The primary purpose of the warning and disciplinary system is not to punish employees, but to ensure consistent compliance with the rules, requirements and expectations necessary for performing work.

The system aims to:

• make clear to employees the importance of the Company's rules and expectations;
• minimise breaches of the rules, particularly repeated breaches;
• support safe, orderly and efficient work;
• contribute to compliance with occupational safety, quality and Company requirements;
• give employees an opportunity to understand the conduct being challenged and change their future conduct accordingly;
• ensure that identical or similar breaches are assessed consistently and predictably.

A warning is therefore primarily a preventive and corrective measure intended to ensure proper work performance and compliance with Company rules. In every case, the employer considers the material circumstances of the incident, taking account of proportionality and progressive escalation.

The personal and organisational scope of this procedure covers Vipulse Production Kft. and Vipulse Technology Kft. (hereinafter collectively the “Company”). Its provisions also apply, as appropriate, to other persons present at the place of work or on Company premises, particularly in relation to entry, security requirements, occupational safety rules and the use of the premises.

In applying this procedure, particular consideration must be given to the following legal framework:

• Act I of 2012 on the Labour Code (Mt.), particularly Sections 9, 10, 11/A, 52, 56, 78 and 146, and the provisions concerning fitness for work, employer monitoring, employee obligations, the legal consequences of culpable breaches of obligations, and the conditions for termination with immediate effect;
• the Hungarian and European Union rules in force on the protection and processing of personal data, particularly the safeguards for processing health data; and
• the Company's occupational safety, fire safety, security, IT, quality management and other internal procedures in force at the relevant time.

Responsible: for decisions, implementation, checking, supervision, coordination and communication.

Cooperates: obliged to cooperate and perform assigned parts of a task.

To be informed: of decisions, implementation and results.

The warning level or score specified in this procedure cannot override applicable legislation.

The score under this procedure is solely an internal system for consistently assessing the seriousness and recurrence of breaches of obligations. A score does not in itself constitute a financial penalty, result in wages being withheld, or result in termination of employment. A particular incident does not in itself mean that the employment relationship may be terminated.

Depending on the seriousness of the incident and an individual assessment of all its circumstances, the employer may also initiate or implement termination of employment if the relevant statutory conditions are met.

If the same or a similar breach of obligations recurs while a previous warning remains active, the employer considers applying the next warning level, taking account of all the circumstances of the case.

A score does not in itself result in termination of employment; the employer assesses individually the seriousness of the incident or incidents, the employee's culpability, recurrence and all other relevant circumstances.

The employer assesses the incident on the basis of provable facts and the material circumstances of the case. To ensure objectivity, involving any witness or witnesses present in the vicinity of the incident is expressly recommended.

The measure applied is proportionate to the seriousness of the breach of obligations, its consequences, culpability and recurrence.

A higher warning level may be applied for repeated or more serious breaches.

The employee's human dignity and personality rights must be respected during checks and investigations.

Only necessary and sufficient personal data may be processed in the case, and access to the records must be restricted.

Where possible, the incident and evidence underlying the employer's measure must be properly documented without delay after the incident.

The Company operates a four-level warning system. The score assigned to each level indicates the seriousness of the incident. Scores must be added together on the basis of the employee's points that remain active. This total score is used to examine whether further employer measures are necessary.

Taking account of all the circumstances of the case, the person conducting the procedure may reduce the warning level assigned to the incident by one level. This must be recorded in the documentation and incident report.

The levels are set out in document VIP-VH-HR-02-01-01-H, “Warning and scoring guidance matrix”.

The manager may retain the warning level or reduce it by one level without giving reasons; the red-highlighted incidents at level IV are excluded from reduction.

If several warning incidents occur at the same time, the higher warning level applies without reduction.

The score is guidance. Each case must be assessed in light of all the circumstances, culpability, consequences and recurrence.

1. Find the breach in the main table.
2. The suggested score may be used as a starting point.
3. If the incident is not listed, compare it with the closest example and assign 1–4 points.
4. A higher level may be considered for recurrence or more serious consequences.
5. Consult HR about the specific employer measure if necessary.

The examples listed are illustrative and do not exclude the assessment of other breaches of obligations arising from employment. The same conduct may be classified at different levels depending on the circumstances of the case.

• Each point assigned to a warning may be taken into account for six months from the date the warning is communicated. (For example: 2026.07.25–2027.01.25 or 2026.08.31–2027.02.28.)
• After six months, that point may not be taken into account when determining the next warning level.
• The fact that expired warnings were issued must be retained for the period prescribed by law, but cannot be used in calculating points.
• If the same or a substantially similar breach recurs while the earlier warning remains active, the employer considers applying the next warning level.

If the total of active points reaches or exceeds 4 points, the employer must examine whether further employer measures, including termination of employment, are necessary.

When preparing an employer measure, the incident must be handled under the following procedure, depending on its nature and seriousness. The incident is detected or reported.

• Record the incident without delay on the basis of the available facts.
• Establish the facts, involve witnesses if necessary, and collect relevant evidence to the extent needed.
• Classify the breach and determine the warning level on the basis of document VIP-VH-HR-02-01-01-H, “Warning and scoring guidance matrix”.
• Inform the employee concerned of the employer's decision by completing VIP-RS-HR-02-01-01-H, “Warning incident report”; hear the employee and give them an opportunity to present their observations on what happened.
• The employee states on the incident report whether they accept the employer's decision. If the employee refuses to receive or sign the report, record this on form VIP-RS-HR-02-03-01-H, “Record of refusal to accept an employer warning”. If the employee disagrees with the decision and records this on the incident report, a full investigation of the matter must be conducted. HR initiates the investigation to provide an objective and comprehensive review of the circumstances and available information. Depending on the nature of the matter, involve the relevant manager, witnesses and, if necessary, an occupational safety, quality management, IT or other specialist.
• Participants sign the incident report. Forward the original to HR for retention and give a certified copy to the employee concerned.
• HR registers the warning.
• If a warning was previously issued to the employee within the relevant six-month period, HR informs the employee in writing of their current warning score using VIP-RS-HR-02-02-01-H, “Information on active warning points and their expiry”, and draws attention to the importance of complying with the rules and the possible consequences of further breaches.
• HR prepares three copies of the score notification, which the employee acknowledges by signing. HR retains the signed original in its records; the employee receives a certified copy; and the workplace manager retains a further certified copy.
• HR checks whether the employee's active warning score reaches 4 points.
• If the active score is below 4 points, the employee continues working under unchanged conditions.
• If the active score reaches or exceeds 4 points, the employer examines whether to release the employee from work, whether another employment-law measure is justified, or whether the conditions for termination of employment are met.

Management aid. The policy in force at the relevant time contains the detailed procedural rules.

The employee is entitled to present observations on the facts and classification set out in the warning, orally or in writing, with a written record. The observations or the written record submitted by the employee must be attached to the case file.

• Every warning and its related incident documentation must be entered in the records maintained by HR.

The warning document must contain at least:

• the date of the incident;
• the information necessary to identify the employee concerned;
• a factual description of the incident;
• identification of the rule or obligation breached;
• the level and score determined;
• the employee's decision to acknowledge or reject it;
• the signatures.

• HR retains the original documents in accordance with the document management and data retention rules in force.
• The basic warning data may be entered in the employer's HR system if necessary and in accordance with access rules.
• Only persons with an appropriate job-related, statutory or other authorisation to process the data may access the case records.
• Information constituting health data or indicating a person's state of health, particularly detailed alcohol test results, may be processed only to the extent necessary and in accordance with the applicable data protection rules.
• Access to and disclosure of the employee's personal data must always be organised in accordance with purpose limitation, data minimisation, necessity and proportionality.

The Company gives particular priority to fitness for work, occupational safety and accident prevention. Employees must start work in a condition fit for work and remain available to the employer in that condition throughout working time.

The procedure covers the Company's entire organisation. It also applies, as appropriate, to other persons present at the place of work, together with the entry, security, occupational safety and premises rules relevant to them.

If visitors or other persons entering the premises refuse to consent to a check, the Company is entitled to refuse entry or require them to leave the premises.

• A targeted check may be ordered if circumstances indicating intoxication or another condition rendering a person unfit for work are observed.
• Random checks may be applied only under general, objective rules communicated in advance, subject to necessity and proportionality.
• A check may be initiated by the head of the area or organisational unit or by an HR staff member designated for this purpose.
• A person designated by the employer and appropriately trained is authorised to perform the check. Security staff may also perform it provided they have received the necessary training.
• In view of the data protection requirements concerning personal data processing, only the employer's own employee designated for this purpose is authorised to prepare the written record.

During the check, the employer must ensure respect for the human dignity and personality rights of the employee and everyone participating in the procedure.

The employer's internal assessment and procedural threshold is 0.11‰. The value displayed by the measuring device, its unit of measurement, the circumstances of measurement and all relevant circumstances of the case must be considered together when assessing the result.

If the first measurement exceeds 0.11‰, a repeat, confirmatory measurement must be taken without delay using a properly functioning device designated by the employer. The confirmatory measurement is performed by a person designated and authorised by the employer, in accordance with the manufacturer's instructions for the device and other requirements for its use. Record the result in the unit used by the device, with the date and exact time of measurement, on form VIP-RS-HR-02-05-01-H, “Test log for checking alcohol impairment and fitness for work”.

The test is positive if both the first and the confirmatory measurement exceed 0.11‰. For a positive result, record the conduct of the check, its result and the relevant circumstances on form VIP-RS-HR-02-04-xx-H, “Record of checking alcohol impairment and fitness for work”, and apply the further procedure set out in this document to the employee.

To ensure evidentiary support and procedural regularity, a positive test result must be documented in the presence of at least one witness. The witnesses' identities and identifying details must be included in the documentation relating to the check.

If the first measurement is not positive, no further measure concerning the employee is necessary, and a separate incident record is not warranted.

The employee is entitled to dispute a positive measurement result. The fact that it is disputed must be recorded. Section 1.6.7.4 of this procedure contains the detailed rules for disputes.

The test is positive if both the first and the confirmatory measurement exceed the 0.11‰ threshold specified in this procedure.

If the employee disputes the positive measurement result, record the dispute and the employee's statement in record VIP-RS-HR-02-04-xx-H. The employer investigates the matter by considering the available evidence, measurement results, witness statements, the employee's statement and all relevant circumstances of the case.

If warranted to establish the facts, the employer may initiate a further medical examination or examination by the competent authorities. Within the available lawful procedures, the employer may request assistance from the authorities to carry out further examinations to establish the facts.

Following a positive measurement result, the employee must not be assigned further work on that working day and must be prohibited from working. The legal classification of the absence and its remuneration are determined in accordance with applicable legislation and the individual circumstances of the case.

If results of further medical examinations or examinations by the authorities are available, the employer must take them into account when assessing the matter.

The employer decides who bears the costs of further medical examinations or examinations by the authorities in accordance with applicable legislation and the specific circumstances of the case.

The employer makes its final decision on the basis of the available measurement results, records, statements, witness testimony and any further medical or authority examination results, and applies the necessary employer measures in accordance with this procedure.

An employee's unjustified refusal to cooperate constitutes a breach of obligations arising from employment. The refusal must be documented without delay, and its employment-law consequences determined on the basis of the circumstances of the case.

The employee may temporarily be prohibited from working if they are unfit for work or there is a well-founded suspicion that they are unfit for work.

Principle: respect the human dignity and personality rights of everyone concerned throughout the check. Final assessment considers measurement results, witness statements, the written record and employee statement, further examination results and all circumstances. Employer decision and closure: determine the decision, the legal classification and remuneration of the absence, and any further measure under legislation and the individual circumstances. Important: always record the value in the unit displayed by the device. 0.11‰ is the internal procedural threshold.

1. Record a positive result, any dispute, refusal of the test and the associated measures in a written record.
2. Prepare two copies of the record: one for the employee concerned and one for HR.
3. Only persons with the necessary job-related access rights may access detailed alcohol measurement data.
4. The employer processes and retains the records and related documents in accordance with the data processing and document management rules in force.

If the employee's condition gives rise to a sufficiently well-founded suspicion that they may be under the influence of an intoxicating or mind-altering substance, further work may temporarily be prohibited to ensure safe working conditions. If necessary, an occupational health or other appropriate medical examination may be initiated.

The examination may be performed only lawfully and by a person with the appropriate professional authorisation.

• This procedure takes effect on the date of approval and replaces, or is consolidated with, the Company's previous warning and disciplinary procedure concerning the same subject matter.
• The employer reviews the provisions as necessary, particularly following legislative or organisational changes or in light of occupational safety or operational experience.
• This procedure and its application do not affect employees' statutory rights or their ability to assert employment-law claims.
• Matters not regulated by this procedure are governed by the legislation in force at the relevant time and the Company's other internal procedures in force.

The purpose of this Code is to define the ethical, business and behavioural expectations that ensure the responsible, transparent, fair and lawful operation of Vipulse Production Kft. and Vipulse Technology Kft. (hereinafter the “Company”).

The procedure promotes:

• preservation of the Company's good reputation;
• respect for human dignity;
• prevention of corruption and misconduct;
• fair and sustainable business operations;
• development of an open and ethical corporate culture.

The requirements of this Code extend to:

• all employees of the Company;
• its executive officers;
• agency and contract staff;
• its suppliers and business partners.

Managers bear heightened responsibility for ensuring ethical conduct and leading by example.

An employer procedure under Section 17 of Act I of 2012 on the Labour Code.

Matters not regulated by this procedure are governed by the legislation in force and other rules applicable to the employment relationship.

Ethical violation: A breach of the Code of Ethics or legislation.

Report: Communication of information concerning a breach of ethical or legal rules.

Reporting person: The person or organisation making the report.

Investigation: Examination of the facts contained in the report.

Conflict of interest: A conflict between personal and Company interests.

Corruption: Giving, requesting or accepting an unlawful advantage for the purpose of exerting influence.

Unlawful advantage: A monetary or non-monetary benefit capable of influencing a decision.

Gift: A benefit, object or service given or received free of charge.

Confidential information: Non-public Company, business or personal data.

Personal data: Information relating to an identified or identifiable natural person.

Harassment: Conduct that violates human dignity or is intimidating or degrading.

Discrimination: Unjustified adverse differential treatment of a person or group.

Company assets: Equipment, information and other resources owned or used by the Company.

Whistleblowing system: The Company's channel for reporting breaches of rules.

Compliance: Adherence to legislation, internal policies and ethical requirements.

Responsible: for decisions, implementation, checking, supervision, coordination and communication.

Cooperates: obliged to cooperate and perform assigned parts of a task.

To be informed: of decisions, implementation and results.

The Company is committed to social responsibility, innovation, sustainable operations and a people-centred corporate culture.

We always strive to act fairly, honestly and in compliance with legislation. This applies to our relationships with colleagues, managers, customers, suppliers and all business partners.

Everyone in the workplace has the right to respectful treatment. We do not accept discrimination, harassment, intimidation or any offensive behaviour. It is important to create an atmosphere where everyone can feel safe and valued.

In our work, we pay attention to quality, safety, compliance with rules and supporting each other. We use Company equipment carefully and for its intended purpose, and strive to ensure working time is actually spent on work.

We treat Company, customer, partner and colleague information confidentially. We do not share data or business information with people it does not concern, and ensure that electronic communication is safe and responsible.

We strive to build honest, fair and reliable relationships with customers, suppliers, authorities and other external partners. We honour agreements and base business decisions on professional considerations rather than personal interests.

Corruption, bribery, and requesting, accepting or offering an unlawful advantage are prohibited. Gifts or invitations may be accepted only transparently and in compliance with the rules. If we are uncertain, we should ask before deciding.

It is important to represent the Company's interests in our work. We avoid situations in which our own interests or those of a family member or another person may conflict with the Company's interests.

Environmental protection is our shared responsibility. We strive to use resources efficiently, reduce waste and environmental impact, and pay attention to sustainable operations in our everyday work.

If we have a question, concern or problem, it is important to raise it. If we see a situation that may contravene legislation, an internal rule or an ethical standard, it must be reported through the appropriate channel.

We all represent the Company, both at work and outside it. It is therefore important that our behaviour, communication and decisions contribute to preserving the Company's good reputation.

The Company treats every employee equally. Discrimination is prohibited, particularly on the following grounds:

• sex;
• age;
• origin;
• nationality;
• religion;
• political convictions;
• marital status;
• disability;
• sexual orientation;
• membership of an employee representative organisation.

The Company applies zero tolerance to all harassing, degrading, threatening or violent conduct. Every employee must report any such incident that comes to their attention.

All verbal, non-verbal or physical conduct that violates the human dignity of the person concerned or creates an intimidating, degrading or hostile environment is prohibited.

The Company does not employ child or forced labour, directly or indirectly, and expects the same of its business partners.

The Company provides a safe and healthy working environment and expects full compliance with occupational safety requirements.

The Company respects employees' rights of association and representation.

The Company respects employees' philosophical and religious beliefs; political agitation in the workplace is nevertheless prohibited.

The Company is committed to sustainable operations. It strives to reduce energy and resource consumption, prevent pollution and use environmentally friendly technologies.

Employees must:

• use Company equipment for its intended purpose;
• protect Company assets;
• manage resources responsibly.

The Company gives particular protection to personal data, trade secrets and confidential information.

Confidential information learned during employment must not be disclosed to third parties or used for private purposes.

Employees must:

• use only lawful software;
• comply with information security rules;
• report suspicious electronic incidents without delay.

Publishing content that damages the Company's good reputation or contains confidential information is prohibited.

Employees must protect the intellectual property of the Company and its business partners.

The Company seeks mutual respect, transparency and fair cooperation with its business partners.

The Company expects its partners and suppliers to meet ethical and legal requirements.

The Company always acts in accordance with competition law.

The Company supports local communities and rejects all corrupt and unlawful sponsorship practices.

The Company applies zero tolerance to corruption, bribery, fraud, embezzlement and all forms of economic misconduct.

Employees must avoid situations in which their personal interests may conflict with the Company's interests.

The following are prohibited:

• offering, giving, requesting or accepting a bribe or any unlawful advantage;
• providing cash, a bank transfer, a gift, a service or any other benefit to obtain a business or official advantage;
• influencing business, procurement, tender or authority decisions for personal interests;
• bribery through an intermediary, consultant, agent or other third party;
• using false, fictitious or misleading invoices, contracts or expense claims;
• providing unjustified gifts, hospitality or other advantages to business partners, officials or decision-makers;
• using inside or confidential information for one's own benefit or that of another person;
• any conduct that may create the appearance of corruption, bribery or a conflict of interest.

Employees may accept only customary business gifts of low value. Any advantage that may affect the objectivity of business decisions is prohibited.

Every business transaction, gift, sponsorship and expense must be recorded accurately, transparently and in a traceable manner.

Every employee and partner is entitled and obliged to report suspected breaches of ethical standards or legislation.

Reports may be made through the Company's whistleblowing system in operation at the relevant time.

bejelentes@vipulsetech.hu

Details of reporting are contained in “INTERNAL WHISTLEBLOWING SYSTEM”, document number VIP-SP-HR-08-01-B.

The Company investigates reports confidentially, impartially and in accordance with applicable legislation.

In cases of serious misconduct, corruption, harassment or other significant breaches, the designated managers act without delay to establish the facts, manage risks and prevent further violations.

The Company conducts regular audits to verify adherence to this procedure and the effectiveness of its compliance system.

A breach of this procedure may result in a warning, disciplinary action, liability for damages, termination of the legal relationship or, if necessary, the initiation of proceedings by the competent authorities.