Code of Ethics

Venture CO Group · July 2026 · Applies to employees, contractors and partners

Venture CO Group | Effective date: July 2026 | Version 1.0

Purpose and Scope

This Code of Ethics (“the Code”) sets out the standards of conduct that define how Venture CO Group does business. It reflects who we are: a company built on trust, working across IT services, marketing, PR and creative work, motion picture and streaming production, esports events, business and NGO consultation, SaaS products, and outsourced sales — in Hungary and the EU, the United Kingdom, Uzbekistan, the United States, and Turkey.

The Code applies to everyone who works for or with us:

Employees of Venture CO Group, at every level, including management;
Contractors and freelancers engaged on our projects, who form an essential part of our delivery model;
Business partners, suppliers, and subcontractors, whom we expect to uphold standards consistent with this Code when working on our behalf.

No document can anticipate every situation. Where the Code is silent, we expect sound judgment guided by its principles. Where local law sets a higher standard than the Code, local law prevails; where the Code sets a higher standard than local law, the Code prevails.

Our Values in Conduct

Our values are not wall decorations — they are decision-making tools:

Integrity. We do the right thing even when no one is watching, and especially when it costs us something.
Respect. We treat colleagues, clients, audiences, and communities with dignity, regardless of who they are or where they are.
Craftsmanship. We deliver work we are proud to sign, and we are honest about what we can and cannot do.
Accountability. We own our decisions, our mistakes, and their consequences.
Openness. We speak up, we listen, and we welcome being challenged.

Speak-Up Culture and Non-Retaliation

We can only fix what we know about. Anyone — employee, contractor, partner, or third party — who has a concern about a possible violation of this Code, the law, or our policies is encouraged to raise it.

How to report: Write to contact@ventureco.group. Reports are received by management, handled confidentially, and shared only with those who need to know in order to investigate. Reports may be made in English or Hungarian. Where permitted by law, concerns may be raised anonymously.

Our commitments:

Every report is acknowledged and reviewed.
Investigations are conducted fairly, promptly, and as confidentially as circumstances allow.
Retaliation is prohibited. No one who raises a concern in good faith, or who participates in an investigation, will suffer any adverse consequence for doing so — even if the concern is not ultimately substantiated. Retaliation is itself a violation of this Code and will be treated as serious misconduct.

Knowingly making a false or malicious report is also a violation of this Code.

Integrity in Business

Anti-Bribery and Corruption

We do not offer, promise, give, request, or accept bribes, kickbacks, or improper advantages of any kind — directly or through intermediaries — anywhere we operate. This includes facilitation payments (small payments to speed up routine government actions), which we do not make even where local practice may tolerate them. We comply with applicable anti-corruption laws in all our markets, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and Hungarian and EU anti-corruption legislation. Third parties acting on our behalf — agents, resellers, event partners, sales subcontractors — are held to the same standard.

Gifts and Hospitality

Modest, occasional gifts and hospitality can be a legitimate part of building business relationships. They cross the line when they are intended to influence a decision, or could reasonably appear to. Our rules:

Never give or accept cash or cash equivalents.
Gifts and hospitality must be reasonable in value, infrequent, transparent, and appropriate to the occasion.
Extra caution applies to anything involving public officials — when in doubt, decline and consult management.
Anything that would embarrass us if described on the front page of a newspaper should not be given or accepted.

Conflicts of Interest

A conflict of interest arises when personal interests — financial, family, or other — could interfere with objective judgment on behalf of Venture CO Group. Examples include outside engagements with competitors or clients, personal financial stakes in suppliers, or hiring or contracting with close relatives. Conflicts are not always avoidable, but they must always be disclosed to management promptly so they can be managed transparently. Undisclosed conflicts are the problem; disclosed conflicts usually have solutions.

Fair Competition

We win business on the merits of our work. We do not fix prices, rig bids, allocate markets, or exchange competitively sensitive information with competitors. We do not obtain competitor information through deception or misrepresentation, and we do not disparage competitors dishonestly. We comply with EU, UK, US, and local competition laws in every market where we operate.

Respect for People

Anti-Discrimination and Anti-Harassment

We do not tolerate discrimination or harassment of any kind — based on gender, age, ethnicity, nationality, religion, disability, sexual orientation, family status, political opinion, or any other characteristic protected by law. This applies to hiring, assignments, compensation, and everyday interactions, and it applies equally at client sites, at events we produce, on film sets, and in online channels. Harassment includes unwelcome verbal, physical, or visual conduct that creates an intimidating, hostile, or offensive environment.

Diversity and Inclusion

We work across multiple countries, cultures, and languages, and we consider that a strength. We aim to build teams — including our contractor network — that reflect diverse backgrounds and perspectives, and to give everyone a fair opportunity to contribute and grow.

Health and Safety

Everyone working with us is entitled to a safe working environment. This matters particularly at physical productions and live events — film shoots, esports tournaments, conferences — where we plan for safety, comply with venue and local regulations, and empower anyone to stop work that appears unsafe.

Protecting Information

Confidentiality

We protect confidential information belonging to Venture CO Group, our clients, and our partners — before, during, and after an engagement. Confidential information is used only for its intended purpose, shared only on a need-to-know basis, and never used for personal benefit.

Data Protection

We handle personal data lawfully, fairly, and transparently, in compliance with the EU General Data Protection Regulation (GDPR), the UK GDPR, and applicable data protection laws in our other markets. We collect only what we need, keep it only as long as necessary, and secure it appropriately.

Client Data

Client data is a trust we hold, not an asset we own. We access client systems and data only within the scope agreed, follow the client’s security requirements, and report any suspected incident affecting client data without delay.

Intellectual Property

We respect intellectual property — our own, our clients’, and third parties’. We use properly licensed software, footage, music, fonts, and assets in our creative and production work, honor contractual IP terms, and protect our own IP and that entrusted to us.

Responsible Technology

Ethical Use of AI

We use artificial intelligence tools to work better — never to deceive. When AI contributes materially to deliverables, we remain accountable for accuracy and quality, review outputs with human judgment, respect confidentiality when using AI tools (no client data in unapproved tools), and comply with applicable AI regulations, including the EU AI Act. We do not use AI to create misleading content, deepfakes, or manipulated media presented as authentic.

Security

Everyone is responsible for cybersecurity. We use strong authentication, keep devices and software updated, follow our access control practices, and report suspected security incidents immediately to contact@ventureco.group. Security is a condition of working with client systems, not an optional extra.

Community and Environment

As a services company, our environmental footprint is modest but not zero. We commit to:

Minimizing travel where remote collaboration serves the client equally well;
Reducing waste and energy use at events and productions we organize;
Preferring suppliers with credible environmental practices;
Supporting the communities where we operate, including through our NGO consultation work, where we bring professional skills to civil society organizations.

We report on our sustainability efforts honestly — no greenwashing, no inflated claims.

Accurate Records and Anti-Money-Laundering Basics

Our books and records must be accurate, complete, and timely. No off-the-books accounts, no false or misleading entries, no undisclosed side agreements. Expense claims, timesheets, and project reporting reflect reality.

We take basic precautions against money laundering: we know who our clients and partners are, we are alert to red flags (unusual payment structures, requests to route funds through unrelated third parties or countries, payments in cash where unusual), and we do not accept funds we suspect derive from criminal activity. Concerns are escalated to management before proceeding.

Sanctions and Trade Compliance

Operating across Hungary and the EU, the UK, Uzbekistan, the US, and Turkey means multiple sanctions regimes apply to us. We comply with applicable EU, UN, UK, and US sanctions and export control rules. Before entering significant new business relationships — particularly in newer markets — we screen counterparties against applicable sanctions lists and consider whether goods, software, or services we provide are subject to export restrictions. When sanctions rules across jurisdictions appear to conflict, we pause and seek advice rather than guess.

How We Make Decisions: The Ethics Test

When facing a decision the Code does not explicitly answer, ask three questions:

Is it legal? In every jurisdiction it touches?
Is it consistent with our values? Would it survive an honest reading of this Code?
Would it stand public scrutiny? Would you be comfortable if it were reported in the press, or explained to a client, a colleague, or your family?

If the answer to any question is “no” — or if you are not sure — stop and ask. Write to contact@ventureco.group or speak with management. Asking first is always acceptable; asking forgiveness is not a strategy.

Consequences of Violations

Violations of this Code are taken seriously. Depending on severity, consequences may include coaching, formal warning, termination of employment or contract, termination of the business relationship, and — where the law is broken — referral to authorities. The same standards apply regardless of seniority or commercial value: no client, deal, or deadline justifies violating this Code.

Governance and Annual Review

The management of Venture CO Group owns this Code, ensures it is communicated to all employees and contractors at onboarding and periodically thereafter, and oversees investigations under it. The Code is reviewed at least annually and updated as our business, markets, and applicable laws evolve. The current version is published on our website.

Venture CO Group 1036 Budapest, Pacsirtamező utca 65. VI. em. 4., Hungary contact@ventureco.group

Adopted July 2026. Questions about this Code may be directed to contact@ventureco.group.