Compliance and Business Ethics

The Code of Conduct is a fundamental document that sets out the norms of internal corporate behavior, rules for interaction of VF employees with clients, business partners, government agencies and external audiences. The Code is mandatory for all VF employees, regardless of their position, as well as for any third party, acts on behalf of or in the interests of the VF, subject to the signing of the corresponding commitment.

The Code of Conduct.pdf

Supplier Code of Business Conduct.pdf

The Code, in particular, guarantees:

• Freedom and protection from discrimination. Recruitment, advanced training, promotion, disciplinary measures are carried out regardless of gender, race, nationality, language, origin, age, place of residence, religion, political beliefs, affiliation or non-affiliation with public associations, social and official status of the employee
• Safe working conditions.
• The company's desire to reduce the impact of its activities on the environment.
• Compliance with all government regulations in the employer-employee relationship.
• Fair and impartial resolution of all controversial issues by the company's management.

The Code specifically prohibits:

• The use of child and forced labor.
• Use of official position for personal interests.
• Actions that do not comply with the anti-corruption legislation of Ukraine, the US Foreign Corrupt Practices Act (1977), the UK Bribery Act, as well as the internal anti-corruption policy of PJSC "VF Ukraine".
• Actions contrary to customs and tax laws.

To ensure the compliance of VF activities with the requirements of the current anti-corruption legislation, to identify, assess, analyze and minimize corruption risks, the Company creates a compliance system. The Anti-Corruption Compliance Policy was approved, in accordance with which each employee of the VF must act, as well as any third party acts on behalf of or in the interests of the VF, subject to the signing of the corresponding commitment.

The policy was put into effect by Order OD/P-268.0 from 24.12.2020.

VF_UKR_Anticor.policy.pdf

If there is information about a violation of the Code of Conduct or manifestations of corruption involving representatives of the VF, both employees and our partners can contact the hotline that operates in our Company – hotline@vodafone.ua. More information is available on the website under the "Anti-illegal actions program".

The program was created as part of the initiatives, measures and actions carried out by the management of the Company and the Internal Control and Audit Group in order to further improve the efficiency of the processes of preventing and detecting possible facts of fraud, abuse and other violations in the following areas:

• non-compliance with legislation (including violations of labor and applicable anti-corruption laws);
• cases of possible conflict of interest;
• non-observance of the Code of Conduct of PJSC "VF Ukraine";
• any fraud or willful error in the maintenance of the Company's financial and accounting records, as well as willful misapplication of generally accepted accounting principles;
• significant violations of the requirements for accounting, tax accounting and the preparation of relevant reporting;
• cases of falsification of financial or accounting statements for the participation of the Company;
• or other illegal actions.

PJSC "VF UKRAINE", as a subsidiary of the company, whose securities are registered by the US Securities and Exchange Commission, the Sarbanes-Oxley Act and existing rules are subject to increased requirements for effective corporate governance.
In particular, the company must implement a program of measures to enable all employees of the company and counterparties to report known facts or suspicions of fraud, abuse and other illegal actions in the above areas that lead to distortion in reporting, violations of laws and requirements, misuse or inappropriate use of the company's assets and property, violation of internal control requirements, or other actions that cause or cause significant losses to the company.
Available channels for communicating such facts should provide a reliable confidentiality regime for the identity of the sender. The Company's management does not have the right to interfere with the operation of such channels or try to establish the identity of anonymous senders, unless there is a reason for this as required by law.
The specified messaging channels should not be used for:

• Dissemination of deliberately false and information defaming honor and dignity (and have other signs of slander, which is determined by law).
• Information of personal accounts, achievement of personal goals, receipt of benefits through the transmission of messages within the framework of the program of events.
• Other goals of senders that do not coincide with the goals of the Company in the field of preventing and combating the risks and facts of fraud, abuse and other illegal actions.
• Responsible persons, based on the results of the initial check, reserve the right to disregard messages and information regarding the goals and objectives of this Program, as well as to use measures available within the framework of the law before messages and information transmitted with clearly unfair and illegal intentions.

This program is intended for all employees of the company, as well as for third parties who directly or indirectly own the relevant information and wish to communicate it.

To provide opportunities to everyone to send a message to any of the methods available for different groups of senders, the company's management have provided appropriate information channels.

Channels and ways of sending that protect your anonymity (optional):

• By E-mail to: hotline@vodafone.ua
  Use any public mailbox on a public e-mail servers, through Internet cafes or any other places that do not require mandatory'mandatory registration of users or not use algorithms your identity; do not sign your message.
• By letter addressed directly to:
  Head of compliance PJSC "VF UKRAINE", address: PJSC "VF UKRAINE", st. Leipzigska, 15,. Kyiv, 01601, marked "Program message — PERSONAL"
  The representative of the company's management, at the address: PJSC "VF UKRAINE", st. Leipzigska, 15 ,. Kiev, 01601, marked "Message program - PERSONAL"

Don't sign the letter with your name; do not include details in it that may help define your identity; do not send a letter through official mail, if this can lead to the identification of the sender, use public places and mail to send correspondence.

To send messages to the company's management, you can use the corporate phone book or contact information available on the company's website www.vodafone.ua

Channels and ways to send messages without providing your anonymity:

You can use any of the above channels to send the message, but your name or other means of identification (of your choice)

• Sending email via a service like e-mail, or via Internet mail with the sender's name, sending a letter with your signature, etc.
• Personally or on your behalf to convey information

The processing of messages received through channels that protect the anonymity of senders is carried out by a strictly authorized employee of the company or an external party in accordance with the provisions of this Program. In accordance with the requirements of the American Sarbanes-Oxley Act, the company's management does not have the right to take measures aimed at disclosing the anonymity of the initiators of messages sent as part of the goals and objectives of this program and do not violate the law, as well as to take sanctions and measures against such senders "in revenge "for submitting messages. Compliance with these requirements is monitored directly by the company's management.

For the most efficient processing of incoming messages, information and ensuring the effectiveness of investigations, the following message format and structure is recommended, regardless of the mode of transmission:

• Type of question - please, if possible, indicate the subject of the question.
• Short title - please include a short title of the questions in your message for easier handling.
• Author (optional) - the source of this information, possibly indicate "employee of the XXX division of the company" or "employee".
• The division of the company in question.
• To lay out the essence of the issue in an understandable form and specific, essential facts are known.
• Contacts for feedback with the sender (optional).

Why and who needs the Program, why are the existing rules and measures not enough?

Requirements of the Sarbanes-Oxley Act (or the "Sarbanes-Oxley Act of 2002", passed by the US Congress in 2002 following numerous corporate scandals that exposed fraud, abuse and violations that led to the largest bankruptcies of large companies in US history) also apply to our company as a subsidiary of a company whose securities are registered with the US Securities and Exchange Commission.

These requirements oblige the company's management to take measures to enable all employees of the company and other interested parties to send messages (if desired, anonymously). Thus, the existing mechanism must ensure that the top management of the company is informed about the facts or suspicions of fraud, abuse and other illegal actions that may threaten the strategic goals, reputation and image of the company, before it becomes impossible to prevent. As corporate practice and the experience of countries with emerging economies show, this mechanism is an effective addition to the usual methods of combating illegal actions by management, not all of which can prevent serious risks.

If you are an employee of a company or its counterparty (supplier, client, partner, shareholder ...), you probably hope and have the right to count on fair, mutually beneficial cooperation and attitude towards you, compliance by the company and its employees with all requirements of laws, regulations, rules and obligations.

The company's management is making every effort to ensure this, however, in the real life of large companies, dynamically developing, objectively there are certain conditions, prerequisites and circumstances leading, at least, to the presence of risks of fraud, abuse and other illegal actions.
Not all of these factors and circumstances can be effectively resisted by the company's existing protective measures from within the processes in which such facts are possible. It is for an additional guarantee of their detection and prevention that these measures serve. The more the company is protected from such risks (including with your help), the more your interests are protected.

How will the anonymity of senders be protected?

The proposed methods of sending messages through the specified confidential channels and the possible measures to preserve anonymity (if the senders wish) provide a reasonably reasonable guarantee of maintaining anonymity.
In addition, the company's management undertakes not to take measures aimed at violating the anonymity of senders.