Training and Development Policy

General principles: The Company considers professional development, fair career management, equal treatment of employees and respect for fundamental labour rights to be interconnected elements of sustainable personnel management. This Policy applies to all Company employees and is used in recruitment, hiring, assessment, training, development, career advancement, changes to working conditions and termination of employment relationships.

Transparent recruitment and priority for internal hiring: Personnel selection is carried out on the basis of predefined job requirements and the professional and business qualities of candidates. Material vacancy conditions, selection stages and decision-making criteria are communicated to candidates clearly and in a formalised manner. Where suitable internal candidates are available, the Company gives them priority access to the selection process for open positions and considers internal mobility before recruiting external candidates, unless this conflicts with the requirements of the specific position.

Non-discrimination in recruitment: The Company does not permit discrimination in hiring or personnel decisions based on gender, race, skin colour, nationality, ethnic or social origin, religion, age, disability or other characteristics unrelated to professional qualities and job requirements. Vacancy wording, selection criteria and candidate decisions shall be neutral and based on objective job requirements.

Regular performance assessment: The individual performance and competence fit of each employee are assessed regularly, but at least once a year. Assessment results are discussed with the employee and used to determine goals for the next period, training needs, competence development, possible career advancement and other development measures.

Individual development and career planning: An individual development plan and, where applicable, a career plan are created for each employee and updated at least once a year. These may include goals for developing professional and managerial competences, training, mentoring, participation in projects, expanded responsibilities, preparation for a possible transfer to another position and other measures appropriate to the needs of the employee and the Company.

Career mobility: The Company supports internal career mobility and provides employees with equal access to information about available development opportunities and internal vacancies. Decisions on transfers, expanded responsibility and promotion are made without discrimination, taking into account performance, competence, potential and job requirements.

Professional development: The Company provides employees with access to professional training programmes, including internal and external training, seminars, webinars, online courses and other learning formats aimed at developing the knowledge and skills required for the safe and high-quality performance of current and future tasks.

Personal growth, mentoring and internal training: The Company supports the development of management and soft skills, leadership qualities, communication and self-development. Mentoring, coaching and internal sharing of knowledge and experience among employees are encouraged in order to spread effective practices and develop competences.

Systematic training and evaluation of its effectiveness: Employee training is carried out systematically and consistently. The Company maintains the necessary records of completed training, conducts knowledge checks or certification where required, and evaluates training effectiveness through feedback, work results and other applicable indicators. Assessment results are used to improve training and development programmes.

Innovation and new learning technologies: The Company uses modern and accessible learning formats, including e-learning, microlearning, distance courses and educational platforms, where they improve the availability and effectiveness of personnel training.

Leadership development: Managers and employees performing management functions receive training and information on team management, communication, decision-making, change management, non-discrimination, equal treatment, proper interviewing and the prevention of bias in personnel decisions.

Measures in the event of organisational changes and workforce reduction: Where organisational changes may result in job reductions, the Company will, where possible, consider measures in advance to avoid or reduce redundancies and their negative consequences. Such measures include internal transfer, retraining, changes in responsibilities or working arrangements, natural attrition and other permissible solutions. If redundancy is unavoidable, the Company ensures compliance with applicable law, timely notification, prescribed payments and compensation and, where possible and proportionate, assistance to the employee in finding new employment or professional reorientation.

Public commitment to non-discrimination: The Company publicly declares that discrimination is unacceptable and seeks to ensure equal treatment and equal opportunities in employment regardless of gender, race, skin colour, religion, national, ethnic or social origin, age, disability or other characteristics unrelated to professional requirements.

Gender equality: The Company takes specific measures to support gender equality by ensuring equal access to vacancies, training and promotion; applying consistent remuneration criteria for comparable work and responsibility; preventing restrictions on career development based on gender; and considering potential unjustified differences in pay, development and promotion when analysing personnel decisions. Where unjustified differences are identified, corrective measures are taken.

Employment and working conditions for employees with disabilities: The Company seeks to ensure real employment opportunities for persons with disabilities and does not limit itself to minimum legal requirements. Specific employment targets for persons with disabilities are set and periodically reviewed by management, taking into account workforce size, the nature of vacancies and applicable mandatory requirements. Where necessary, reasonably adapted working conditions and workplaces are provided for employees with disabilities, including accessibility of the workplace, equipment, software, working arrangements and other conditions required to perform job duties.

Reporting violations and disciplinary measures: Every employee has the right to report in good faith a suspected breach of legislation, this Policy, safety requirements, ethics, non-discrimination, labour rights or other internal requirements. A report may be submitted in writing or electronically to the immediate manager, the Company’s management or the person responsible for the relevant function. The Company ensures that such reports are reviewed, preserves the reporter’s confidentiality where possible and does not permit retaliation for a good-faith report. Confirmed violations result in corrective actions and, where there are grounds, disciplinary measures in accordance with applicable requirements.

Prevention of child labour: The Company complies with applicable legal requirements concerning the minimum age for employment and does not use child labour. Where relevant legal requirements are absent, persons under the age of 15 shall not be employed and, where permitted by applicable rules, persons under the age of 14 shall not be employed, except in lawful apprenticeships, work placements, summer employment, school or educational programmes. Employees under the age of 18 shall not perform work or work under conditions that may harm their health, safety, security or moral development. The total time spent travelling to and from work and study, studying and working shall be less than 10 hours per day. The Company maintains personnel records that allow confirmation of employees’ ages and the age of the youngest employee.

Prohibition of forced labour: The Company does not permit the use of forced, compulsory, bonded or involuntary prison labour. Employment relationships are based on the voluntary consent of the employee and are formalised in accordance with applicable requirements. The Company does not permit the withholding of documents, money or other actions that unlawfully restrict an employee’s ability to terminate employment in the established manner.

Documentation and evidence of implementation: To confirm the application of this Policy, the Company retains applicable records and documents, including recruitment and internal vacancy materials, annual assessment results, individual development and career plans, training records, internal mobility decisions, documents on organisational changes, records of the review of violation reports and measures taken, as well as other documents required to confirm the implementation of established mechanisms.

Responsibility: The person responsible for organising implementation of this Policy is the person responsible for the OR function. Department managers ensure the application of Policy requirements within their authority. Every employee is required to comply with established requirements and has the right to report identified violations.

Review and update: The Policy is reviewed regularly and updated as necessary, taking into account changes in legislation, organisational structure, the results of effectiveness assessments and the Company’s needs.