Teamnet considers itself committed to fair, ethical and proper business conduct, and sees its employees as committed to acting in accordance with ethical and moral standards and values. The company sees the code of ethics as one of the foundations on which its organizational culture is based and an important component of its long-term success.  The rules of the code of ethics are an integral part of the employment conditions of each relevant employee in the company.

Ethics

Each of the relevant officers and employees must act with integrity, fairness and caution, and accordingly each employee is required to:

• Act decently and ethically in its activities toward employees, customers, suppliers and others, and to work to maintain organizational discipline.
  Refrain from discrimination, giving preference to relatives, libel, defamation or harassment, including sexual harassment.
• To maintain the confidentiality of the information brought to his attention in the course of his duties and to promote ethical and integrity behavior at work.
• Alert his supervisor in the company to any event that the employee believes violates the company's code of ethics or procedures.

Human dignity, relationships within the organization

Employees and managers should treat each other with respect, politeness and tolerance for each other and with any other party they interact with. Employees must avoid offensive remarks and expressions of lack of appreciation, pass on criticism in a professional, factual and constructive manner where appropriate, and maintain a pleasant working atmosphere in which each employee enjoys being at work.

Conduct and representation of the company

Proper behavior must be observed, respectful representation of the company and an adequate and respectful external appearance.

Prohibition of receiving favors, gifts and bribes and prevention of corruption

Bribery can have many forms: gifts, meals, travel, hospitality, entertainment, employment, anything valuable

The non-bribery and anti-corruption policy includes a number of laws, including:

The laws of the State of Israel, the ratification of the OECD Convention relating to the Fight against Corruption of Foreign Government Officials in International Transactions, a number of laws and regulations of Israeli law including Section 192 of the Penal Code relating to:

Prohibition of bribery in Israel and around the world, various laws and regulations that apply to Teamnet from its various activities around the world regarding non-bribery and anti-corruption.

The employee must refrain from receiving money, money equivalent, service, gift or any other benefit for an action related to his work from parties who have a business relationship with the company or who wish to maintain business relations with the company, except in situations expressly permitted by the company's procedures. An employee who has been offered a benefit under the above circumstances shall immediately report this to his supervisor in the company and/or to the commissioner of the CEO's code of ethics.

Proper work arrangements

In the performance of his duties, each employee must accept the authority of each of his superiors and comply with any procedure established and any instruction duly given to him by a person authorized to do so or that derives from his defined position.  An employee must fulfill his work and the functions assigned to him without delay, faithfully, diligently and to the best of his ability, and he is obliged to do his work with discipline and precision.

Confidentiality

Any information contained in the Company is confidential unless otherwise stated. Employees of the company are obliged to maintain the confidentiality of the information transmitted to them as part of their work in the company. The company's employees may use the said information only for the purposes for which the information was provided to them, and to the extent required only.  This directive applies to all employees of the company even after the termination of their work in the company.

No conflict of interest

An employee of the company must refrain from performing any action that raises a concern of a conflict of interest between his position in the company and his personal affairs, his or her relative's, or another position of his or her relative. If there is a concern of a conflict of interest, the employee must immediately provide any information relating to this to his superior. In addition, an employee must refrain from establishing private business relationships with commercial entities associated with the company and with whom the employee maintains ongoing relations by virtue of his work in the company.

Prohibition on exploitation of a business opportunity of the company and prohibition of competition with the company

An employee will refrain from any action that takes advantage of a business opportunity of the company and / or any action that may constitute competition with the company. The employee must use the information that comes into his possession as part of his work in the company only for the purposes for which the information was transferred to him, and not with the aim of obtaining a benefit for himself and / or any third party.

Protection of company assets

The use of the Company's assets and property will be made solely for business, operational and proper purposes and will be done in accordance with the information security procedures. Employees of the company are required to protect the company's property and assets from theft, loss and causing damage.

Fair Trade

The Company's employees must act fairly and decently in their relationship with third parties, including customers, suppliers and representatives of government agencies.

In all cases, the customer will receive the service, financial payment or financial equivalent as a loan and not as a gift. An employee of this provision is expected to be discharged immediately.

Consulting with the relevant parties in the company

In cases where there is doubt regarding the decision or course of action, the employee must consult with the relevant parties in the company / or with the supervisor.

Use of powers

An employee will not take any undertaking and/or declare on behalf of the company except in accordance with the company's explicit permissions and signature rights.

Compliance with the provisions of the Code of Ethics

Each and every one of the relevant company employees is obliged to comply with the provisions of the Code of Ethics. An employee who believes that there is a concern that the conduct of another employee constitutes a violation of the provisions of the law, regulations or instructions of the authorized bodies, or a concern of a violation of the provisions of the Code of Ethics, is obliged to report this immediately to his supervisor or to the Commissioner of the Code of Ethics. Violation of the provisions of the code of ethics may lead to disciplinary measures taken by the company, reaching the point of dismissal of the employee, and in severe cases even taking criminal proceedings.

Enforcement and disciplinary measures

The prohibitions and obligations set forth in the Code of Ethics do not constitute a complete list of the prohibitions and obligations imposed on employees. Disciplinary measures may be taken against an employee, even if the act or omission he has committed constitutes a violation of a prohibition or duty that the Code of Ethics does not explicitly discuss, provided that the act or omission is within the definition of the disciplinary offenses listed below.

An employee of the company who did one of the following, is guilty of a disciplinary offense:

1. Committed an act or conduct that was detrimental to discipline in the Company;
2. He  has failed to perform his duties as an employee of the Company in accordance with practice, law or regulation, the Code of Ethics or any general or special order issued to him by law, or is negligent in the performance of his duties as indicated;
3. Has acted in a manner unbecoming his or her position as an employee of the Company or has acted in a manner that could harm the Company's reputation or good name;
4. Acted unfairly in the performance of his  duties or in connection therewith;
5. Has obtained his appointment with the company by providing false information or concealing a fact relating to the matter, or by using threats or force or other improper means;
6. Convicted of a dishonorable offense.

General provisions

An employee of the Company who has violated any of the rules of the Code of Ethics shall be summoned to a hearing by the Ethics Committee, chaired by the CEO of the Company as Chairman, the VP of Operations, the Legal Counsel – if required.

The Ethics Committee shall examine the nature of the violation and hold a discussion on its severity and the steps that will be taken against the violating employee. The employee shall be given an opportunity to present his or her claims to the Committee.

Minor and one-time violation – The committee will be entitled to write a written warning filed in the employee's personal file.

Amaterial breach and/or one that caused financial damage to the company and/or damage to the company's reputation and/or a repeat violation by an employee who committed a violation in the past – The committee will be entitled to register a letter of reprimand filed in the employee's personal file.

The letter of reprimand shall have the effect of deferring the employee's promotion for a period of time determined by the Committee from a financial standpoint and/or in such other manner as the Committee deems appropriate and commensurate with the employee's actions.

A serious violation of the rules of the Code of Ethics and/or one that has resulted in significant financial damage to the Company and/or a violation that has exposed the Company to a lawsuit and/or an accumulation of violations for a particular employee shall be considered a serious disciplinary violation and the Committee shall have the right to consider dismissal of the employee and any other sanction.

Signed by

Israel Amar – CEO

Signature (-)

01/07/2022