INTRODUCTION

This Partner Interaction Code (hereinafter referred to as the “Code”) has been developed by the AURORA Group of Companies (hereinafter referred to as the “Company”) to define the fundamental principles governing the relationship between the Company and its business partners (hereinafter referred to as the “Partner”). We view this Code as a shared framework for building open, transparent, and long-term cooperation with our Partners. The Company’s mission is to improve people’s everyday lives by making products for home and personal well-being more accessible. We achieve this mission through the continuous search for the best offers from our Partners, the ongoing optimization of internal processes, the expansion and enhancement of our product assortment, and the analysis of current consumer demand, price segments, seasonality, as well as our customers’ preferences and needs.

This Code is founded on the Company’s guiding principles:

Act for people

People — our customers, Partners, and employees — are always at the center of our decisions. We strive to build interaction based on respect, understanding of needs, and mutual value.

Lead to unlock opportunities

We support initiative, willingness to take responsibility, and the search for new opportunities to develop cooperation. We believe that proactivity and an entrepreneurial mindset help find better solutions even in new or challenging situations.

Collaborate for more

Joint efforts are our key strength in bringing large-scale ideas to life.

Lead with efficiency

Our success is built on cost reduction through continuous improvement. We offer low prices and additional benefits that make customers choose Aurora.

Give with goodwill

We have kind hearts and are willing to give without expecting anything in return.

Data-driven decisions

We strive to ensure that our decisions are based on facts, analytics, and real results. This helps us act reasonably and effectively.

Be open to the new

We are open to change, new ideas, and experimentation. Continuous development and readiness to reconsider established approaches help us move forward.

Client at the center

The client defines our direction. We focus on what truly matters to them and act accordingly.

Measure ROI

We aim to make well-reasoned decisions regarding investments and development by assessing their feasibility and long-term value.

Act with integrity

We conduct business honestly, transparently, and responsibly. Integrity means complying with applicable laws, internal policies, and ethical principles — even when no one is watching.

Achieve results

We focus on fulfilling agreements, taking responsibility for outcomes, and meeting our commitments.

As-is – To-be

We analyze current processes, identify opportunities for improvement, and implement changes that help us operate more efficiently. Our goal is to cooperate only with those who share our guiding principles and values that form the foundation of this Code. To ensure this is implemented in practice, the Company expresses its readiness to support our Partners, including by providing consultations, conducting training sessions, assisting in the implementation of LEAN management, and supporting their projects and growth. The Company considers a Partner to be any party with whom it cooperates in the course of its business activities. The provisions of this Code also apply to the Partner’s employees, representatives, and subcontractors engaged in such cooperation. Partners represent and warrant that they conduct their business activities in compliance with all laws and regulations applicable to their operations and take reasonable measures, proportionate to the scale and nature of their activities, to comply with this Code. Partners shall take the provisions of this Code into account when selecting their suppliers, contractors, and subcontractors involved in fulfilling obligations to the Company and shall make reasonable efforts to ensure that such parties adhere to the principles set forth in this Code.

WHO CAN BECOME OUR PARTNER?

The Company considers the possibility of cooperation with counterparties who:

• conduct transparent and responsible business practices and have a proper business reputation, • maintain the highest level of customer orientation and flexibility,
• offer economically justified and competitive terms,
• develop their business in compliance with the quality standards of the relevant industry,
• conduct business ethically and are ready to provide mutual assurances regarding joint prevention of fraud and corruption,
• refrain from any attempts to improperly influence employees, Partners, or other persons associated with the Company, or to affect their actions or decisions through the provision of improper benefits or material advantages, • share the guiding principles and values set out in this Code,
• do not engage in any forms of unfair competition or violations of business conduct rules,
• demonstrate respect and restraint in their relations with the Company,
• comply with applicable laws, including regulations on labor conditions and occupational safety, environmental standards, fair competition, anti-corruption measures, and ensure transparency of operations as well as proper accounting and tax reporting in accordance with the law.

HOW TO BECOME OUR PARTNER?

1. Follow the link: https://corporate.avrora.ua/for-partners/
2. Submit your application on the website by selecting the potential area of cooperation.

Submitting an application does not guarantee the conclusion of a contract or the commencement of cooperation. The decision on the possibility of cooperation is made by the Company based on the results of internal due diligence in accordance with its policies, procedures, and risk assessment criteria.

PARTNER SELECTION PROCEDURE

Upon receipt of an application, the Company reviews and verifies it in accordance with its internal regulations, policies, and procedures. The review may include, in particular, an assessment of business reputation, compliance checks, sanctions screening, analysis of compliance with the principles of this Code, and other risk assessment measures. The Company reserves the right to request additional documents and information necessary for making a decision. Following the review of the application, the Company shall inform the applicant of its decision within a reasonable period of time. In the event of a refusal to cooperate, the Applicant may re-submit an application after eliminating the circumstances that led to the refusal or if new material information becomes available that may affect the Company’s decision. Any re-submitted application shall be subject to a new review in accordance with the Company’s internal policies and does not guarantee a change in the previously adopted decision. The Company reserves the right to restrict the possibility of re-submitting an application in cases where material violations have been identified or false information has been provided.

PRINCIPLES OF INTERACTION WITH PARTNERS

• Rational Use of Natural Resources and Environmental Protection

The Partner represents and warrants that it complies with applicable environmental laws and regulations in the course of its activities and takes measures to reduce its negative impact on the environment. In particular, the Partner optimizes the consumption of raw materials and energy; reduces the use of natural resources; minimizes emissions arising from the production and use of products; and reduces waste generation. Proper management of natural resources and responsible waste disposal are important indicators of responsible partnership.

• Interaction with Public Officials and Prevention of Corruption

We expect our Partners to cooperate with public authorities in compliance with applicable laws. We also expect our Partners to act responsibly and, in cases provided for by law, to report identified violations to the relevant authorities.

• Compliance of Documentation and Reporting with Applicable Law

Partners represent and warrant that their financial statements and accounting records comply with applicable legal requirements, are complete, accurate, and clear, and properly reflect their business activities in their accounting systems. Partners maintain tax and accounting records and prepare documents related to business transactions with the Company in accordance with legal requirements, ensuring consistency and accuracy of information contained in primary accounting documents and tax invoices.

• Support for Ukrainian Manufacturers

As the global economy becomes increasingly interconnected, the Company seeks to build its own business ecosystem by creating additional opportunities that improve the business climate and enhance the operational excellence and competitiveness of Ukrainian businesses. Joint growth with our Partners is our priority.

• Compliance of Goods and Services with Established Quality Standards

We cooperate with Partners who represent and warrant that their goods and services comply with agreed requirements and quality standards (including specifications, technical requirements, legal requirements, and/or the Company’s requirements). With respect to the supply of goods, Partners are responsible for the accuracy and reliability of product information, as well as compliance with applicable information disclosure and labeling requirements. With respect to the provision of services, Partners are responsible for engaging qualified personnel, complying with agreed scopes, deadlines, and performance parameters, and ensuring the accuracy of information regarding the scope and results of the services provided. Partners respect the intellectual property rights of third parties both in the process of supplying goods and in the provision of services. Mutual trust in matters of quality is of fundamental importance to us. Therefore, we seek to cooperate with Partners who represent and warrant their readiness, upon request, to provide all necessary documentation and, subject to prior agreement, grant the Company’s representatives access to their production facilities or service locations for the purpose of conducting audits and verifying compliance with quality standards.

• Prevention of Bribery and Corruption

The Company and its Partners represent and warrant that they fully comply with all applicable laws relating to anti-corruption, the offering or receipt of improper benefits, fraud, money laundering, and terrorist financing, including international anti-corruption standards and principles, as well as conflict-of-interest prevention requirements set forth in the Law of Ukraine “On Prevention of Corruption.”

• Risk Assessment

The Code establishes the necessity of assessing the risks associated with interaction with potential or current counterparties. If there are serious and reasonable grounds to believe that continuing cooperation with a Partner may harm the Company’s reputation, this may serve as grounds for reviewing or terminating the relationship. Negative media coverage concerning a Partner may also be considered a serious breach of these standards and may constitute grounds for termination of the partnership.

• Sanctions Lists

The Company and its Partners represent and warrant that they are not included in any of the following sanctions lists: the NSDC (National Security and Defense Council of Ukraine) Sanctions List, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) Sanctions List, the Canadian Sanctions List, the European Union Sanctions List, the Australian Consolidated Sanctions List, the United Kingdom Sanctions List, the Japanese Sanctions List against the Russian Federation in connection with the events in Ukraine, or the U.S. Department of Commerce Bureau of Industry and Security (BIS) restricted party lists. They further represent that they are not included in the Unified State Register of Persons Who Have Committed Corruption or Corruption-Related Offenses and do not engage in any payment and/or trade transactions with countries and/or entities subject to restrictions and/or economic sanctions. The Partner represents and warrants that it has no business relationships with individuals or legal entities from the Russian Federation or the Republic of Belarus that may directly or indirectly facilitate aggression against Ukraine. Partners further represent and warrant that they do not engage in activities that directly or indirectly support the aggressor state or undermine Ukraine’s defense capabilities. The Partner undertakes to use all reasonable efforts to promptly inform the Company of any claims, investigations, or proceedings related to the imposition of sanctions on the Partner or its key personnel.

• Fulfillment of Tax Obligations

Partners represent and warrant that they act with integrity in tax matters and do not participate in activities that may constitute tax evasion. Partners are responsible for understanding and complying with all tax requirements and obligations applicable to their activities with respect to any funds received from the Company.

• Anti-Money Laundering

Partners represent and warrant that they comply with anti-money laundering principles and do not participate in any activities that may be associated with the laundering of proceeds derived from criminal activities.

• Promoting Objective Decision-Making by Employees

The Company recognizes that business hospitality and the occasional exchange of gifts with business Partners are common business practices. However, such practices must not create conflicts of interest or influence decision-making. Any gifts, hospitality, or other benefits are unacceptable if they may influence, or appear to influence, decisions made by the Company’s employees. In cases of doubt regarding the appropriateness of a gift, it is recommended to refrain from offering it. In accordance with the Company’s policy, if the value of a received gift or benefit exceeds UAH 800, it must be transferred to the Company’s balance sheet. Such items may subsequently be donated to charitable causes.

• Corporate Social Responsibility

The Company strives to make the world a better place by using its resources in the most effective way possible. We expect our Partners to take a systematic approach to social responsibility management and to contribute to the development of a corporate culture that brings society together. The Company encourages the active participation of its employees and Partners in improving the quality of life in society by supporting and promoting voluntary involvement in social initiatives and community-focused activities.

• Respect for Human Rights and Prevention of Forced Labor

We expect our Partners to respect human rights in accordance with the United Nations Universal Declaration of Human Rights. Partners represent and warrant their clear commitment to respecting the dignity, privacy, and rights of every individual. Any form of violence, discrimination, modern slavery, abuse, or sexual harassment is unacceptable. The Company is a participant of the United Nations Global Compact in Ukraine and integrates its principles into its operations while supporting the achievement of the Sustainable Development Goals. We seek to develop cooperation with Partners who share these values.

• Workplace Safety and Health

Partners represent and warrant that they provide safe working conditions and demonstrate due care for the health and well-being of their employees in accordance with applicable laws and international standards. These requirements apply to all employees and contractors under the Partner’s control.

Such requirements include, but are not limited to:

• compliance with occupational health and safety regulations;
• ensuring adherence to workplace safety and health protection requirements and obligations;
• reporting hazards, risks, or unsafe conditions;
• providing employees with appropriate welfare and workplace facilities;
• adhering to the principles of a barrier-free business environment and ensuring continued support for accessibility and inclusion.

• Protection of Confidential Information and Personal Data

The Company pays special attention to the protection of confidential information and expects its Partners to handle it responsibly. The processing, use, transfer, and storage of information must be carried out solely for business purposes and in compliance with applicable laws. The Partner is not entitled to use information obtained during cooperation with the Company for training or testing artificial intelligence systems without the Company’s prior consent.

• Political Neutrality

We adhere to the principle of political neutrality in our activities and do not support any political parties, movements, or campaigns. Within the framework of partnership cooperation, we expect mutual respect for this approach and refraining from political campaigning, propaganda, or participation in political activities that may be associated with our Company. We believe that business partnerships should be based on professionalism, transparency, and shared values, outside of any political context. This approach helps maintain trust, stability, and the reputation of all parties involved.

• Adaptability

Today, business reflects the need for companies to change and adapt to shifts in both the internal and external environment. This principle is becoming increasingly important in the context of rapid technological development, changes in consumer preferences, market competition, and other factors.

• Compliance with Working Hours and Respect for Personal Time

Partners represent and warrant compliance with the Company’s established working hours (on weekdays from 08:00 to 17:00) and respect for the personal time of its employees. Contacting Company representatives outside working hours, including telephone calls, personal visits, or other forms of communication, is permitted only in exceptional cases and by prior arrangement. The Company, in turn, ensures timely feedback during working hours and provides mechanisms for prompt communication in the event of urgent matters. We count on mutual respect for working time.

• Prohibition of Moral Pressure and Manipulation

We strive to build cooperation based on open and constructive dialogue. Any forms of pressure or manipulation contradict the principles of our interaction. Any attempts to influence the Company’s decisions, including through blackmail, ultimatums, or demands to revise material terms of the contract on conditions unfavorable to the Company, are considered unacceptable. In the event such actions are identified, the Company reserves the right to:

• initiate an investigation;
• review the terms of cooperation or refuse further cooperation with the Partner.

For its part, the Company strives to maintain constructive dialogue with its Partners. Any changes to the terms of cooperation must take place solely by mutual agreement of the parties and on the basis of the partnership principle.

• Intellectual Property

The Partner represents and warrants that the goods, services, materials, designs, content, and other intellectual property results used in cooperation with the Company have been lawfully created and used, do not infringe the intellectual property rights of third parties, and are covered by the necessary licenses or other legal grounds for use. When using artificial intelligence tools within the framework of cooperation with the Company, Partners represent and warrant that they use only those tools whose license terms permit their use for the relevant commercial purposes. Partners represent and warrant that they make every effort to ensure that the results obtained do not infringe the intellectual property rights of third parties. Partners shall inform the Company of the use of such tools if it affects the Company’s rights to the results of the cooperation and shall provide additional information regarding such use upon the Company’s reasonable request.

The Partner shall:

• not use the Company’s intellectual property without prior written authorization;
• notify the Company of any third-party claims regarding potential infringement of intellectual property rights;
• provide supporting documentation upon the Company’s request.

In the event that third parties assert claims regarding infringement of intellectual property rights in connection with results provided by the Partner, the Partner shall promptly inform the Company thereof, cooperate in good faith in resolving such claims, settle such claims at its own expense and by its own efforts, and reimburse the Company for documented costs incurred as a result of such claims.

EMERGENCY PREPAREDNESS

The Company pays attention to risk management and preparedness for emergency situations. Partners represent and warrant that they take reasonable measures, proportionate to the scale and nature of their activities, to prepare for and respond to such events, including incidents related to health and safety, technological risks, natural disasters, military actions, and other force majeure circumstances. In the event of an emergency, the Partner shall immediately notify the Company of any circumstances that may affect the performance of contractual obligations and shall take reasonable measures to mitigate the consequences. In particular, this may relate to business relocation, damage to production facilities, disruptions in logistics, or other consequences of war-related risks. The Partner shall also give priority to the safety of employees and, to the extent possible, ensure business continuity.

MONITORING, AUDIT, AND COMPLIANCE

We seek to cooperate with Partners who conduct their activities in a transparent and responsible manner, complying with applicable laws and the standards set forth in this Code. Where necessary, the Company may conduct compliance reviews and request supporting documentation, including through the collection of information via questionnaires, audits, surveys of the Partner’s subcontractors, inspections of product samples provided, reviews of production business processes, and other similar measures. The Partner, in turn, shall facilitate such reviews and notify the Company of any material changes. This approach helps prevent risks and maintain stable trust in cooperation. By familiarizing itself with this Code, the Partner confirms its intention to comply with its provisions throughout the entire period of cooperation with the Company. Partners shall promptly notify the Company of any known actual or potential violations of this Code, applicable laws, human rights, anti-corruption, sanctions, environmental, or ethical requirements, as well as any other material circumstances that may adversely affect the Company’s business reputation or operations. Together with such notification, the Partner shall provide any available relevant information and assist the Company in conducting a review or audit and, where necessary

- propose a corrective action plan to remedy the violation. The Company supports a culture of good-faith reporting of concerns and violations (“Speak Up Culture”). Reports may be submitted confidentially or anonymously (where permitted by applicable law) through:

- Trust Line Portal: https://avrora.ethicontrol.com/web/en

- Telephone: 0 800 357 166. The Company guarantees careful and impartial consideration of every report, confidentiality of the information received, and protection of individuals who, in good faith, report violations from retaliation, discrimination, or any other adverse consequences. Reports from Partners shall be reviewed on the same basis as reports submitted by other reporting parties. Where necessary, the Company may request additional information, documents, or access to relevant materials from the Partner, as well as initiate a review of compliance with this Code. In the event violations by the Partner are identified, the Company and the Partner shall agree on the procedure and timeframe for remedying such violation. If no agreement is reached, as well as in cases where the Partner fails to report known violations or refuses to cooperate during a review, the Company shall have the right to immediately suspend cooperation with the Partner by sending a written notice of termination. If the circumstances in relation to which the Partner provided representations prevent payments from being made in the Partner’s favor, the Parties shall agree on an alternative payment procedure and timeline. Any outstanding debt for which no payment arrangement has been agreed shall be written off in full after one year from the date such circumstances arose. In the event of any inconsistency between the documented terms of cooperation with the Partner and this Code regarding the procedure for termination of cooperation or write-off of debt, the provisions of this Code shall prevail.