Code of Conduct & Compliance Policy

Published: 12 August 2026 | Version 1.0

1. Purpose and Scope

Yolk Studio s.r.o. (“Yolk,” “the Company,” “we”) is committed to conducting its business honestly, fairly, and in compliance with applicable law. This policy sets out the standards of conduct expected of everyone who works for or on behalf of Yolk — employees, directors, contractors, and freelancers — and the controls we apply when dealing with clients, suppliers, and other third parties.

This policy applies to all Yolk personnel, in all locations in which the Company operates (currently Czech Republic, United Kingdom, and United Arab Emirates), and to all business relationships entered into on the Company’s behalf.

2. Anti-Bribery and Corruption

Yolk does not offer, give, solicit, or accept bribes, kickbacks, or other improper payments or advantages, whether directly or through a third party, to obtain or retain business or any other improper advantage. This applies regardless of local custom, and regardless of whether the counterparty is a private individual or a public official.

Facilitation payments — small payments to speed up routine government action — are prohibited. Any request for such a payment must be refused and reported to a director without delay.

All expenditure relating to business development, client relationships, or government interactions must be recorded accurately in the Company’s books, with no off-the-books arrangements of any kind.

3. Sanctions and Export Control Compliance

Yolk will not knowingly transact with any individual, entity, or country that is subject to applicable sanctions administered by the European Union, United Nations, United Kingdom, or United States (including OFAC), or that appears on a restricted or denied-party list maintained by those authorities.

Before entering into a new client, supplier, or partner relationship of significance, the responsible director will check the counterparty’s name against the EU Consolidated List of sanctions and the UN Security Council Consolidated List (both free, publicly searchable), and will not proceed if a credible match is found. Screening is repeated periodically for existing relationships of ongoing significance and whenever a relevant list is updated.

As a Czech and EU-domiciled company, Yolk complies with all applicable EU restrictive measures and export control regulations, including those affecting software, technology, and data covered by dual-use export control rules, and will decline any engagement that would put the Company in breach of these obligations.

4. Gifts and Entertainment

Modest, occasional gifts and hospitality exchanged in the ordinary course of business (for example, a working lunch or a branded item of nominal value) are acceptable. Gifts or entertainment must never be offered, given, or accepted where they could reasonably be seen as an attempt to improperly influence a business decision, and must never take the form of cash or cash equivalents.

Any gift or hospitality above approximately €150 in value, offered or received, should be disclosed to a director and, if accepted, may be shared with the wider team rather than kept by one individual.

5. Conflicts of Interest

Personnel must avoid situations where personal interests — financial, familial, or otherwise — could conflict, or appear to conflict, with Yolk’s interests or their duties to the Company. This includes outside business interests, side engagements with Yolk clients or competitors, and close personal relationships with counterparties involved in a Yolk deal.

Any potential conflict must be disclosed to a director as soon as it is identified. Where a genuine conflict exists, the individual will be recused from the relevant decision or engagement.

6. Whistleblowing

Anyone — employee, contractor, client, or supplier — who becomes aware of suspected misconduct, fraud, bribery, sanctions violations, or other breaches of this policy is encouraged to report it. Reports can be made to either director (Peter Vidlička or Branislav Ruščák) directly, or in writing to hello@yolkstudio.com marked “Confidential — Compliance.”

Yolk will not tolerate retaliation against anyone who raises a genuine concern in good faith, even if the concern later turns out to be mistaken. Reports will be handled discreetly and investigated promptly.

7. Business Partner and Third-Party Due Diligence

Before entering into a significant relationship with a new client, supplier, contractor, or business partner, Yolk will take reasonable, proportionate steps to understand who we are dealing with — including confirming the counterparty’s legal identity and ownership where relevant, applying the sanctions screening described in Section 3, and using ordinary commercial judgement to identify any obvious red flags (for example, an unwillingness to identify beneficial ownership, or a request for unusual payment arrangements).

The depth of diligence is proportionate to the size and risk of the relationship — a large enterprise client or a payments-related engagement warrants more scrutiny than a small, low-risk vendor.

8. Anti-Money Laundering and Counter-Terrorism Financing

Yolk will not knowingly process, facilitate, or accept funds connected to money laundering or terrorism financing. Client payments are accepted only through standard, traceable banking channels (bank transfer to the Company’s registered account); Yolk does not accept cash payments of material value or payments from parties unconnected to the contracting client.

Any payment instruction or request that appears designed to obscure the origin or ownership of funds — for example, payment from an unrelated third party, structured payments intended to avoid reporting thresholds, or requests to route funds through personal accounts — will be refused and escalated to a director.

9. Fraud Prevention

Yolk maintains basic financial controls appropriate to its size, including dual director authorization for payments above 100,000 CZK (consistent with the Company’s Articles of Association), segregation of invoicing and payment-approval duties where practicable, and regular reconciliation of accounts. Any suspected fraud, whether internal or external, must be reported immediately to a director and will be investigated.

10. General Code of Conduct

Beyond the specific policies above, everyone acting for Yolk is expected to:

Treat clients, colleagues, and partners with honesty, respect, and professionalism.
Comply with applicable law in every jurisdiction in which Yolk operates.
Protect confidential information belonging to Yolk, its clients, and its partners, and use it only for its intended purpose.
Avoid discrimination or harassment of any kind.
Raise concerns early rather than staying silent, using the whistleblowing channel in Section 6 if needed.

11. Governance and Review

This policy is owned by Yolk’s Board of Directors (Peter Vidlička and Branislav Ruščák) and is reviewed at least annually, or sooner if a material change in the business, client base, or regulatory environment warrants it. Questions about this policy, or requests for a specific client’s due-diligence file, can be directed to compliance@yolkstudio.com.