Conflict of Interest Policy

SEABERRY TECHNOLOGIES DOO BEOGRAD (hereinafter referred to as SEABERRY TECHNOLOGIES DOO) considers that SEABERRY TECHNOLOGIES DOO employees and contractors carry out conscientious actions that meet mutual interests and do not undermine the trust of legal entities, individual entrepreneurs and individuals, employees, participants and shareholders, and other persons regarding SEABERRY TECHNOLOGIES DOO or its procedures.
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Conflict of interest means any situation in which an employee or a close relative of an employee has an outside interest that could affect the objective performance of his or her duties for SEABERRY TECHNOLOGIES DOO, regardless of whether that interest actually affected their performance.
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The appearance of a conflict of interest can often be as damaging as its actual existence, as it may raise doubts or suspicions and undermine the confidence of legal entities, sole proprietors and individuals, employees, members and shareholders, and others regarding the integrity of SEABERRY TECHNOLOGIES DOO or its procedures.

The presence of a conflict of interest is not a violation, but creates a risk of illegal actions.

Declaration and identification of conflicts of interest, its settlement and resolution of any situations related to the presence of a conflict of interest is the most important element of interaction between the employee and SEABERRY TECHNOLOGIES DOO.

This Policy sets forth the standards and procedures that SEABERRY TECHNOLOGIES DOO employees and contractors must follow when conducting business in order to prevent actual or perceived conflicts of interest.

The relationship between SEABERRY TECHNOLOGIES DOO, its employees and contractors must be based on mutual trust.
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SEABERRY TECHNOLOGIES DOO employees and contractors must strive as a matter of principle to avoid any relationships, influences or activities that:
- interfere with their ability to perform their official functions;
- interfere with making fair and objective decisions when performing their work;
- harm the interests of SEABERRY TECHNOLOGIES DOO.
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Dealing with conflicts of interest is based on the following principles:
• The principle of mandatory disclosure. SEABERRY TECHNOLOGIES DOO welcomes the declaration of potential or actual conflicts of interest by an employee when they arise.
• Principle of data completeness. To decide on the presence or absence of a conflict of interest, SEABERRY TECHNOLOGIES DOO uses exclusively verified and available information from official sources.
• The principle of individual approach. Risks for SEABERRY TECHNOLOGIES DOO are reviewed and assessed individually for each case where a conflict of interest is identified.
• Principle of information confidentiality. All information about an employee’s conflict of interest and how to resolve it is not publicly available and is subject to protection.
• The principle of equivalence. The interests of the employee and the employer must be taken into account equally.
• Principle of guaranteed protection. SEABERRY TECHNOLOGIES DOO guarantees maximum protection against retaliation for any employee who reports a conflict of interest and assistance in resolving any disputes that arise.The above principles should apply to all SEABERRY TECHNOLOGIES DOO employees, regardless of their position.

In order to ensure maximum integrity in the conduct of SEABERRY TECHNOLOGIES DOO's business, and in view of the expansion of SEABERRY TECHNOLOGIES DOO's business (including the acquisition of new organizations), each employee and counterparty must promptly and fully declare the presence of a potential conflict of interest when it arises, or when it becomes aware of it. actual or possible existence.

The main objectives of this conflict of interest policy are:
- identification and definition of conflicts of interest for counterparties and SEABERRY TECHNOLOGIES DOO employees;
- ensuring a procedure for declaring conflicts of interest;
- settlement of conflicts of interest individually in each individual case.
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The structural unit that determines whether a conflict of interest actually exists and helps resolve or eliminate it is determined by the General Director of SEABERRY TECHNOLOGIES DOO.

SEABERRY TECHNOLOGIES DOO expects its employees and contractors to openly declare information about existing or potential conflicts of interest.The procedure for declaring a conflict of interest for SEABERRY TECHNOLOGIES DOO employees, resolving it or eliminating it is described in the Regulations for declaring and resolving conflicts of interest.
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SEABERRY TECHNOLOGIES DOO's counterparties may declare a conflict of interest through feedback services.
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Conflicts of interest can take many different forms, including:
- using your position in SEABERRY TECHNOLOGIES DOO for personal gain;
- engaging in activities that may bring direct or indirect profit, benefit or advantage to direct competitors;
- ownership of shares (stakes in the authorized capital) of a direct competitor;
- use of contact information received through SEABERRY TECHNOLOGIES DOO for personal purposes;
- use of SEABERRY TECHNOLOGIES DOO equipment or property for the development of third-party business or for personal purposes;
- having a personal relationship with another SEABERRY TECHNOLOGIES DOO employee, including those in the same team or directly subordinate;
- the presence of family ties with another SEABERRY TECHNOLOGIES DOO employee, including those in the same team or directly subordinate.
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The listed forms of conflict of interest fully apply to counterparties.

This Policy applies to all employees and contractors of SEABERRY TECHNOLOGIES DOO.
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If there is a conflict of interest, the necessary measures are taken to resolve or eliminate it.
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All cases of conflict of interest are considered on an individual basis.
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Violations of this policy, concealment of potential conflicts of interest, or other actions intended to cause any harm to SEABERRY TECHNOLOGIES DOO may result in disciplinary action being taken against employees.
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The decision-making and activities of an employee or counterparty cannot be influenced by ownership of stocks and bonds. Accordingly, SEABERRY TECHNOLOGIES DOO will not ask for a declaration of this information.
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SEABERRY TECHNOLOGIES DOO may, under certain circumstances, limit situations in which close family members or employees in a personal relationship may work together.

SEABERRY TECHNOLOGIES DOO uses various terms in the area of conflicts of interest.
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Close relatives - father, mother, brother, sister, son, daughter, husband, wife, grandmother, grandfather or any other person living together in this family.
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External interest - additional income, third-party business or agreements to provide services to external parties, including:
- any additional (second) job, part-time job;
- activities in addition to one’s work at SEABERRY TECHNOLOGIES DOO in order to increase one’s income, individual entrepreneurship, self-employment;
- ownership or participation in other organizations;
- provision of consulting or other services;
- charitable and/or public work;
- any other third party activities.
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Counterparty is any person interacting with SEABERRY TECHNOLOGIES DOO or acting on behalf and/or on behalf of SEABERRY TECHNOLOGIES DOO, including customers, clients, contractors, suppliers, consultants, advisors, distributors, agents, commercial and other intermediaries.
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Personal relationships are regular and ongoing relationships, interpersonal, business or financial in nature.
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Competitor is an organization that offers the same services for similar customer needs and in the same market as SEABERRY TECHNOLOGIES DOO.
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Employee - any employee employed by SEABERRY TECHNOLOGIES DOO on a permanent or temporary basis.
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Financial interest - anything of material value, including wages or other payment for services (work), participation shares and/or value of intellectual property rights, investments from a legal entity or individual with whom SEABERRY TECHNOLOGIES DOO has a transaction or arrangement, direct and indirect remuneration, as well as gifts or services that are not immaterial.

Managers at all levels must be aware of conflicts of interest among their subordinates.
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If there is any doubt about the existence of a conflict of interest, such information should be declared.
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To prevent potential conflicts of interest, employees should not:
- engage in business that may distract from completing work and achieving goals;
- have relationships with competitors outside of work tasks or compete with SEABERRY TECHNOLOGIES DOO independently;
- maintain a financial interest in legal entities or organizations that are clients, suppliers or other partners of SEABERRY TECHNOLOGIES DOO, as founders or managers;
- work or cooperate directly with family members or with persons with whom the employee or contractor has a personal relationship, being in direct or indirect influence on each other.