Ethics & Anti-corrupion & Whistleblowing

BACKGROUND
1. Biotic Circular Technologies Ltd. (the “Company”, “Biotic”, “we”) has adopted this Ethics Code & Anti-Corruption Standards (the “Code”) as a guide for personal business ethics when dealing with customers, representatives, suppliers, employees, and government agencies (“Company’s Representatives”) to help in the recognition and management of ethical issues as well as to provide mechanisms to report unethical conduct and to foster a culture of honesty and accountability.
PURPOSE AND SCOPE
1. This Code summarizes the standards and procedures that guide Company’s actions. All of our employees, officers and directors must conduct themselves according to the language and spirit of this Code and seek to avoid even the appearance of improper behavior.
2. While covering a wide range of business practices and procedures, these standards cannot and do not cover every issue that may arise, or every situation where ethical decisions must be made, but rather set forth key guiding principles that represent Company policies and establish conditions for employment at the Company.
APPLICATIONS
1. This Code is not intended to be comprehensive rulebook and cannot address every situation that you may face, If you feel uncomfortable about a situation or have any doubts about whether it is consistent with the Company’s ethical standards this should be reported to any of the persons listed in the Reporting Mechanism Section
2. All Company’s Representatives have a duty to report any known or suspected violation of this Code, including any violation of the laws, rules, regulations or policies that apply to the Company. Again, if you know of, or otherwise suspect, a violation of this Code, immediately report the conduct to the Regulation Manager.
ETHICS STATEMENT
1. Biotic is proud of its policy of adhering to high ethical standards in dealing with customers, representatives, employees, and government agencies. We believe our business partners / employees enjoy that reputation and share our belief in the importance of integrity and our concern over the potential for misconduct in business practices.
2. The Company is committed to operate all activities within the spirit of obeying all laws and regulations affecting its businesses and employees.
  Whenever an employee has doubt how to act he should ask himself the following questions:
  “Why am I doing this?”
  “Is it legal? Is it the right thing to do?”
  “Did I follow the right steps?”
  “How does this look?
  When in doubt, ask! Do not guess.
Anti-corruption
1. It is Company’s strict policy that it conducts its business free of corruption and other impropriety. Like all businesses, the Company, and all its personnel (including all officers, directors, employees) and third parties acting on the Company’s behalf (including but not limited to agents, resellers etc.), are subject to anti-bribery, anti-corruption and anti-money-laundering laws in the various jurisdictions in which they operate. It is prohibited to pay or offer, directly or indirectly, money, material benefits or any other advantages of any kind to third parties, whether representatives of governments, other public officers and public servants, or private employees and entities, in order to influence or remunerate the actions of their office or otherwise receive unfair and illegal business for the Company.
2. In the event of a violation of these provisions, Company and any company personnel involved may be subject to disciplinary action for violation of this Code as well as potential civil or criminal liability for violation of applicable anti-bribery and anti-corruption laws. Should you have any questions relating to the Company’s anti-bribery and anti-corruption policy, the applicable laws or whether an activity could be deemed to be problematic or illegal, or wish to raise any concern at all please seek the guidance of a Regulation Manager.
Reporting mechanism
1. Every employee has the right to report any suspected violation with referring to this procedure.
2. The Information of the violation should be specific, and it is best if can be backed up by dates, places and any other information that can clarify the details of the case.
3. The Regulation Manager is responsible for collecting all the information of the case, write it down as clearly as possible, and file it. It is imperative that reporting persons not conduct their own preliminary investigations. Investigations of alleged violations may involve complex legal issues and acting on your own may compromise the integrity of an investigation and adversely affect both you and the Company.
4. If needed and other parties are involved, Regulation Manager should interview the parties and collect all information.
5. The Regulation manager should report the CEO of the specific case and its details. Further steps will be discussed and determined by the CEO and the Regulation Manager.
6. if you think an employee / customers/ suppliers / Representatives / Government agencies breaks the Code or the law please report to Eti Levi Rozen who acts as the “Regulation Manager” or any of the below managers:
7. Please note Biotic strictly prohibits all forms of retaliation or victimization against any employee who has raised concern or reported a compliant, in good faith under this Code. Specifically, the Company guarantees that employees will not face retaliation from their superiors or management for reporting any suspicious activity. If you believe you are being retaliated against, please speak up. It is expressly stated that retaliation against an employee for whistleblowing may be grounds for immediate termination.
8. You can also report to:
  1. Adi Goldman: CEO & Co-Founder: [email protected] 054-442-4542
  2. Eran Perlstein: COO Operation & Co-Founder: [email protected] 054-774-7302
  3. Einat Truger, Business development, HR: [email protected] 054-673-1267
  4. Eti Levi Rozen, Operations Supply Chain, Regulations, HR: [email protected] 054-774-7612
  5. Etai Landou, R&D(Environmental): [email protected] 054-819-9735
  6. Eirit Fishman, Finance: [email protected] 054-774-7634