Ethics Code

ACTIVE CAPITAL, Ltd.

ACTIVE CAPITAL, Ltd. (below as “the Company”) provides its services through the medium of qualified and professionally trained consultants.

The Company efforts to anticipate the requirements of investor and adapt provided service to his needs, knowledge and experience.

The Company is obliged to acquaint investor with all the essentials of mutual cooperation, especially with a price list of provided services, terms of trading and further to inform him about all the changes immediately.

The approach during the investment realization is always consulted with the investor with regard to his knowledge and experience with investments on capital markets. Optimal way of providing service is selected according to these individual conditions.

The Company ensures and controls keeping and raising the level of expertise of all the consultants in the area of legislative regulations relating to business on capital markets, consumer protection, personal data protection and others. All the consultants provide entire necessary coordination to supervisory bodies, profession organizations and other competent bodies.

The Company does not disadvantage individual customers in favour of others, it proceeds according to concluded agreements, it keeps the price list and regularly and truly informs about risks and advantages of appropriate transactions.

The Company does not implement such procedures that would motivate employees or cooperating consultants to give investor incomplete, misleading or incorrect information.

The managers of the Company carry out such arrangements so that cooperating consultants keep valid laws, rules and notices and prevent from their infringement.

Employees of the Company and cooperating consultants use such source materials that are suitable and gained by exploring appropriate resources so that they could serve to negotiation with investor.

The Company and its consultants are obliged to prioritize interests of the clients to their own interests. They are bound to keep a professional care.

The Company and its consultants are obliged to keep in secret confidential information of current and potential clients.

The Company and its consultants are not entitled to give assurance or guarantees concerning expected or possible yields from investments, both in oral and written form.

The Company and its consultants do not promote investment services untruly or by misleading way and they do not conceal any important circumstances of mutual cooperation.

Within the framework of possibilities of the particular deal the Company and its consultants give investor sufficient time for understanding and evaluating of information given to them.

The Company and its consultants keep appropriate attention so that they do not bother potential client during acquiring information.

ACTIVE CAPITAL, Ltd.