Violation Reporting Policy

SEABERRY TECHNOLOGIES DOO BEOGRAD (hereinafter referred to as SEABERRY TECHNOLOGIES DOO) sincerely appreciates the assistance of employees and third parties (business partners) acting on behalf of SEABERRY TECHNOLOGIES DOO who identify and report any violations, unethical behavior and potential problems that need to be resolved.
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By considering all communications, SEABERRY TECHNOLOGIES DOO achieves goals such as minimizing reputational, financial and operational risks that could lead to a decrease in the company's operational and development potential.
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SEABERRY TECHNOLOGIES DOO guarantees the safety and confidentiality of anyone who raises concerns in good faith. SEABERRY TECHNOLOGIES DOO has zero tolerance for any retaliation for speaking out.

The Policy applies to all SEABERRY TECHNOLOGIES DOO employees working at any level of the organization, as well as to all third parties (business partners), including those acting on behalf and (or) on behalf of SEABERRY TECHNOLOGIES DOO, including customers, partners, suppliers, consultants, agency employees, contractors and other persons.

At SEABERRY TECHNOLOGIES DOO we are committed to the principles of honesty and openness. If you witness or suspect any misconduct or unethical behavior at work, report it. Your reporting can prevent violations that could harm SEABERRY TECHNOLOGIES DOO's reputation or business, and even prevent harm to people.

The purpose of this policy is to ensure that employees or any third parties have a detailed and transparent opportunity to report, including anonymously, violations, unethical behavior and potential issues, without fear of retaliation.

If you become aware of or have information about any potential violation of the law, SEABERRY TECHNOLOGIES DOO policies, business processes, policies or procedures, please report it. There are many examples of what things should be reported:
- Fraud;
- Bribery, corruption or commercial bribery;
- Violation of an individual's rights;
- Hiding information;
- Discrimination or harassment;
- Violation of laws and competition rules;
- Abuse of official position;
- Money laundering or violation of trade restrictions;
- Inadequate financial or non-financial accounting;
- Conflict of interest;
- Violations related to environmental protection, health and safety;
- Incorrect use of company information resources;
- Disclosure of confidential information;
- Violation of personal data protection rules;
- Persecution of someone for speaking in good faith;
- Other violations.

SEABERRY TECHNOLOGIES DOO takes every report of misconduct or unethical behavior seriously and always conducts compliance audits. All business units are interested and take part in conducting such an audit. The originator of the report will be informed of the overall findings of the compliance audit within the specified time frame.
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If an SEABERRY TECHNOLOGIES DOO manager receives a report of a violation, unethical behavior or potential problem, he is required to maintain complete confidentiality regarding the report. He should document all available information and immediately contact the Ethics and Compliance Committee to discuss the matter further.
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When engaged to participate in a compliance audit, all employees are expected to cooperate fully and answer all questions posed honestly and in detail. Lying, delaying, interfering with proceedings, inaction or non-cooperation may result in disciplinary action. All parties involved have the right to confidentiality to avoid unnecessary damage to their reputation. Consequently, all participants are expected to maintain confidentiality about their participation in the investigation and known details.

When reporting a violation, the applicant’s personal data is not disclosed (except for cases where their transfer to third parties is required by law). SEABERRY TECHNOLOGIES DOO provides support and protection to anyone who reports a violation, unethical behavior, or potential problem in a sincere and good faith manner.
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If you or others are retaliated against because you raised your concerns in good faith, you should report them through one of the channels listed below.
If the report is substantiated, and the compliance audit confirms the violation or unethical behavior, then the necessary measures will be taken, as provided for in policies and regulations.
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SEABERRY TECHNOLOGIES DOO needs information from business partners and customers. During any communication, SEABERRY TECHNOLOGIES DOO employees are obliged to convey to counterparties information about the methods of informing and forms of reporting the discovery or suspicion of violation or unethical behavior on the part of any SEABERRY TECHNOLOGIES DOO employee. Data of business partners and clients is not subject to disclosure (except when their transfer to third parties is required by law). The business partner or customer will be communicated with the results of the compliance audit on a confidential basis unless there is a legal reason why SEABERRY TECHNOLOGIES DOO cannot communicate it.
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In the field of Compliance, Quality, Personnel Policy, Security and Legal Affairs, SEABERRY TECHNOLOGIES DOO addresses and adheres to the requirements and other fundamental documents:
- Code of Business Conduct, Ethics and Compliance;
- Quality Policy;
- Policy of zero tolerance towards corruption and commercial bribery;
- Conflict of Interest Policy;
- Privacy Policy;
- Business partner due diligence policy.
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A complete list of current policies, violations of which can be reported, can be found on the website https://www.seaberrytech.com/.

How can you report violations?
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Option 1: Inform your immediate supervisor. You are encouraged to report misconduct, unethical behavior or potential violations to your supervisor in the first instance. If you are uncomfortable contacting your immediate supervisor or he is unable to help, you should use the methods below.
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Option 2: Inform the Ethics and Compliance Committee. Notify the Chief Security and Compliance Officer or any other Ethics and Compliance Committee representative of the violation. This can be done in any accessible form of communication accepted by SEABERRY TECHNOLOGIES DOO, including with complete confidentiality.
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Option 3. Report to a special mail. You can also submit information about a violation, unethical behavior or potential problem by email to compliance@seaberrytech.com or other means of communication specified in the appropriate section on the website https://www.seaberrytech.com/ or the corporate portal. Use this channel if you require anonymity.

Do not use this policy:
- To report events that pose an immediate threat to life, health or property. If you require emergency assistance, contact law enforcement or contact emergency services;
- To resolve personal or legal disputes outside of work procedures;
- To make deliberately false accusations. This may lead to disciplinary action and, in some cases, legal liability.
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When reporting, you must ensure that you do so in good faith and have reason to believe that the information is true. When reporting violations, unethical behavior or potential problems, you are encouraged to provide as much specific information as possible, including names, dates, locations and details of events that occurred.