Even though the specific activities developed within OXO NETWORK CORPORATION are not secret, a number of aspects of our work can not and should not be overly popular.

The operations with military products, the main activity of the company, are a sensitive one, and any information related to it can be traced and desired, both by competing firms, especially by Romania and its allies.

OXO NETWORK CORPORATION is committed to building a corporate culture of transparency and integrity based on ethical behavior and compliance with laws that govern the specific field. This is essential for the long-term sustainability of our business in a restrictive and competitive market environment where reputation is gaining in difficulty and is the result of the actions of each of us every day. It is also a valuable resource for our customers and communities in which we operate.

     I.        PREAMBLE

The provisions of this Code apply to all employees, contractors, subcontractors, agents, suppliers and anyone who provides services for and on behalf of OXO NETWORK CORPORATION. Even if it does not regulate any situation, it can not be considered a substitute for the application of common sense and good judgment. If there is any doubt about any issue that creates legal, regulatory, legal or regulatory uncertainty, the advice of the immediate superior, the head of the security structure or the manager of the company will be required.

This Code of Conduct defines the guidelines and standards of integrity and transparency that must be respected by all employees, regardless of their hierarchical level.

The principles detailed in this Code will apply to OXO NETWORK CORPORATION’s relationships with its contractors, subcontractors, agents, suppliers, associates, as well as commercial intermediaries, non-commercial agents, consultants or any person providing services for and on behalf of OXO NETWORK CORPORATION remunerated or not.

Its essence is the personal commitment to honesty and loyalty to society and legal transparency in everything that each employee carries out.

The main OXO NETWORK CORPORATION employee’s general obligations can be summarized as follows:

To know and abide by the laws, regulations, policies and procedures that apply during the service and not only;

When they have doubts or are not sure of the action they will take, they can turn to the hierarchical line to get counseling and guidance;

To be vigilant and communicate any aspects or possible violations of law or internal regulations to the immediate superior, security structure or company management team.

   II.        DIRECTI LINES

1.    LAW RESPECT

Employees must know and comply with the law applicable to militar operations. They must be aware that the specifics of ammunition and armament activities are regulated precisely, internally as well as internationally, and inappropriate conduct, a mistake, no matter where they are done, can harm both OXO and of all its employees, possibly involving administrative or criminal liability.

For this reason, if there are doubts that a proposed action or any other activity may subject OXO to legal liability in any country, employees should immediately report to their supervisor, security officer or company manager.

In this context, at each decision and execution level within the company, training and communication on legislative and regulatory novelties will be carried out so as to raise the level of training and knowledge of all employees in terms of skills.

2.    MANAGEMENT TRANSPARENCY

Regardless of the level of adoption, managerial decisions take into account the following principles:

Compared to employees :

– we are committed to honesty, fair management and objectivity, promoting a safe working environment, and respecting the dignity of everyone.

Compared to customers :

– we consider them our business partners and we are determined to deal with them fairly.

Compared to suppliers :

– we treat them as business partners and ensure them fair competition and the sense of responsibility of a right customer and partner.

Compared to society :

– we behave as citizens concerned and responsible for local, national and international issues.

Compared to the associates :

– we are determined to provide solid financial and business goals, optimizing resources and investing soundly.

The entire management process is based on the transmission of clear, accurate and real information, and managerial, transparent decisions. Thus, the information circuit will be intelligible, fluent and optimal.

3.    WORK ENVIRONMENT

Company leadership requires at all levels to maintain a dignified working environment characterized by respect, fairness and principle.

No discrimination based on sex, ethnicity, religion or ideology is permitted in the company.

It is totally forbidden to present at work under the influence of alcoholic beverages, drugs or psychotropic substances. It is also forbidden to consume such substances during working hours.

If an employee has to administer, under control and her doctor’s prescription, medications that may have adverse effects on the state of lucidity, he is obliged to communicate this to the direct head who, depending on the situation, will decide. Under no circumstances will punitive measures be imposed on the employee in such a situation, the concern being to provide him with the best conditions for restoring his health.

We impose both the members of the management team and all of the company’s partners, employees, suppliers, clients, contractors, agents, associates, consultants or any person providing services for and on behalf of OXO NETWORK CORPORATION, to cultivate the following values and principles:

Honesty
  to be honest in everything you do, to be fair with others and with your customers, suppliers, business partners and associates.

Integrity
  to say what we want to convey and deliver what we promise.

Respect
  to treat one another with dignity and fairness.

Trust
  to build trust through teamwork and open communication.

Modesty
  to be modest and want to share with others.

Responsibility
  to communicate and report on workplace concerns, including violations of company laws, regulations and policies, and seek clarifications and instructions when you are in doubt.

Citizenship responsibility
  to respect the laws of Romania and of the states in which we carry out activities and to contribute to the welfare of the community and the nation.

4.    CONFLICT OF INTERESTS

If an employee has a (business or collaboration) relationship with a third party that is detrimental to OXO NETWORK CORPORATION’s interests, he / she is in a conflict of interest.

In dealing with customers, suppliers, agents, contractors and competitors, OXO employees should consider protecting the company’s interests beyond the material benefits of time they might be offered in the context of performing their service duties.

Any work activity that brings to the employees, their relatives or their associates an unauthorized personal benefit that could harm OXO NETWORK CORPORATION or any of its shareholders, customers, suppliers or other employees will be considered contrary to the principles of this Code.

It is forbidden to promise, grant and accept gifts on behalf of the company in pursuit of personal interest.

Even if in the process of initiating and developing business relationships, protocol gifts are often received and / or offered to facilitate communication and harmonization of interpersonal relationships between those involved, OXO NETWORK CORPORATION’s employees should not grant or accept excessive gifts or entertainment or inappropriate, which could create or imply an inappropriate influence or which would be likely to create obligations for the beneficiary.

OXO NETWORK CORPORATION’s employees must take special care when conducting transactions with employees of private companies, as well as employees or officials of government agencies and government-affiliated entities, to ensure that there is no suggestion of non-compliance.

Thus, they can grant and accept low-value gifts, such as small gifts or hospitality gifts, only when they are not intended to create an inappropriate influence or can not be interpreted by an impartial observer as having the purpose of offering or obtaining advantages inappropriate.

Employees who receive gifts or special treatments that do not naturally result from normal courtesy relationships must inform their supervisor, security officer or manager about the actions in question to ask for guidance on how to express an appropriate attitude.

5.    USE OF THE GOODS

OXO NETWORK CORPORATION’s goods should be used with responsibility, with staff being required to ensure that they are used for purposes intended and by authorized persons.

Every employee has the responsibility to protect the company’s property against unauthorized use, abuse of trust, damage or destruction due to negligence or direct intent.

Hardware and software should only be used in the interest of the corporation or for other authorized uses.

Employees are not allowed to use IT equipment, systems and devices for purposes other than those authorized.

It does not have to bring illegal copies of software into the company’s technology environment.

Those who use IT resources will be informed about the restrictions

use, will not violate the license agreements and will not initiate any action that compromises the integrity of the technology systems or subject OXO to any third party or governmental authority.

It is forbidden to bring illegal copies of software into the company’s technology environment.

Those who use IT resources will be informed about the restrictions

use, will not violate the license agreements and will not initiate any action that compromises the integrity of the technology systems or subject OXO NETWORK CORPORATION to any third party or governmental authority.

Technological resources will be handled in accordance with operating regulations and procedures defined by OXO IT specialists.

6.    INFORMATION SECURITY

Information of any kind should be accessed only by authorized personnel and protected against inappropriate disclosure.

In the context of the OXO NETWORK CORPORATION’s specific activities, information is disclosed, the disclosure of which may be detrimental to the interests of the firm or its partners, even if these are not legally classified.

Specific activities in the field of military goods operations may be of interest to third parties who do not always have principal interests. Data relating to contracts, customers, suppliers, means and production methods may be tracked by various individuals, companies or any other legal or illegal entity.

For this reason, it is necessary for each of OXO NETWORK CORPORATION’s employees to adopt a discrete attitude regarding the operations they are knowledgeable about, the activities carried out, the staff employed or with whom they come into contact. Any information may be exploited by external persons to the detriment of OXO NETWORK CORPORATION’s interests.

Employees will maintain confidentiality regard to all the information they have access for OXO NETWORK CORPORATION, even if this information is not secret and does not specifically addresses to OXO NETWORK CORPORATION (for exemple, information about shareholders, customers, competing firms, suppliers, markets, public organizations, etc.) and regardless of the way the information was obtained or the community.

These obligations include, without limitation, information obtained or communicated by verbal, written, electronic means, through the analysis of records and registers, through voice recordings or any other form, as well as information stored on paper or in digital format in the form of documents or files, images, audio and video recordings, or other format.

Through the work done, some of the company’s staff have access to confidential information about sales, sales plans and business plans, financial data, technical information, merger or acquisition activity, management changes, commercial prospects, current products and services and future research and development activities, market studies, results or information that has not been made public, financial forecasts, charts and organizational information, information stored in OXO NETWORK CORPORATION’s storage systems or other information.

As a general rule, confidential information may only be disclosed to authorized parties and sensitive or confidential information should only be disclosed to persons who need to know that information. Personnel must comply with all safety procedures and pursue all elements that may result in the loss, misuse or theft of OXO NETWORK CORPORATION’s information or assets.

The confidential information of other individuals or entities with whom OXO NETWORK CORPORATION engages in business or interacts should also be respected. In case of doubt, all information should be considered confidential and treated as such. OXO NETWORK CORPORATION’s confidential information must be protected to avoid misrepresentation or maladministration. Confidential information should not be used to bring benefits to another employee or business or foreign investment in which OXO NETWORK CORPORATION is involved.

The obligation to protect confidential information is retained for the employee, even after the employment relationship is over.

Failure to comply with this confidentiality obligation will be considered a serious infringement if it involves disclosing or facilitating the disclosure of non-public information regarding OXO NETWORK CORPORATION’s engagements or activities.

Adopting an attitude and conduct characterized by discretion and prudence is necessary for the proper management of contexts that may result in unauthorized disclosure of information.

Recommendations:

• Do not develop professional talks in conversations with friends, both old and new.
• Do not demonstrate your competence and the level of information in open discussions involving people you do not know directly (conferences, symposia, exchanges of experience, etc.).
• You do not accept the provision of consultancy in the field of professional responsibility.
• Do not reveal your vulnerabilities and especially financial problems with less well-known people.
• Do not provide professional information for so-called moral reasons.
• Do not comment on the weaknesses of any kind of colleagues, bosses.
• Do not do things that can be the subject of blackmail or pressure in the future.

7.    FAIRLY OBVIOUS

All employees, irrespective of their functions, are responsible for creating and maintaining accurate records and inventories.

OXO NETWORK CORPORATION’s policy is like:

Records of OXO NETWORK CORPORATION’s must reflect transactions and operations in accordance with legal methods of recording economic and / or technological operations;

false statements, concealment, forgery, circumvention, and other deliberate actions that cause inaccurate financial records and records are illegal and will be sanctioned as such;

transactions should be duly reflected in the OXO NETWORK CORPORATION records so as to enable the financial statements to be prepared in accordance with the applicable accounting standards.

The term “records” is very broad, effectively including any form of information made or maintained on the OXO NETWORK CORPORATION patrimony.

8.    RELATIONS WITH THE COMMUNITY

OXO NETWORK CORPORATION strictly respects the fundamental rights and freedoms of all employees, as stipulated in the Romanian Constitution and international documents.

However, they are not allowed to publicly express their political, religious or any other genres by associating them with the company name, suggesting that they reflect a position of the OXO NETWORK CORPORATION.

Respecting everyone’s right to choice and / or opinion, political, religious or any other kind of propaganda is only allowed outside the offices and without OXO NETWORK CORPORATION’s engagement, being totally forbidden at work points.

In the same context, mentioning the employer on personal profiles on social networks (Facebook, Twitter, etc.) is not advisable.

  III.        CONCLUSIONS

The provisions of this Code of Conduct applies to all OXO NETWORK CORPORATION’s employees throughout the duration of employment contracts.

References to the SECURITY OF INFORMATION are mandatory after termination of employment too, given the major implications that may arise.

This Code of Conduct aims to protect the interests of OXO NETWORK CORPORATION and all its employees as a condition linked to the development of the company’s capacity to provide material welfare to all members of our community.

Failure to comply with these principles may result in legal action on the persons concerned.