Ethical Code

Code of Professional Conduct and Interaction with Partners and Clients

I. General Provisions

1. This code establishes the principles, rules, and standards that Stenik Group Ltd. (“Stenik”) applies in its professional activities, including in its relationships with clients, partners, and similar organizations.

2. The purpose of this code is to ensure a high level of ethics, transparency, confidentiality, and good practices in the development of software solutions and related technology services.

3. The provisions of the code are mandatory for all employees, subcontractors (if any), and representatives of Stenik.

II. Ethical Standards

1. Professional Competence and Responsibility

    1.1. Stenik carries out its activities with the necessary care, skill, and professionalism, in line with industry best practices and the local market preferences and realities.

    1.2. All employees and representatives of Stenik are required to perform their duties conscientiously, with quality, and in accordance with contractual obligations to clients and partners.

    1.3. Stenik strives to ensure that it does not take on disproportionately large or complex commitments (including project development and service provision) for clients or partners for which it does not have the necessary expertise or the ability to develop it alongside providing the services, and without explicitly informing the respective counterparties.

    1.4 In order to maintain high standards and professional service, Stenik reserves the right not to accept commitments or respond to inquiries that do not align with its strategic business focus and core activities and/or have unclear parameters, goals, and scope, as well as those for which the client cannot provide the necessary input information.

2. Honesty and Transparency

    2.1. Stenik maintains correct and transparent relationships, providing clear, accurate, and complete information regarding scope, timelines, limitations, and expected results.

    2.2. Intentionally misleading, incomplete, or inaccurate statements are unacceptable.

3. Confidentiality and Information Protection

    3.1. Any information provided by a client or partner is treated as confidential and used solely for the purposes of the respective project.

    3.2. Access to confidential information is granted only to persons whose job functions require it, strictly applying the "need-to-know" and "least privilege" principles.

4. Corporate Ethics

   4.1. All employees adhere to high standards of integrity, respect, and professional behavior.

   4.2. Discriminatory, dismissive, offensive, manipulative, or hostile behavior toward clients, partners, or colleagues is neither tolerated nor encouraged.

   4.3. Stenik encourages constructive dialogue, resolving disputes based on facts and arguments, and an overall solution-oriented approach rather than conflict.

5. Zero Tolerance for Corruption

   5.1. Stenik has zero tolerance for corruption and bribery. Offering, promising, or accepting unlawful financial or other benefits to gain business advantage is not allowed. 

   5.2. Any gifts (including Christmas and New Year gifts) should be within reasonable limits relative to local norms and not provided to influence business decisions.

III. Policy for Working with Partners

1. Principles and Criteria for Partnership

    1.1. Partnership relations are built on professional qualification, reputation, and the ability to add value to client projects.

    1.2.  Stenik does not select partners based on commissions, referral schemes, commercial incentives, or other irrelevant factors.

    1.3. The main criterion for selecting a partner is ensuring the quality and sustainability of services provided to the client.

Examples of types of partners Stenik may work with:

• Marketing agencies.
• Suppliers of software solutions or services for online store optimization for search engines and artificial intelligence.
• Suppliers of warehouse, ERP, WMS, and other business software for process and warehouse management improvement.
• Payment systems and financial integrators.
• Courier and logistics companies.
• Suppliers of analytical tools and services to improve client experience.
• Consulting firms providing expert business or technology solutions.
• Other relevant organizations that contribute added value to Stenik’s clients, including subcontractors.

2. Interaction Priorities

    2.1. In case of disputes or misunderstandings between partners, priority is given to the interests of the end client and the objective establishment of facts.

    2.2. Stenik requires communication between partners to be open, timely, and professional.

    2.3. Mutual accusations, unverified claims, or actions undermining trust between parties are not tolerated.

3. Competence and Responsibility Boundaries

    3.1. Each party is responsible only for its own actions, decisions, and performance.

    3.2. Taking on commitments or responsibilities on behalf of a partner without prior written consent is not allowed.

4. Recommendations 

    4.1. If a partner recommended to a client by Stenik fails to meet professional standards or cannot adequately serve the client, Stenik reserves the right to recommend another partner.

    4.2. Such a recommendation is made after objective assessment, documented communication, and analysis of the situation, in order to protect the client’s interests and ensure service continuity.

    4.3. The purpose of these actions is to ensure a quality and effective process, not to sanction or publicly discredit the partner.

IV. Policy for Working with Clients from Competing Businesses and Industry Verticals

For its development, Stenik needs to balance acquired market expertise while adhering to client commitments through information isolation. Accumulated experience in a given industry (business niche) is an asset that allows Stenik to provide higher-quality services, while ensuring that the specific trade secrets and unique developments of each client remain inaccessible to its competitors. 

1. Principles of Independence and Objectivity

    1.1. Stenik may provide services to more than one client operating in identical or similar market segments.

    1.2. Stenik does not assume or provide exclusivity to work solely with a particular organization or group of organizations in a specific industry vertical.

    1.3. Accepting a new client from the same vertical does not constitute a conflict with an existing client, provided that standards for information and organizational independence are maintained.

2. Organizational Separation

    2.1. For clients from similar verticals, Stenik ensures separate project managers if necessary.

    2.2. Projects are managed through independent communication and operational channels to ensure full functional and informational independence.

3. Information Independence and Domain Expertise

    3.1. Stenik does not disclose, analyze, or use specific information, trade data, solutions, or strategies of one client for the benefit of another client from a similar vertical.

    3.2. Accumulated expertise is used solely as general professional experience, without transferring specific business or strategic details between clients.

    3.3. Stenik has the right to collect, analyze, and use aggregated information on specific industry verticals for strategic business decisions. This process is carried out in a way that does not favor a specific client and does not reveal individual trade secrets publicly or to other current or potential counterparties.

To avoid any doubt, Stenik follows the principle that a conflict of interest arises only when access to a client’s specific trade secret could affect impartial performance of obligations to its direct competitor.

4. Intellectual Property

Unless otherwise agreed in a specific client contract, the following general principles apply:

    4.1. Ownership Principles. Intellectual property in software solutions, modules, code, libraries, designs, and methodologies that are part of Stenik’s standard technology or previously accumulated expertise belongs to Stenik.

   4.2. Custom Development. The client has the right to claim ownership of specific, unique components for their business processes only if explicitly agreed in writing and relating to precisely defined parts of the project created according to their specific requirements.

   4.3. Rights over Proposals. All concepts, strategic directions, and solutions proposed by Stenik within the project are considered Stenik’s intellectual property, unless a paid transfer of rights is agreed upon.

V. Final Provisions

1. This code is subject to periodic review and update in view of changes in industry standards, technological practices, and corporate structure.

2. All employees and representatives of Stenik are required to be familiar with this code and apply it strictly.

3. Violations of the code are subject to assessment in accordance with internal procedures and applicable contractual provisions.

4. Stenik encourages its employees, clients, and partners to report any illegal or unethical behavior they witness, without fear of retaliatory measures, biased behavior, or abuse of position.

Last revision: January 7, 2026