BizMachine Ethics, Human Rights and Anti-Corruption Policy

Effective Date: August 15, 2026
Approved by: CEO, BizMachine s.r.o.

1. Introduction

At BizMachine, we believe that ethical business conduct and respect for human rights are essential to our long-term success. As a provider of B2B sales intelligence and data services, we recognize our responsibility to uphold labor standards, support fairness and dignity in the workplace, and prevent abuse or exploitation in our operations and supply chain.

This document outlines our policy commitments in areas required by key enterprise clients and international standards.

2. Scope

This policy applies to all BizMachine employees, contractors, and third parties working on our behalf. It is designed to be consistent with:

- The Universal Declaration of Human Rights
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The ILO Core Labor Standards
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The UN Guiding Principles on Business and Human Rights
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Relevant provisions of the UK Modern Slavery Act and EU Charter of Fundamental Rights
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The EU Whistleblower Protection Directive

3. Policy Commitments

3.1 Employee Health and Safety

We maintain a safe and healthy working environment in line with Czech labor laws and modern digital work standards. Although BizMachine operates in a low-physical-risk office environment, we promote:

- Ergonomic working conditions for remote and onsite staff
- Psychological safety and mental well-being
- A culture of open communication around workload, burnout, and health

All employees are encouraged to report unsafe conditions without fear of retaliation.

3.2 Labor Relations & Conditions

BizMachine fosters fair labor practices including:

- Clear employment contracts that meet or exceed statutory requirements
- No forced or bonded labor
- Reasonable flexibility in working hours, appropriate to our industry
- Respectful and lawful termination processes

We are not a unionized workplace but respect the right of employees to associate or organize as permitted by law.

3.3 Non-Discrimination and Workplace Conduct

We do not tolerate any form of unlawful discrimination or harassment. Decisions related to hiring, promotion, compensation, and working conditions are based on merit, qualifications, and business need. We reject discrimination on the basis of:

- Gender, race, ethnicity, age, disability, religion, political belief, sexual orientation, or national origin

We prohibit violence, intimidation, and any form of physical, verbal, sexual, or psychological harassment or abuse. Suspected violations are investigated by the CEO; where the CEO has a conflict of interest, by independent legal counsel. Confirmed violations lead to proportionate consequences, up to and including termination of employment or contract, in line with the Czech Labour Code where it applies.

3.4 Fundamental Human Rights

We support the protection of individual rights and freedoms. Employees are treated with dignity and respect and have the right to:

- Freedom of thought, expression, and belief
- Fair and transparent employment terms
- Reasonable privacy in communication and personal data handling

3.5 Child and Forced Labor

BizMachine prohibits:

- The use of child labor (as defined by local and ILO standards)
- Any form of forced, indentured, or trafficked labor
- The retention of identity documents, coercive practices, or financial bondage

All work at BizMachine is freely chosen and conducted under fair terms.

3.6 Anti-Bribery and Corruption

BizMachine has zero tolerance for bribery, kickbacks, or any form of corrupt activity.

- We do not offer, promise, authorize, or accept any bribe or improper payment to gain a business advantage.
- Gifts and hospitality must be reasonable, infrequent, and aligned with local laws and company policy.
- Facilitation payments are strictly prohibited.

We comply with the anti-corruption laws of all jurisdictions in which we operate. This includes the related EU and national legislation as well as the UK Bribery Act.

3.7 Ethical Conduct and Business Integrity

All team members are expected to act with:

- Integrity: We are honest, transparent, and accountable.
- Fair Dealing: We compete fairly and do not engage in deceptive practices.
- Confidentiality: We respect the privacy of clients, employees, and business partners.
- Avoidance of Conflicts: We disclose any actual or potential conflicts of interest.

Employees must avoid behavior that could damage the company's reputation, even if it does not break the law.

3.8 Sanctions and Anti-Money Laundering

BizMachine complies with applicable economic sanctions and anti-money-laundering (AML) laws in the jurisdictions where it operates, including EU and UN sanctions regimes and any other sanctions applicable to a given transaction.

- We do not knowingly provide services to, accept payment from, or otherwise transact with persons, entities, or countries subject to sanctions.
- Where there is reason to believe a counterparty may be subject to sanctions, we check official lists before proceeding.
- We accept and make payments only through legitimate banking channels in the counterparty's name. We do not handle third-party funds, accept cash, or use company accounts to disguise the origin of funds.
- If we identify or reasonably suspect a sanctions or money-laundering concern, we pause the transaction and escalate to the CEO before proceeding.

4. Reporting & Whistleblower Protection

We encourage internal reporting of any suspected violations of this policy. Retaliation against whistleblowers is strictly prohibited. Reports may be directed to the CEO or an independent legal counsel.

Reports may also be made anonymously, by post to BizMachine s.r.o., Pernerova 697/35, Karlín, 186 00 Praha 8, with the envelope marked "Confidential - to the CEO". Anonymous reports are handled with the same care as named reports.

5. Implementation and Oversight

- Responsibility: The CEO and leadership team oversee this policy.
- Training: New hires are introduced to this policy during onboarding.
- Review: The policy is reviewed annually or upon material changes.
- Reporting: Any violations or concerns can be reported confidentially or anonymously to the CEO or legal counsel.

6. Conclusion

BizMachine is committed to ethical conduct, responsible labor practices, and human rights. This policy reflects our values and will evolve as our company grows and expectations change.

Contact: Martin Ondáš CEO, BizMachine martin.ondas@bizmachine.com