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Good practices

 

Content of the ruleApplying the YES/NO principleCompany's comment
1. In addition to fulfilling the information obligations specified in the relevant provisions of law and regulations of the alternative trading system, the company shall publish on its website, in a readable form and in a separate place, and immediately update:
1.1. basic information about the company, a description of its activities, as well as information about its subsidiaries and the scope of their activities; Roof 
1.2. a brief description of the business model and the adopted business strategy, including the ESG areas included in the strategy; RoofWith the exception of the ESG areas included in the strategy due to the lack of a requirement for the Company to adopt an ESG policy.
1.3. the date of introduction of the company's shares to the alternative trading system on the NewConnect market (debut date) and all previous names of the company, if the company's name has changed since the debut date; Roof
1.4. the composition of the company's management and supervisory boards and professional CVs of the members of these bodies; Roof
1.5. information about each member of the supervisory board meeting the independence criteria referred to in point 3, including actual and significant connections with a shareholder holding shares representing not less than 5% of the total number of votes at the company's general meeting; Roof
1.6. corporate documents of the company; Roof 
1.7. information materials made available to stakeholders about the company, the adopted strategy and its implementation; Roof 
1.8. selected financial data and published forecasts; Roof
1.9. current shareholding structure, indicating shareholders holding at least 5% of the total number of votes in the company; Roof 
1.10/XNUMX company information documents, prospectuses with supplements and other documents constituting the basis for a public offering of shares or the introduction of shares to an alternative trading system; Roof 
1.11/5. current and periodic reports published by the company over the last XNUMX years; Roof 
1.12/XNUMX. calendar of publication of financial reports, publicly available meetings with investors, analysts and the media, and other events important from the point of view of investors; Roof 
1.13/XNUMX. a section of questions asked to the company by both shareholders and non-shareholders, along with answers provided by the company;  
1.14/XNUMX. information about the entity with which the company signed an agreement to provide services of an Authorized Advisor; Roof 
1.15. a statement published in the last annual report on the company's application of the corporate governance principles contained in this document; Roof 
1.16/XNUMX. contact details of persons responsible for communication with investors in the company, including a dedicated e-mail address or telephone number. Roof 
2. The scope of professional activity of members of the management board or supervisory board should ensure efficient and effective management of the company and effective supervision in the implementation of strategic goals and achieved results. Roof 
3. At least two members of the supervisory board should meet the independence criteria set out in the Act of 11 May 2017 on statutory auditors, audit firms and public supervision, and demonstrate the lack of actual and significant connections with a shareholder holding at least 5% of the total number of votes in the company. Roof 
4. A member of the management board or supervisory board should avoid taking up professional or non-professional activities that could lead to a conflict of interest or negatively affect his reputation as a member of the company's governing body. A member of the management board or supervisory board shall immediately inform the other members of the relevant body of the company about any conflict of interest or the possibility of its occurrence and shall not participate in the discussion or vote on a resolution on a matter in which a conflict of interest may arise in relation to him or her. Roof 
5. The company provides solutions in the field of internal control, risk management, including the risk related to the preparation of financial statements and supervision of compliance with the law, as well as the internal audit function. The solutions adopted by the company in this respect should be adapted to the size of the company and the type and scale of its business, as well as to the level of risk associated with its operation. Roof 
6. The supervisory board, within its powers, monitors the process of preparing financial statements. For this purpose, the supervisory board at least familiarizes itself with the schedule of work necessary to prepare the financial statements in accordance with applicable regulations and discusses this schedule with the company's management board, as well as maintains communication with the statutory auditor selected to audit the financial statements. Roof 
7. The supervisory board reads the agenda of the general meeting and gives opinions on the materials to be presented by the company to the general meeting. Roof 
8. When convening a general meeting, the company's management board selects the date, place and form of the general meeting so as to enable as many shareholders as possible to participate in the meeting. Roof 
9. If the management board receives information about convening a general meeting pursuant to Art. 399 § 2 - 4 of the Commercial Companies Code, the management board shall immediately carry out the activities to which it is obliged in connection with the organization and conduct of the general meeting. This principle also applies in the event of convening a general meeting on the basis of an authorization issued by the registry court in accordance with Art. 400 § 3 of the Commercial Companies Code. Roof 
10. Members of the management board and supervisory board participate in the general meeting, either at the meeting place or via means of two-way electronic communication in real time, in a composition enabling them to provide substantive answers to questions asked during the general meeting. Roof 
11. No shareholder should be privileged over other shareholders in terms of transactions concluded by the company with shareholders or entities associated with them. Roof 
12. Before the company concludes a significant agreement with a shareholder holding at least 5% of the total number of votes in the company or an entity related to him, the management board requests the supervisory board's consent to such a transaction. Before giving consent, the supervisory board assesses the impact of such a transaction on the company's interests, ensuring that the interests of various groups of shareholders do not outweigh the company's interests. The above obligation does not apply to typical transactions and transactions concluded on market terms as part of the company's operating activities with entities from the company's capital group that are subject to consolidation. If the decision on the conclusion of a material agreement by the company with a related entity is made by the general meeting, before making such a decision, the company provides all shareholders with access to the information necessary to assess the impact of this transaction on the company's interests. Roof 
13. If an investor requests information about the company, the company shall respond no later than within 14 days. Roof 
14. If the issuer violates the information obligation specified in Annex No. 3 to the Regulations of the Alternative Trading System, the issuer should immediately publish, in the manner appropriate for submitting current reports on the NewConnect market, information explaining the situation. Roof