fair and sound practices,investing in education and enablingmarket development

Contributing to the values of Europeansociety and good practices, not only bybeing a role-model in abiding to theregulations and laws, but exceedingbeyond that and responding to the needsof the society wherever communicationsconsultants may add value

Passion and DedicationWe believe that the best consultancy,besides great knowledge and skills, has tocultivate the element of passion and strongbelief. It includes a dedicated approach topeople and things and full commitment to

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the clients, stakeholders and issuesattached. Passion and dedication meanadditional energy invested in our work,greater attention to the issues, betteridentification with clients and greater loyalty.

We are passionately devoted to ourprofession, company, team, clients andpositive issues we promote as consultants

Our work exceeds the simple need tohave a job and make existence; weapproach our philosophy and our actionswith full dedication

We strongly believe in our values andenergetically put them to work in our dailybusiness

We approach our stakeholders with thedesire to understand them and to shareour values with them

We are fully devoted to our clients andcommitted to their success

DiversityWe equally value our similarities and ourdifferences. We recognize that we all comefrom different cultural and social settings

Corporate Governance

Management Board is responsible for soundmanagement of the group businessoperations. Leadership in the group is basedon the premise that ethical behavior shouldnot be exclusively understood ascommitment to legal compliance, althoughwe recognize that ethics can only exist

where there is an effective and respectedlegal infrastructure, but as a value drivenquest for sustaining professional andpersonal behavior that is not pursuingbusiness for the sake of business beforeanything else. Members of the managementboard have therefore set wide agenda tofollow:

we recognize that ethics can onlyexist where there is an effectiveand respected legal infrastructure

and therefore we take efforts to understandeach other and merge diverse experienceand knowledge to build strong network ofpeople who work together as one team.

We cherish qualities which enable us tounderstand, accept and cultivatedifferences

We believe that with diversity of ideas,background and perspectives ouremployees enable us to build morecomplete picture and adapt better tocomplexities and challenges of modernword

We are fully aware that working in adiverse team can be more difficultbecause we confront different and oftencontradictory perspectives and yet westrongly believe that working in diverseteams helps our employees to be moreopen and develop new approaches

We respect diversities in the society andtake effort to understand and accept eachstakeholder and group and are dedicatedto bringing different perspectives together

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Sustaining financial and social capital(long-term stability and profit, quality ofrelationship with stakeholders, reputation)

Fulfilling duty of loyalty and duty of carefor the group, placing the best interestsof the group first, and helping the groupto create new values

Providing transparent information on thegroup activities

Taking clients individually and being fullydedicated to helping each client in aspecific way by recognizing their uniqueneeds and context in which they operate

Competing successfully and fairly

Understanding of the relevant nationaland regional contexts in which the groupoperates

Mitigating risks and fostering newbusiness opportunities

Encouraging accountability of allemployees

Promoting the team

Openly seeking suggestions from everyemployee and encouraging employeesto raise any concern, question andcomplaint in good faith

Promoting fair and open communicationbetween management and employees

Promoting diversity and developingqualities that enable acceptance andunderstanding of differences

Promoting sound balance betweenvarious areas of life and encouragingemployees to dedicate themselves tofamily and other out-of-work activities

Encouraging leadership practices by allemployees

Engaging in public dialogue andpromoting responsible business practicesand positive changes in the societies

Legal compliance and companyrecords

As we operate in different countries everygroup member complies with relevantnational laws and regulations. We arecommitted to strict compliance with the lawsand regulations that apply to Hauska &Partner International Communicationsbusiness operations.

Every group member also followsinternationally accepted professionalstandards. Our business operations areconducted on a transparent and accuratebasis.

Every group member is also entitled to keepall books and records in accordance withapplicable national laws and accountingstandards. We do this in order to ensurefinancial integrity of our group.

C o m m u n i c a t i o n s w i t h o u rstakeholders

We believe that engaging with stakeholdersbuilds our capacities for understanding.We approach our stakeholders with thedesire to understand them and to shareour values with them. Understanding is byall means one of our key assets by whichwe position ourselves as consultancies that“do things in different way”.

We recognize that stakeholders may havedifferent expectations towards us. We,however, believe that essential foundationfor any relationship is trust and this codesets the standards for behavior they canexpect from us. We foster only reasonableexpectations among our stakeholders.

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Employee relations

Every employee in Hauska & PartnerInternational Communications should be aleader in bringing sustainable growth to theclients and the group. At any level of ourgroup every employee should be strivingfor the excellence by incorporatingknowledge, competence, efficiency andquality, highest standards, courage andvision in our day-to-day requirements.

Every employee in Hauska & PartnerInternational Communications can rely onstability of employment, income, health andsafe working conditions, professional andpersonal development and challengingwork.

Every employee is expected to adhere withthe following requirements:

Pursuing the best interest of thegroup. We expect our employees toexclusively act for the benefit of the group.We forbid pursuing private interests orsimultaneous work for a competitor or a

client. In doubt, employees shouldquestion their actions and consult theirmanagers in order to make sure that theydo not harm the interests of the group.

Appropriate use of companyresources. We expect our employeesto use company resources in responsibleand ethical manner, primarily forconduct ing the group businessoperations. Computer software, electronicmail or the Internet is not to be used forunauthorized personal use.

Fair and open communications. Weexpect our employees to communicate

in fair and open way. They should showrespect one to another and respect theright of every employee to have differentopinion.

Safe work place and healthy life style.We expect our employees to report anyunsafe conditions and encourage saferworkplace practices. We are drug andalcohol free organization. We expect ouremployees to practice healthy lifestylesand we encourage them to organize theirlives accordingly.

Respecting the differences. We expectour employees to respect differentlifestyles, ethnic or national origin, religionpreferences, age, marital status, genderor sexual orientation. Our employees areprohibited to perform any action whichmay promote or encourage hate andviolence or stir up prejudices. Ouremployees must not use electronic mailto disseminate information that promotesdiscrimination. We expect our employeesto display qualities of acceptance and

understanding.

Seeking sound balance betweenvarious areas of life. We expect ouremployees to dedicate themselves tofamily and other out-of-work activities inorder to become more completepersonalities. We believe that employeeswho are capable of realizing themselvesin different areas perform in a better wayand bring excellence in every aspect oftheir professional day-to-day life.

Striving for excellence. We expect ouremployees to be willing to develop theircompetences. We expect our employeesto share acquired knowledge and skillson daily basis.

Having constructive role in team. Weexpect our employees to work togetheras a total team. In a total team we respectand build up our strengths and overcomeour weaknesses. We are proud of everymember of our team and we expect thatevery team member shows a healthysense of collegiality and mutual respect.

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Clients

Our reputation is built upon our uniqueapproach to our clients. Our approach isrooted in the very essence of ourconsultancy work - we constantly challengeourselves in order to sustain new valuesto our clients.

We deliver our services to clients byemploying our best assets, engaging themost suitable knowledge and skills, andselecting the most appropriate team.

We deliver our services to clients notonly to fulfill our contractual obligationsbut to achieve results that are base forbuilding long term and trustful relations.

We are accessible, providing qualityservice in time and according tostandards of practice and professionalconduct on the part of public relationsand business advisors.

Having respect for the client and actingalways in the best interest of the clientis our standard rule for engagement.

We partner with our clients.

We strive to understand our clients, theirneeds, visions and specific characteristicsof industry or sectors in which theyoperate in, complex social and marketdevelopments.

We offer our clients specializedknowledge and skills helping them tobetter understand and manage theirsustainability issues.

Business partners and suppliers

In selecting business partners and supplierswe take all reasonable measures todetermine legality of their operations andbusiness conduct. We seek the proof of allrelevant publicly accessible informationabout operation of a company we plan topartner with. The legality of businessoperations and business conduct isconsidered as a special competitiveadvantage. We conduct our selectionprocesses with great care and accordingto clearly set out criteria.

Competition

We believe that competition is essential forachieving sound business environment. Inour market approach we:

Compete in fair and collegiate manner.

Promote fair and open competition asessential for achieving sound businessenvironment.

Never speak about our competition orcriticize their actions. On the other hand,if actions of our competition undermineprofessional standards we all apply to,we will openly discuss them in relevantforums.

Never use deceptive means in order toobtain information regarding ourcompetition.

we constantly challengeourselves in order tosustain new values

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Community and Environment

We actively play a role in communities byfostering values we have recognized aselemental to our philosophy and strategy.As responsible community members we:

Comply with all laws and governmentregulations

Meet and raise all relevant professionalstandards

Fulfill all our tax and contractualobligations

Support projects that are aimed atimproving stakeholders relations andunderstanding of stakeholders’ issues inmodern society

Good PR leaves the mark...

Strategic Communications

Reputation Management

Media Relations

Internal Relations

Public Affairs

Risk and Crisis Management

Corporate Social Responsibility

We assess our environment performancewithin the framework of our consultancywork. We monitor on our impact coveringfollowing areas: travel, people, energy,waste, water and paper.

Hauska & Par tner In ternat iona lCommunications recognizes important roleof the private sector in building sustainablesocieties. Therefore, we have alsoexpanded our business portfolio to enableother companies to more efficiently managetheir sustainability issues.