Business Code of Conduct & Ethics
Crown Metals CZ
In Louka u Litvínova, April 21, 2026
Crown Metals CZ, s.r.o. (the “Company”) is a Czech-based enterprise specializing in the research and development, recycling, and production of magnesium alloys since 1998. Our mission is to provide excellent quality products and services and to focus on continuous improvement of new materials in order to meet our customers’ expectations. We work closely with our suppliers and customers and focus on continuous innovative solutions to protect human health and the environment.
The Company is committed to conducting its business with honesty and integrity, including the ethical handling of conflicts and apparent conflicts of interest, and in compliance with applicable laws and regulations.
Therefore, the Company has adopted this Code of Ethics and Business Conduct (the “Code”) to serve as a guide for appropriate conduct and to set out acceptable behavior for persons associated with the Company in conducting the Company’s business and acting on its behalf.
All directors, officers, and employees (collectively, “Company Personnel”) are required to be familiar with the Code, comply with its provisions, and report any suspected violations as described below in Section 8 (Reporting and Enforcement). All Company Personnel are expected to comply with all applicable laws and regulations in the Czech Republic and any other relevant jurisdictions in which the Company conducts its business. If a provision of the Code conflicts with applicable law or regulations, those laws or regulations shall prevail.
The Code is intended to be read together with other internal policies and procedures of the Company. In the event of any inconsistency between the Code and such policies, the stricter standard shall apply unless prohibited by applicable law.
The Company prohibits retaliation against any person who reports misconduct or violations of this Code in good faith. All reports will be treated confidentially to the extent permitted by law and investigated appropriately.
The Company also expects all Company Personnel to comply with applicable export control, sanctions, and anti-boycott laws where relevant to its operations.
Code of Conduct
1.2. Company Personnel must act with integrity and observe high ethical standards of business in the course of performing their job. Directors and officers are expected to promote ethical behavior and help foster a culture of ethics and compliance.
1.3. With our customers, we endeavor to build partnerships that operate in a manner consistent with our core values, including ethical, social, and environmental aspects. Satisfaction of our customers’ needs and expectations is our priority, and we avoid any actions that could undermine our trustworthiness in their eyes.
1.4. We apply the same ethical, social, and environmental standards to our business partners as we do to ourselves. With our business partners, we establish and develop honest and proper relationships based on mutual trust and adherence to contractual obligations. We prefer long-term business relationships and enter into relationships only with those adhering to applicable laws and using financial resources not derived from illegal activities.
1.5. We recognize that the well-being of our Company Personnel is essential to meeting our standards and delivering the highest quality products to our customers. Therefore, we create a safe working environment built on trust and mutual respect, recognizing and respecting all legitimate rights of our employees. We care about the health of our Company Personnel and strictly comply with applicable laws governing a safe and injury-free workplace. Our Company Personnel are provided with fair and competitive wages, and their working hours do not exceed the maximum set out by labor laws applicable in the Czech Republic.
1.6. We recognize and respect the human rights of all individuals as set forth in the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work. Therefore, we do not engage in any form of forced, involuntary, or prison labor. We do not use child labor and do not employ any persons who have not completed their compulsory schooling. All full-time Company Personnel must be at least 18 years of age. Persons over the age of 15 may be employed only on a part-time basis, strictly in accordance with the limitations set out by labor laws applicable in the Czech Republic.
1.7. We are committed to conducting business in an environmentally sustainable manner and to going beyond mere compliance with applicable environmental laws and regulations. We have introduced waste-free production processes and continue to follow best available techniques when doing so.
2.1. Conflicts of interest should be avoided unless specifically authorized under the conditions set out in this Code.
2.2. A conflict of interest occurs when an individual’s private interest (or the interest of a member of their immediate family) interferes, or appears to interfere with the interests of the Company. A conflict of interest arises when Company Personnel (or a member of their immediate family) take action or have interests that make it difficult to perform their duties for the Company objectively and effectively. Conflicts of interest also arise when Company Personnel (or a member of their immediate family) receive improper personal benefits as a result of their position with the Company.
2.3. Company Personnel working with customers, business partners, competitors, or any other persons cooperating with the Company shall always act in the best interest of the Company and exclude considerations of personal preference or benefits.
2.4. Whether or not a conflict of interest exists or will exist is not always. Employees who have questions about a potential conflict of interest, or who become aware of an actual or potential conflict, should discuss the matter with, and seek a determination and prior authorization or approval from, their line manager or one of the Company’s executive directors. A line manager may not authorize or approve conflict of interest matters, or determine whether a conflict of interest exists, without first providing one of the Company’s executive directors with a written description of the activity and obtaining that executive director’s written approval. If the line manager is involved in the conflict, the employee shall discuss this matter directly with one of the Company’s executive directors.
2.5. Directors and officers must seek determinations and prior authorizations or approvals of potential conflicts of interest exclusively from the General Meeting of the Company.
3.1. Company Personnel must comply with all applicable laws, rules, and regulations of the Czech Republic and any other jurisdictions where the Company operates.
3.2. It is important for Company Personnel to be familiar enough with applicable laws, rules and regulations to know when to seek advice. Questions about compliance shall be addressed to one of the Company’s executive directors, who will contact counsel in accordance with the relevant business unit’s normal practices and requirements for engaging outside counsel.
3.3. Company Personnel are required to comply with statutory obligations on anti-corruption and anti-bribery in the Czech Republic, as well as in other states where the Company directly or indirectly operates. We do not tolerate corruption, bribery, or fraud in any form. No Company Personnel shall directly or indirectly offer, make, promise, or transfer anything of value to obtain or retain a business advantage from a public official, or to influence any decision by such public official in their official capacity. Company Personnel are required to immediately report any actual or suspected corruption, bribery, or fraud to one of the Company’s executive directors.
3.4. Company Personnel must comply with all applicable laws on the prohibition and prevention of money laundering and terrorist financing (AML). The Company and Company Personnel are strictly prohibited from attempting to conceal or “launder” illegally obtained funds or to make the source of such funds appear legitimate. To avoid engaging in money laundering, all Company Personnel must remain alert to and immediately report any irregular or unusual methods of payment, refund requests, or other suspicious transactions to one of the Company’s executive directors.
3.5. As we deliver our products and provide services abroad, the Company complies with applicable export control laws in the Czech Republic and in destination countries. The Company avoids entering into business relationships in jurisdictions, or with entities that are subject to sanctions, embargoes, or other export restrictions. The same applies to compliance with anti-boycott regulations. Employees involved in the export or import of products and services are required to ensure that the Company complies with applicable laws and regulations and must provide accurate and truthful information to customs and other relevant authorities.
3.6. We conduct business honestly and in a fair manner, complying with applicable competition and antitrust laws. Our business is competitive, but we treat our competitors, suppliers, and customers appropriately and fairly, as violations of competition and antitrust laws will result in severe penalties for the Company.
4.1. The Company’s periodic reports, financial statements, and other documents filed with the commercial register or other national bodies must comply with all applicable laws, regulations, and rules. All payments made or received by the Company must be accurately recorded in the Company’s books and records.
4.2. All Company Personnel who contribute to the preparation or verification of the Company’s financial statements and other financial information must ensure that the Company’s books, records, and accounts are accurately maintained. All Company Personnel must cooperate fully with employees of the financial department, as well as with the Company’s independent auditors and counsel.
4.3. Company Personnel involved in the Company’s disclosure process must:
a) comply with the Company’s disclosure controls and procedures and its internal control over financial reporting; and
b) take all necessary steps to ensure that all filings with the commercial register and other national bodies, and all other public communications regarding the financial and business condition of the Company, provide full, fair, accurate, timely, and understandable disclosure.
5.1. All Company Personnel must protect the Company’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on the Company’s profitability.
5.2. All Company assets must only be used for legitimate business purposes, although incidental personal use may be permitted under the relevant business unit’s rules. Any suspected incident of fraud or theft must be reported immediately for investigation.
5.3. The obligation to protect Company assets extends to the Company’s proprietary information. Proprietary information includes intellectual property such as trade secrets, patents, trademarks, and copyrights, as well as business and marketing plans, engineering and manufacturing ideas, designs, databases, records, and any non-public financial data or reports. Unauthorized use or distribution of this information is prohibited and may also be illegal, resulting in civil or criminal penalties.
6.1. Company Personnel shall maintain the confidentiality of information entrusted to them by the Company or by its customers, suppliers, or partners, except when disclosure is expressly authorized or legally required. “Confidential Information” means all non-public information (regardless of its source) that might be of use to the Company’s competitors or harmful to the Company or its customers, suppliers, or partners if disclosed.
6.2. Confidential Information must be protected, and reasonable efforts must be taken to avoid inadvertent disclosure. Discussions related to Confidential Information must be held in private locations where they cannot be overheard, and documents shall be kept out of public view and secured whenever not in use. Company Personnel shall not give unauthorized persons access to e-mail messages or computer directories and shall not store Confidential Information in electronic form in directories, databases, or other storage mechanisms (e.g., internet “cloud” storage) that are publicly accessible.
The Company complies with applicable laws on privacy and data protection, including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). The Company collects and retains personal data only to the minimum extent necessary and for proper purposes as required by applicable laws and the Company’s operational needs. We take all necessary steps to safeguard such data and maintain its confidentiality as required by applicable laws. Company Personnel must respect the rights of data subjects under applicable law, including rights of access, rectification, restriction, and erasure where applicable. Any suspected or actual personal data breach must be reported immediately in accordance with the Company’s internal procedures.
8.1. As a general rule, any alleged breach of applicable laws, this Code, or other group internal rules shall be reported to one of the Company’s executive directors.
8.2. In the case of an alleged breach involving any employee or director where the Company’s executive directors determines that a breach of this Code has occurred, the executive director shall have discretion to take any such preventive or disciplinary action as they deem appropriate. This includes (but is not limited to) reassignment, demotion, dismissal, and, in the event of criminal conduct or other serious legal violations, notification to the appropriate governmental authorities.
8.3. In the case of an alleged breach involving the Company’s executive directors, the person who has such suspicion must inform the General [Meeting] of the Company. If the General Meeting of the Company determines that a breach of this Code has occurred, it shall take such preventive or disciplinary action as it deems appropriate. This includes (but is not limited to) reassignment, demotion, dismissal, and, in the event of criminal conduct or other serious violations of the law, notification of the appropriate governmental authorities.
8.4. All Company Personnel are expected to fully cooperate with in internal investigation of misconduct.
9.1. Waivers or exceptions to this Code may be granted, but only in advance and in exceptional circumstances.
9.2. Waivers for employees and directors may be granted by a Company executive directors of the Company.
9.3. Waivers for a Company executive director may be granted by the General Meeting of the Company.
The Company does not tolerate acts of retaliation against any Company Personnel who make a good faith report of any known or suspected acts of misconduct or other breaches of this Code. However, it is a breach of this Code to knowingly make a false accusation, act in bad faith when reporting, lie to those investigating a breach, or interfere with or refuse to cooperate with an investigation under this Code. Good faith reporting does not mean that you must be correct in raising a concern; it means you must honestly believe that you are providing accurate information.
Our purchase terms govern all transactions with suppliers and partners. All purchases are conducted in accordance with our ethical standards and legal requirements. Suppliers must comply with applicable environmental, labor, and safety regulations.
All business relationships with the Company are subject to our standard terms and conditions.
The Company encourages all employees, suppliers, and partners to report any suspected violations of this Code or any applicable law. Reports may be made confidentially and without fear of retaliation.
The Company will investigate all reports promptly and take appropriate action if violations are confirmed after investigation.
Crown Metals CZ s.r.o. | Nadrazni 214, Louka u Litvinova, 435 33 Czech Republic
©2026 Crown Metals CZ