VIDEOTON Automotive Electronics Ltd.

Employee Code of Conduct and Ethics

- short version -

2017.

1.The purpose of the Code

This Code of Conduct and Ethics (hereinafter referred to as ”Code”) applies to all employees and directors (hereinafter collectively referred to as “employees”) of VIDEOTON Automotive Electronics Ltd. (hereinafter referred to as “VIDEOTON” or “Company”).The purpose of the Code is to give guidance and fix basic company values, which determine the ordinary operation of VIDEOTON, thus helping the Company to become more successful.

2.Principles

Employees are required to comply with the applicable laws, rules and regulations and meet the high level of expectations of business ethics. Our employees are expected to act in good faith and make all efforts to comply with contractual obligations undertaken on behalf of our Company.

3.Anti-trust, competition laws

We expect all of our employees to work to advance and promote our Company’s interests and business growth, while always complying with all relevant antitrust and fair competition laws. In order to ensure compliance with these laws, our employees shall never discuss about issues that could be considered appropriate to restrict competition, fix or control prices or carry out any kind of other coordinated market activities.

4.Prohibition of corruption, bribery and unfair trade

VIDEOTON is committed to operating business in a fair and ethical manner – so we refuse activities such as offering or accepting bribes or kickbacks, granting preferential treatment in connection with financial supports, awards, payments or other similar business activities.

5.Partnership with customers and suppliers

In its partnership with customers and suppliers, VIDEOTON is always acting according to the principle of fair dealing and business correctness.

6.Political involvement, governmental relations

We do not limit our employees’ political involvement. However, during their political actions it is not allowed to use the name of VIDEOTON Automotive Electronics Ltd. and their such activities cannot be in contrast with the interests of the Company.

7.Safety at work, environmental protection, data protection and social responsibility

We require our employees to observe and strictly respect all safety laws, rules and regulations to maintain a safe workplace. VIDEOTON, as an ethical company, is firmly committed to the sustainable development, that is why we deem it extremely important to contribute to the promotion of green economy, the reduction of harmful emissions and the increase of waste recycling. VIDEOTON is committed to complying with all applicable legal requirements regarding data protection and privacy. As a responsible company, VIDEOTON plays an active role in society as well.

8.Working environment, prohibition of discrimination, violence and harassment at work

VIDEOTON provides a safe and productive working environment, where we respect the human dignity of each individual, we do not tolerate any discriminating behaviour and reject all forms of sexual, physical or verbal harassment. Our employees are not discriminated against based on race, ethnicity, colour, religion, political opinion, gender identity, national origin, ancestry, age, disability, family status, sexual orientation or other similar characteristics. Our Company rejects illegal child labour and will not tolerate it at any of our business partners either. VIDEOTON expects all employees to refrain from alcohol and/or drug abuse. VIDEOTON does not tolerate violence or threat of violence at the workplace, whether it is against the company assets or the physical integrity of the employees.

9.Protection of company assets and confidential information

All of our employees are obliged to protect the assets of our company. It is not allowed to use the Company’s assets, capital, facilities, means, personnel or other resources for private purposes, except where required by law or special authorization is granted by the company policy. Our employees must not use corporate confidential information for personal benefits. Unauthorized disclosure of confidential information is strictly prohibited and could result in serious consequences. It is important to take all appropriate precautions to protect confidential information. These types of information may only be disclosed even within the Company on a strict need-to-know basis.

10.Financial reports and audits

All registers and reports belong to the ownership of VIDEOTON. All registers must clearly reflect the revenues, expenditures, assets and liabilities of the Company. It is prohibited to make false, misleading or fraudulent registration into the company books or reports.

11.Conflicts of interest

Honesty and integrity must be applied while we are doing business. Our employees cannot be engaged in any activities which are incompatible with their positions and duties performed at the Company.

When a conflict of interest is unavoidable, employees must disclose the interest to the appropriate member of the management as soon as they become aware of the conflict or potential conflict.

12.Gifts and gratuities

Gifts should never be in form of cash, they should be infrequent, of low or insignificant value and should follow all company guidelines. A gift of significant value must be returned immediately and reported to the supervisor. All business entertainment should be infrequent, modest and intended to serve legitimate business goals.

13.Trade and export controls

VIDEOTON ensures full compliance with all of the requirements of commercial law.

14.Communication, press releases

As VIDEOTON Automotive Electronics Ltd. is the subsidiary of VIDEOTON HOLDING ZRt., the group’s relationships with the media are conducted according to a unified and controlled communication strategy, the main point of which is that only the authorised persons are allowed to make public statements.

15.Reports, questions, failure to comply with the Code

Employees have the responsibility to ask questions, request guidance and report potential violations of this Code. If an employee or representative of the Company has engaged in a conduct that violates applicable law or this Code, employees have a duty to report such breach. All reports are treated as confidential.

Failure to comply with the present Code will - subject to applicable law - result in disciplinary action that may even lead to dismissal. Violations of certain provisions of this Code may require the company to refer the matter to authorities for investigation or prosecution.

16.Final provisions, summary

All of the managers are responsible for the compliance with and the enforcement of the present Code. We are striving to meet the high level needs of our customers and clients by continuously developing or products and services.

Remark: VIDEOTON Automotive Electronics Ltd. reserves the right to amend or terminate this Code at any time for any reason. The purpose of the present document is solely to bring the general principles and policies of VIDEOTON Automotive Electronics Ltd. together. Nothing in this document can serve to create a cause of action in favour of any third party, including any employee, officer, director, customer, supplier or stockholder of the Company. None of the provisions in this Code is a guarantee or promise of employment.