VIGOLIN JSC's statement on impartiality and confidentiality.

Ensuring impartiality and confidentiality of information related to clients is a prerequisite to ensure confidence in the company's professional activities.

VIGOLIN JSC defines the basic provisions on impartiality and confidentiality of the company as follows:

• Not to participate in the performance of activities that call into question the impartiality of the company,
• Ensure impartiality in decision-making during the internal audit of the of the management system and management review,
• Act independently of any external or internal, as well as commercial, financial, administrative pressures that could adversely affect the quality of the company's performance,
• Comply with the obligations of independence of remuneration of employees,
• Analyze impartiality risks and, if any are detected, take action to eliminate and minimize them,
• Maintain confidentiality of information received from clients or in the process of performing in the course of performing their job duties,
• Maintain confidential information about the client that is not obtained from the client and keep confidential the source of this information, and do not share this information with the client without authorization from the source,
• Observe the basic rules of confidential information protection concerning access to the territory of the company and its subdivisions, storage and use of documents, employee access to information, and computer security,
• If confidentiality of information is not specified, it should be treated as confidential,
• Confidential information may be disclosed to third parties only with the written consent of the of the client or after the information is recognized as publicly available by the client,
• Confidential information may be disclosed if it is legally required of the company (e.g. to law enforcement authorities, security authorities) or is authorized by contractual agreement to disclose confidential information to other organizations, which in turn are responsible for the confidentiality of the information received.
  The client shall be notified of the transfer of information, unless prohibited by law.
• Inform and train staff on the basic provisions on impartiality and confidentiality of the company,
• Information about the privacy policy is communicated by publishing the relevant information on VIGOLIN JSC's website: www.vigolin.com.