Ethical Code

Introduction
BlueGen Ltd.’s (referred to as “the Company”) Ethical Code serves as a guiding framework for all Company’s employees and officers. This Ethical Code aims to prevent violations of the law, ensure ethical conduct, strengthen internal and external relationships and uphold the Company’s reputation.

Compliance and Application
This Ethical Code complements existing laws and regulations. All employees, officers, and directors are bound by this Ethical Code, which forms an integral part of their employment terms. Violations of this Ethical Code may result in disciplinary actions, including termination.

Compliance with Laws
The Company and its employees are committed to conducting lawful business activities, adhering to relevant laws, regulations and instructions in all jurisdictions where the Company operates. Employees must ensure their actions align with these legal requirements.

Confidentiality and Intellectual Property
Employees are required to safeguard the Company’s confidential information, intellectual property and trade secrets. This includes protecting proprietary data, patents, trademarks, and business relationships. Any information not publicly available is considered a trade secret and must be treated as confidential.

Securities Transactions and Inside Information
Directors, officers, and employees are prohibited from trading Generation Capital Ltd.’s securities while in possession of inside information and/or providing such information to third parties. Compliance with trading regulations and responsible disclosure is essential to maintain fair trade practices.

Reporting
Employees must promptly report material events and ensure accurate and timely disclosure in periodic and quarterly reports. Timely reporting is vital to maintain transparency and regulatory compliance.

Conflict of Interests
Employees must prioritize the Company’s interests over personal gain and avoid situations where personal interests conflict with those of the Company. Any potential conflicts of interest must be disclosed and managed appropriately.

Business Opportunities and Competition
Employees are prohibited from personally benefiting from business opportunities related to the Company. Employees must avoid competing with the Company, both during and after employment.

Prohibition on Gifts and Benefits
Employees must refrain from giving or receiving gifts or benefits that exceed customary tokens of appreciation. Excessive gifts could compromise impartiality and create conflicts of interest. This applies to transactions with a foreign or domestic government official, including municipalities, agent, associate, company or contractor.

Asset Protection
Employees must responsibly use and protect the Company’s assets, including equipment, materials and products. Misuse or theft of Company’s assets is prohibited.

Records and Documentation
Accurate and transparent record-keeping is essential. All records, financial statements, and accounts must be maintained accurately and in accordance with legal and regulatory standards.

Respect, Dignity, and Harassment
Employees are expected to treat others with respect, avoiding discrimination, harassment, and any hostile behaviors. A safe and inclusive workplace environment must be maintained, free from any form of harassment.

Safety and Protection
Employees must prioritize safety, protecting human lives and property. Adherence to safety protocols and responsible actions are essential to prevent accidents and injuries.

Professional Conduct
Fair, honest and professional cooperation among employees is crucial. Abusing authority or status is prohibited.

Environmental Responsibility
The Company and its employees are committed to environmental protection and sustainable practices. Responsible resource use and reducing environmental impact are priorities.

Customer Service
Fair, truthful, and professional interactions with customers are required. Accurate representation of products and services is essential for building trust.

Consultation
Employees are encouraged to consult superiors or the Ethical Code Officer when unsure about proper courses of action. A set of questions can guide decision-making:

Ethical Code Officer
Adv. Keren Cohen Saad, the General Counsel, serves as the Ethical Code officer.
Employees can seek guidance and advice on ethical conduct from the Ethical Code Officer.

Reporting Violations
Employees and officers must report any violations of laws, the Ethical Code, or irregularities in the Company’s conduct. Reports can be submitted to the Ethical Code Officer directly or anonymously through designated channels.

Email: kerencs@bluegencorp.com
Phone: +972-54-2466696
Postal mail: HaTahana 1. Kfar Saba 4453001
Adv. Keren Cohen Saad

Updated on December 30, 2024