Code of Conduct

1. Preamble - 4

2. Cooperation with business partners - 5

‍2.1. Competition - 5
2.1.1. Agreements, cartels and fair competition - 5
2.1.2. Bribery, corruption and money laundering - 5
2.1.2.1. Offering and granting advantages - 5
2.1.2.2. Requesting and accepting advantages - 6
2.1.2.3. Money laundering - 6
2.1.2.4. Political contributions, donations and sponsorship - 7
2.1.3. Patents, industrial property rights - 7
2.2. Selection of business partners - 7
2.3. Trade control regulations - 8
2.3.1. Embargo - 8

3. Best TSL employees - 8

‍‍3.1. Four eyes principle - 8
3.2. Human resources management - 9
3.3. Equal opportunities - 9
3.4. Working conditions - 9
3.5. Avoiding Conflicts of Interest - 9
3.5.1. Outside Employment - 10
3.5.2. Political Activities - 10
3.6. Protection of Assets - 10
3.7. Payments - 10
3.8. Use of Information - 11
3.8.1. Confidentiality - 11
3.8.2. Data protection and information security - 11
3.8.3. Information constituting a trade secret - 11
3.8.4. Correct reporting - 11
3.9. Occupational health and safety, environmental protection and sustainable development - 12
3.10. Quality - 12

4. Implementation of the Code of Conduct - 12

‍4.1. Compliance with regulations - 12
4.2. Consulting - 12
4.3. Complaints and comments - 13
4.4. Implementation of regulations - 13
4.5. General provision - 13

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1 Preamble

Best TSL combines passion for car transportation with a commitment to providing excellentservices, creating reliable connections, and meeting our customers' expectations at every stageof transport. Our vision is to become a trusted partner in the car transportation industry,recognized for our commitment to exceptional service, innovation, and customer satisfaction. Westrive to continually improve our operations, leverage advanced technologies, and foster strategicpartnerships to deliver efficient, secure, and tailored transportation solutions. Our aim is toexceed industry standards, set new benchmarks, and be the preferred choice for customersseeking reliable and cost- effective car transportation services.

The values that guide us in this are absolute readiness for action, reliability and superiority overothers. Our entire organization identifies with these values in order to delight customers, create astrong self-identification, increase the value of the company and its results, and also act in asustainable manner and attach committed employees to the company.

Each of our employees plays a role in building the trust of our customers, owners, collaboratorsand members of society. In order to maintain trust, all employees comply with the law andinternal company regulations (compliance). This Code of Conduct summarizes the mostimportant principles that apply to all employees of Best TSL. The Code of Conduct is alsointended to serve as a guide for employees, helping them to act independently and for the goodof the company.

Each employee must take responsibility for ensuring that their conduct is always consistent withthe Code of Conduct. Our management must also lead by example in this area. Managers mustnot only communicate these principles effectively, but also lead by example and ensure thatemployees comply with these principles. Our management should be the first point of contactwhen employees have questions about this Code of Conduct.

This Code of Conduct and the standards set out in it are part of our risk management system.They are designed to protect Best TSL and each of its employees. The Code describes a minimumlevel of standards that should be extended in individual regions in accordance with stricter legalrequirements and cultural customs. Where separate guidelines exist in addition to the Code ofConduct on specific issues, these will be applied as additional regulations to this Code ofConduct. The current guidelines are available in the "Compliance" section of the Intranet.

This Code of Conduct applies to all employees of Best TSL.

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2 Cooperation with business partners

Best TSL provides customers, suppliers and other business partners with high-quality servicesand cooperates with them while maintaining a high level of professionalism and absolutehonesty. For this reason, correctness, honesty and transparency must form the basis ofcommunication and agreements.

2.1 Competition

Best TSL always respects the principles of fair competition and supports all efforts to maintain afree market and open competition, both nationally and internationally. Therefore, Best TSL willnot perform the contract if it would violate applicable law.

2.1.1 Agreements, cartels and fair competition

All employees are required to comply with the provisions on competition and consumerprotection and combating unfair competition. Formal or informal agreements with competitorsto hinder competition are therefore prohibited. The same applies to joint, secretly agreedpractices. It is therefore not allowed to designate sales territories or share customers withcompetitors, conclude agreements or exchange information with competitors regarding prices,supplier relationships, business arrangements, opportunities, market share, margins, costs,customer data, content of offers or participation in tenders. In the event that Best TSL holds adominant market position, this position may not be used in a manner contrary to the law.

All proposed agreements with competitors must be submitted in advance to the responsible legaldepartment for review and to the CFO for approval.

2.1.2 Bribery, corruption and money laundering

Best TSL will not tolerate bribery, corruption or money laundering in any form. All businessactivities of the company must be conducted in a spirit of honesty and responsibility.

2.1.2.1 Offering and granting advantages

In a competitive market, Best TSL relies on the quality and success of its services. We thereforedo not allow agreements or amendments to agreements that provide impermissible benefits.This applies to direct or indirect benefits to individuals or organizations in connection with theagreement, granting, acceptance, implementation, implementation or payment of contracts. This`applies to all contracts with business partners, their employees and management staff, as well asthird parties. The same applies to benefits related to administrative proceedings.

Prohibited benefits may be in cash, in kind or in any other form. Granting benefits to individualsis also prohibited if the person benefits indirectly. An indirect benefit may take the form of apayment to a family member or a payment (e.g. a donation) made by a third party when theperson benefits from the action, e.g. strengthening their social or political position.

Gifts and invitations are only permitted if their personal, financial or social value is not so great asto influence the recipient's behaviour or decisions and if they do not create a sense of obligationtowards the recipient. When sending an invitation to an event, it must also be ensured that theevent is of a rank and nature customary in business circles and is specifically related to businessactivities. Particularly strict standards must apply to public officials. Cash gifts are strictlyprohibited.

All remuneration (e.g. commissions) paid to third parties (e.g. representatives, brokers,consultants or intermediaries) must be justified and their value must be proportionate to thework they perform. The amount of such remuneration must not suggest that its purpose is tocircumvent the rules on granting impermissible advantages. Agreements with representatives,brokers, consultants or intermediaries, including any amendments to these agreements, must beconcluded in writing and contain an obligation of the parties to the agreement to comply with theabove principles and not to accept or give bribes. These agreements must be approved by theManagement Board of Best TSL before they are signed.

2.1.2.2 Requesting and accepting advantages

Although it is customary to accept gifts of limited size from business partners, this can damage the company's reputation and lead up to a conflict of interest. For this reason, Best TSL employees are strictly prohibited from requesting or accepting personal benefits such as services or improper invitations for themselves, other people or institutions associated with them. An exception are occasional gifts of low value. Cash gifts are strictly prohibited. Other gifts and benefits must be refused and the matter reported to your superior. Otherwise, the rules detailed in the code apply.

2.1.2.3 Money laundering

Best TSL is committed to ensuring compliance with anti-money laundering regulations.

2.1.2.4 Political contributions, donations and sponsorship

Best TSL receives requests for donations from various organizations and institutions. Donationsmust be made in a transparent manner. This means that the recipient and purpose of thedonation must be known. Payments to private bank accounts are prohibited. Payments toorganizations that could damage the reputation of Best TSL are prohibited. The above rules applyto donations. This applies in particular to donations made close to the date of the contract awardor when the donation is related to the subject of the contract. Donations to any political partiesrequire the consent of the Board of Best TSL. In the case of sponsorship, there must be a rationalrelationship between the amount of support and the benefits obtained in return.

2.1.3 Patents, industrial property rights

The company's proprietary technology is constantly being developed, and developing newinventions and improving know-how can be critical to maintaining competitiveness. Therefore, allemployees are prohibited from disclosing new knowledge or company secrets in any form tothird parties. The intellectual property of Best TSL must be protected by employees.

All employees must respect the industrial property rights of third parties. No employee mayacquire third-party secrets or use them in an unauthorized manner. The theft of other parties'intellectual property is strictly prohibited.

Both the introduction into circulation and the acquisition of plagiarized works or works areprohibited. Such cases must be reported to the company management immediately.

2.2 Selection of business partners

Best TSL conducts fair and objective evaluations of all offers/requests submitted by suppliers,subcontractors and customers ("business partners"). The evaluation, decision, award andimplementation of the contract must be transparent and based on strictly professional criteria.Best TSL concludes agreements with business partners in a complete, unambiguous anddocumented manner, including subsequent changes and additions. It is strictly forbidden to favorbusiness partners or to prevent them from acting. Best TSL requires that when selecting businesspartners, they also adhere to the values listed in this Code. Violation of the principles by abusiness partner may lead to the termination of the business relationship.

2.3 Trade control regulations

2.3.1 Embargo

Many countries in which Best TSL operates have enacted trade control laws and regulations thatrestrict or prohibit the cross-border exchange of goods, merchandise, services, technology, andcertain international capital transactions and payments. This may affect the export and import ofgoods, services, and technology related to certain countries. All employees who are involved inthe export or import of goods, services, technology, or international capital transactions andpayments must be familiar with and strictly comply with the relevant trade control laws andregulations.

Sanctions lists are official lists of individuals, groups, or organizations that have been subject toeconomic and/or legal restrictions. Sanctions lists are intended to assist in combatinginternational terrorism on economic grounds by preventing financial transactions and the use ofsources of financing. Therefore, commercial or other business relationships with individuals,companies, groups, or organizations on the sanctions list are prohibited. Best TSL will not enterinto or conduct any commercial or business relationships with individuals, companies, groups, ororganizations on the sanctions list.

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3 Best TSL employees

Productivity and people must go hand in hand to ensure the sustainable success of a company.The economic success of Best TSL depends on the support and cooperation of all its employeesworldwide. For Best TSL, as a service provider, its greatest asset is its employees.

3.1 Four eyes principle

The "four eyes" principle is intended to minimize improper decision-making, both internally andwhen representing the company externally. Unless otherwise prohibited by law, the internal"four eyes" principle always applies in contacts with third parties. Authorization to represent thecompany alone can generally only be granted to a limited extent for specific activities and alwaysrequires prior approval of the Management Board of Best TSL.

3.2 Human resources management

All employees are required to comply with this Code of Conduct, and management in particularmust lead by example. Best TSL cultivates an atmosphere of trust that assumes that managersmust provide sufficient supervision to prevent or stop violations of this Code of Conduct in theirrespective area of responsibility.

3.3 Equal opportunities

Best TSL respects human rights, as well as the rights of minorities and indigenous peoplesaround the world. As a global company, Best TSL works with employees and business partnersrepresenting many different nationalities, cultures and worldviews. Best TSL declares itscommitment to the values of diversity, inclusiveness and equal opportunities and advocates for awork environment in which respect and tolerance prevail, as well as respect for all people.

Best TSL does not tolerate unlawful, unequal treatment (discrimination), harassment orhumiliation. In particular, Best TSL does not tolerate discrimination on the basis of race, ethnicorigin, gender, pregnancy or maternity and paternity, religion or worldview, political opinions,physical or intellectual disability, age or gender identity.

3.4 Working conditions

Recruitment and employment in the company is carried out on the basis of fair and lawfulconditions and in compliance with ethical principles. The company does not hinder the creationof lawful organizations representing the interests of employees. When employing young workers,care is taken to ensure that they are not assigned tasks that exceed their physical and mentalcapabilities or pose a risk due to contact with hazardous substances. All employees are subject tominimum statutory provisions, in particular, it is not permissible to exceed the statutorymaximum daily working hours, as well as statutory provisions on night work, daily rest, annualleave and breaks from work. In the absence of relevant minimum standards or legal provisions,the international standard of the International Labor Organization (ILO) of a maximum of 48hours of work per week and one break of at least 24 hours every seven days should be applied.In addition, in accordance with ILO guidelines, overtime work of up to 12 hours per week ispermitted temporarily and in urgent cases. The health and safety of employees must be takeninto account and protected during work. Best TSL offers employees fair wages and ensuresworking conditions in accordance with all statutory requirements. Best TSL rejects all forms offorced and child labor, as well as all forms of modern slavery and human trafficking.

3.5 Avoiding Conflicts of Interest

Best TSL is committed to ensuring that its employees do not have any conflicts of interest orloyalty related to their work. Such conflicts may arise, for example, in the case of transactions between Best TSL companies and employees or their close relatives. Each such transactionmust be - previously reported to the appropriate manager and requires his approval.

3.5.1 Outside Employment

If an employee intends to take on additional gainful employment that causes a conflict ofinterest, he or she must obtain prior written consent from his or her supervisor, and managersmust obtain written consent from the Management Board and the Human Resources Department.

3.5.2 Political Activities

Best TSL does not participate in activities related to political parties. However, employees are notprohibited from participating in such activities outside of working hours. Best TSL is pleased withthe involvement of its employees in civic and social activities and their participation in social andcharitable initiatives. Employees involved in such initiatives act in their private capacity. Weexpect them to conduct these activities in such a way as to avoid conflicts of interest with theirwork.

3.6 Protection of Assets

Best TSL requires its employees to protect the company's tangible and intangible assets. Theseassets include property, manufacturing equipment and supplies, securities, cash, officeequipment and supplies, information systems and software, as well as patents, trademark rightsand know-how. Violations of law such as fraud, theft, embezzlement and money laundering willbe prosecuted. Issues related to the acceptance of business risk are discussed in the RiskManagement System.

All machines and equipment of Best TSL may only be used for work-related purposes, unlessexpressly permitted for private use. When using the Internet, it is prohibited to download and/ortransmit information that incites racial hatred, glorifies violence or other types of crimes or is ofan offensive nature.

3.7 Payments

In order to guarantee complete transparency, payments made by Best TSL Company should bemade by bank transfer. Cash payments should be avoided whenever possible.

All payments must be made directly to the relevant business partner. No employee may make apayment using a special name,account number or to a third party account (even at the express request of the business partner).

If cash payment is the only option, the employee must document such payment by providing thedetails of the person making the payment, the details of the person who has agreed to thepayment, the name and address of the recipient, the amount, date and title of the payment. Thisdocument must be immediately provided to the Best TSL finance department.

No employee may make, approve or influence a payment of Best TSL for their own benefit or thatof a family member.

3.8 Use of Information

Best TSL expects its employees to exercise appropriate caution when using information.

3.8.1 Confidentiality

All internal company matters that have not been made public must be treated confidentially. Thisalso applies to inventions and know-how. These are essential elements for the long-term successof Best TSL and are a guarantee of the company's future. For this reason, employees may notdisclose information in any form that constitutes a business or company secret to third partieswithout authorization. This also applies after their employment relationship has beenterminated.

3.8.2 Data protection and information security

The global exchange of information is essential for the efficiency of our employees and theoverall success of the company. In addition to the advantages, electronic communication can alsopose risks to data protection and security. Unauthorized persons must never have access toofficial documents and data carriers. Both managers and all employees must take effectiveprotective measures to protect against such risks; this is also an important element of ITmanagement.

Employees who deal with personal data are provided with advice and support from the responsible data protection officer.

3.8.3 Information constituting a trade secret

You may not derive benefits for yourself or others by using information that is a trade secret. Thesame applies to disclosing such information to unauthorized persons.

3.8.4 Correct reporting

When preparing an oral or written report for internal or external use, employees are required toinclude the true state in them. It is prohibited to provide false information in order to manipulatethe content. Best TSL is aware of its financial responsibility and complies with all the principles ofcorrect and audit-compliant accounting.

3.9 Occupational health and safety, environmental protection and sustainable development

Best TSL makes every effort to protect people, animals, life, health and species diversity andhandles all resources (water, air, land, raw materials, energy) and hazardous materialsresponsibly. All employees are obliged to avoid dangers in the workplace, pay attention to animalwelfare, minimize environmental damage (e.g. by using renewable energy, environmentallyfriendly alternatives, biodegradable products) and use available resources economically. Best TSLcomplies with applicable national and international laws and regulations. In addition, Best TSLstrives to improve energy efficiency, reduce environmental impact and implement measures tomitigate climate change. In providing services, Best TSL is guided by the principles of sustainabledevelopment and environmental protection. Best TSL pays special attention to the prohibition ofillegal evictions and illegal takeovers of land, forests and waters as part of their acquisition,construction or other use of land, forests and waters, which are the basis of human existence.The principle of sparing land use must be observed and deforestation must be avoided or, whereappropriate, compensatory measures must be taken.

3.10 Quality

The market success of Best TSL services is closely linked to their quality. The Best TSL Grouprequires a high level of substantive competence, creativity, skills and care from all employees.Best TSL does not tolerate deliberate behavior or negligence that results in a decrease in quality.

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4 Implementation of the Code of Conduct

4.1 Compliance with regulations

Best TSL has established a Compliance Committee responsible for implementing and enforcingthe Code of Conduct. In accordance with the organization of Best TSL's risk management system,the CEO of Best TSL is the contact person for implementing and enforcing the Code of Conduct.

4.2 Consulting

Best TSL provides its employees with information to help them avoid potential breaches of this Code of Conduct. In particular, this includes training on specific topics and selected risk areas. If employees nevertheless have additional questions, they can direct them directly to the company's Chief Financial Officer, the relevant legal or human resources department, or to a member of the Compliance Committee. In addition, Best TSL has set up a help desk to which such questions can be directed. Contact details and all necessary information on compliance can be found in the "Compliance" section on the intranet.Best TSL provides its employees with information to help them avoid potential breaches of thisCode of Conduct. In particular, this includes training on specific topics and selected risk areas. Ifemployees nevertheless have additional questions, they can direct them directly to thecompany's Chief Financial Officer, the relevant legal or human resources department or to amember of the Compliance Committee. In addition, Best TSL has set up a help desk to whichsuch questions can be directed. Contact details and all necessary information on compliance canbe found in the "Compliance" section on the Intranet.

4.3 Complaints and comments

All employees may and have the right to report violations or suspected violations of the Code ofConduct to Best TSL. Reports may also be made anonymously. Appropriate cases may bereported – at the employee’s discretion – to their direct supervisor, the relevant HR officer or theCompany’s President. The necessary contact details will be made available to all employees of theCompany through the appropriate channels.No retaliatory action will be taken against an employee who, based on tangible evidence and ingood faith, sincerely believes that the Code of Conduct has been or may have been violated andwho exercises the right to report such violation to the Company. In each such case, Best TSL willtake the necessary steps to protect the employee from retaliatory action as a result of such areport. To the extent possible and permissible or required by law, Best TSL will keep the identityof the employee who reported a violation or suspected violation of the Code of Conductconfidential. The same applies to the identity of employees who cooperate in the investigation ofa violation or suspected violation of the Code of Conduct.

4.4 Implementation of regulations

Best TSL will issue additional regulations regarding the implementation of selected parts of thisCode of Conduct. These regulations will also address issues of interpretation and establishapproval procedures.This Best TSL Code of Conduct is also available in English. In the event of differences orcontradictions between the individual language versions, the Polish-language version will prevail.

4.5 General provision

Individual countries, areas of operation or relationships with specific business partners may havestricter standards than those described in this Code of Conduct. In such cases, the stricter rulesshall generally apply.