At Dental Studio Den Haag, ethical behavior, honesty, reliability, and integrity are core values that guide our internal operations, client interactions, and external relations. Protecting the reputation of Dental Studio Den Haag is of the utmost importance. This requires a culture rooted in transparency, integrity, and ethical conduct. Regardless of our individual roles, we are all responsible for upholding these ethical and legal standards.

This Code of Conduct (the “Code”) outlines these principles for everyone who works at, with, or on behalf of Dental Studio Den Haag, regardless of their contractual relationship (the “Employees”). The Code applies explicitly to them.

For the purposes of this document, “Dental Studio” refers to Dental Studio Den Haag B.V., located in The Hague and registered with the Dutch Chamber of Commerce under number 96861754.

The Code is structured around sixteen key areas relevant to Dental Studio Den Haag’s business operations. It provides clear guidelines on integrity and ethical behavior in professional conduct. It governs our decisions and actions, not only in business dealings but also in how Employees behave during their work. Moreover, the Code plays an essential role when deciding to initiate or maintain relationships with clients, suppliers, or third parties.

The Code sets out the minimum behavioral standards and is not exhaustive.

1. Company Culture at Dental Studio Den Haag

Dental Studio Den Haag operates with the ethos of a three-star restaurant—every client is treated with equal care and respect, whether they opt for a lavish or modest treatment. All clients can expect exceptional quality and outstanding service, which are the foundation for loyalty and repeat visits.

Service, at its core, is about meeting client needs—whether by offering products or services in exchange for payment, solving problems, or addressing complaints. When issues are resolved quickly and complaints are handled effectively, we speak of excellent service. And excellent service boosts client satisfaction, leading to higher revenues and allowing the company to invest in improvements and growth.

To ensure high levels of client satisfaction and loyalty, Dental Studio Den Haag upholds the following core values:

• Anticipate people’s needs before they express them;
• Support one another (teamwork);
• Acknowledge the feelings of others (empathy);
• Respect the dignity and privacy of everyone (courtesy);
• Clearly explain what is happening (communication).

2. Legal Compliance

Dental Studio Den Haag is committed to complying with all applicable laws and regulations and expects the same from all Employees. This includes all legislation, regardless of where activities are carried out or where affiliated entities are based.

Healthcare-specific legislation includes:

1. Medical Treatment Agreement Act (WGBO)
2. Personal Data Protection Act
3. Individual Healthcare Professions Act (BIG)
4. Healthcare Institutions (Quality) Act
5. Client Care Sector Complaints Act
6. Working Conditions Act (Arbowet)
7. WIP Guidelines
8. Radiation Protection Decree
9. Nuclear Energy Act
10. Medicines Act

General legislation includes (based on Dutch Criminal Code):

1. Bribery of public officials (Art. 177)
2. Forgery (Art. 225)
3. Theft (Art. 310)
4. Extortion (Art. 317)
5. Embezzlement (Art. 321)
6. Embezzlement in official capacity (Art. 322)
7. Fraud (Art. 326)
8. Private-sector bribery (Art. 328ter)
9. Money laundering (Art. 420bis)
10. Insider trading and violations of the Financial Supervision Act

3. Fair Competition

Dental Studio Den Haag embraces fair competition and supports the development of appropriate antitrust legislation. All operations and Employee conduct must align with principles of fair competition and applicable regulations.

4. Confidentiality and Data Protection

Employees must treat all company information as confidential and may not share company or client information with third parties without explicit consent from their direct supervisor and the client. This also applies to confidentiality clauses in employment contracts and other agreements. Confidentiality remains in force even after employment ends.

Dental Studio Den Haag safeguards the privacy and security of personal data relating to clients, Employees, suppliers, and other business partners. Personal data must only be used for legitimate business purposes and in accordance with applicable laws. Any suspected data breach must be reported immediately.

5. Conflicts of Interest

Employees are expected to act in the best interest of Dental Studio Den Haag and avoid any conflicts of interest, including situations that may appear as such.

Employees must not engage in business transactions involving clients or suppliers where they or their family members have a financial or management interest, unless expressly authorized by management. Any potential conflict must be reported to the Employee’s supervisor. In cases of doubt, consultation with a supervisor is mandatory.

6. Gifts and Entertainment

As a general rule, Employees may not accept or offer gifts or entertainment of more than nominal value (maximum €50) from or to clients, suppliers, or others with whom Dental Studio Den Haag has a business relationship.

Cash gifts or payments are never permitted without explicit management approval.

7. Company Assets and Resources

Employees are responsible for the appropriate use, protection, and preservation of Dental Studio Den Haag’s assets, including confidential information provided by clients and partners. These resources may only be used to further the company’s goals and not for personal gain.

Any suspected misuse must be reported to the supervisor.

8. Record Integrity

Accurate, fair, and complete record-keeping is essential for reliable reporting to management, regulators, the Health Care Inspectorate, shareholders, creditors, and authorities. All official records must reflect the truth and comply with applicable laws. Misleading transactions via intermediaries or concealed payments are prohibited.

9. Bribery and Corruption

Dental Studio Den Haag competes based on the quality of its services. Any form of bribery is strictly prohibited, whether involving clients, suppliers, government officials, or internal staff.

10. Political Contributions and Insider Trading

Dental Studio Den Haag does not support political parties or candidates and prohibits Employees from using company resources for political purposes.

Though not publicly listed, Dental Studio Den Haag may engage in transactions with listed companies. Employees privy to non-public information about such companies may not trade in their securities until that information becomes public.

11. Employee Relations

Dental Studio Den Haag promotes equal opportunity and a respectful work environment. Discrimination based on race, religion, gender, origin, or any legally protected status is not allowed. Sexual harassment will not be tolerated.

12. Alcohol and Drug Policy

The use of alcohol or drugs on Dental Studio Den Haag premises is strictly prohibited. Employees under the influence will be denied access and may be removed from the workplace.

13. External Communications

Only authorized Employees may communicate with the inspectorate, media, suppliers, or other third parties on behalf of the company. Those with such authority must remain within their limits and not attempt to bypass or exceed them.

14. Violations

Violations of this Code may result in disciplinary action, including immediate termination of employment or contract. Dental Studio Den Haag reserves the right to take appropriate measures depending on the circumstances.

15. Reporting Misconduct

Dental Studio Den Haag fosters a culture of trust and responsibility. Employees who encounter unethical or unlawful behavior are encouraged to report it in good faith. Reports can be made—anonymously if preferred—to HR or management. It is every Employee’s duty to report violations.

16. Final Provisions

This Code outlines the primary ethical expectations for all Employees. While it cannot cover every possible legal or ethical dilemma, those with questions or in need of guidance should consult their supervisor, the HR department, or company management.