GENERAL CORPORATE AND ETHICS CODE OF AMTEST d.o.o

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Amtest doo, Kneza Borne 30, Zagreb, Croatia, ID number: 01660063, VAT number: HR95206978963 (hereinafter referred to as the "Company") is aware that provision of a high-quality services is inextricably linked to a compliance with certain ethical rules.

 

Therefore, as an expression of responsibility for ethical business operations and for further development of the Company, this General Corporate and Ethics Code (hereinafter referred to as the "Code of Ethics") was adopted as a document of strategic importance for the Company, the purpose of which is to determine and define the basic legal and ethical standards in relation to all employees of the Company and persons acting on its behalf, and that is, depending on the circumstances and in accordance with the conditions stated below, also applied in relation to the Company's business partners.

 

The Code of Ethics is based on the principles of legality, respect for human dignity, tolerance, honesty, decency, responsibility, expertise, fairness, diligence and humane treatment, whereby these principles, along with responsibility, professionalism and the quality of our services, are the basic values that we implement in all activities and services that our Company provides.

 

By adopting the principles stated in this Code of Ethics, the Company undertakes to respect and apply the standards, guidelines and principles stated in the following legal sources or acts:

 

• The General Declaration on Human Rights, the International Covenant on Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights, and in other international instruments on human rights;
• UN conventions on the rights of the child, and on the elimination of all forms of discrimination against women, and in other relevant conventions and acts;
• fundamental conventions of the International Labour Organization, especially those related to collective association rights and negotiation, prohibition on child and forced labour, and ban of discrimination in relation to employment;
• United Nations Global Compact (UNGC) and OECD Guidelines, and relevant anti-corruption principles,
• Rio de Janeiro’s Declaration on environment and development, the Paris Climate Accords and other relevant climate agreements, conventions, protocols, and acts;
• all national and other relevant laws and regulations that apply in the countries where the Company's business activities are carried out, as well as in business practices during the performance of activities that create ethical standards and patterns of behaviour of all employees and associates of the Company in relation to clients and business partners, and in their mutual relations.

 

Terms used in this Code of Ethics, that have a gender meaning, shall refer equally to men and women.

 

1. Basic values of the Code of Ethics

 

Integrity

We fulfill our goals honestly, correctly, and responsibly, with full and essential respect for rules, professional ethics and in the spirit of signed contracts and assumed obligations.

 

Excellence

We have set the goal of constant improvement and advancement, looking ahead, anticipating challenges, cultivating creativity that strives for innovation, and we recognize and reward the achieved performance.

 

Transparency

We advocate that transparency be the basis of our business, to enable all our employees, clients, and business partners to make independent and informed decisions.

 

Equality

We undertake to remove all forms of discrimination from our behaviour and business and to respect differences in personal or other characteristics of each individual.

 

The value of the individual

The value of each individual is the guideline that leads us in our actions: we use listening and dialogue as instruments to constantly improve relations with all our employees, clients and business partners.

 

Responsibility when using sources

Our goal is to carefully use all sources and resources, and we encourage behaviour that achieves optimization in terms of their use.

 

2. Respect for fundamental human rights, ethical and moral standards

 

Our Company emphasizes respect for the protection of human rights, the creation of fair and safe working conditions, responsible and professional management, all in strict accordance with the general moral and ethical principles stated in international and national sources, and in this Code of Ethics.

 

3. Compliance with the rules of business competition

 

We follow the principles of general business ethics, business practices, and we respect the general rules of transparent market competition, in order to create long-term prosperity and a healthy and sustainable business environment.

 

4. Anti-corruption policy

 

When dealing with business partners, we strictly separate the interests of our partners from the personal or financial interests of the employees of both parties.

 

We pay special attention to the following:

• to prohibit the provision of personal benefits to government or public officials in any form (monetary, physical, or otherwise) by our employees or our business partners and/or their employees in order to achieve benefits for each other and/or for third parties,
• to prohibit the offering, promising, approving and/or giving or receiving personal benefits in any form (monetary, physical, or otherwise) that would arise from business or other relationships of the Company and/or in relation to the Company, that could influence the business decisions of any party.

 

 

The interests of the Company's employees must not come into conflict with the obligations they have in the Company or that the Company has towards its clients and business partners, and the Company's employees are obliged to separate their private interests from business interests when performing work in the Company or for the Company.

Performing activities or certain actions when there is a possible conflict of interest must be approved with the prior written consent of the Ethics Commissioner or another person designated for that purpose by the Company.

 

Gifts, business representation or similar benefits are often accepted as customary part of a business life. However, it is necessary to ensure that their value does not cause a conflict of interest and threatening the ethics of the business relationship.

 

Therefore, the general rule is that employees are not allowed to accept gifts or other benefits, except those of a symbolic value, and employees may not, regardless of the amount, receive money or similar equivalents under any circumstances. The detailed rules of the anti-corruption policy will be determined by the Company in its internal act.

 

5. Responsible management of the Company's property, business finances and procurement process

 

Employees are obliged to protect the completeness, integrity, and security of the Company's property.

 

Employees who work in asset management, financial affairs and procurement affairs are also obliged to adhere to additional ethical principles according to specific professional standards and laws and regulations.

 

Employees are obliged to avoid all attempts to influence the making of objective and impartial decisions, and to act responsibly and with a due care in the performance of their duties.

 

Procurement of goods, services and works are performed according to the principle of ensuring the expected value for the money, in accordance with the provisions of the applicable regulations.

 

6. Prohibition of discrimination

 

Our Company hereby also declares zero tolerance towards any manifestation of discrimination based on age, nationality, ethnic or social affiliation, linguistic and racial origin, political or religious beliefs or preferences, trade union affiliation, disability, education, social position, gender, marital or family status, sexual orientation or on any other basis.

 

7. Work procedures and reputation

 

The good reputation of the Company, and the trust of our clients and employees, are the most important values in the business environment. All work procedures are carried out at a highly professional level in order to maintain a good name and eliminate reputational risk for our clients and business partners, and at the same time maintain the good reputation of our Company.

 

We are aware of our obligations towards third parties and clients, and therefore we monitor the fulfillment of these goals in relation to our associates and our cooperating parties, which is a prerequisite for good and long-term beneficial cooperation.

 

7.1. Principles of behaviour in relation to suppliers

 

Listening and dialogue

 

We consider that behaviour based on listening and exchange of ideas with our suppliers encourages continuous improvement of these relations, and makes them stronger and creates value for both sides through:

• trust-based mindset, which gives suppliers a proactive role and encourages them to register issues that require finding a common solution;
• measuring the level of satisfaction of our suppliers and determining the areas that we need to improve, with respect to transparency, communications, and respecting payments-deadlines.

 

Transparency and Equality

 

We believe that a clear and transparent attitude contributes to maintaining long-term relationships with our suppliers. We are convinced that the integrity represents a fundamental basis for this relationship and therefore:

• we choose our suppliers based on a clear and documented criteria using objective and transparent procedures;
• we adhere to business policies that relate to suppliers based on the maximum correctness, above all when negotiating, executing, and performing contracts, that, among others, avoids even a potential conflict of interest;
• in certain cases when there is a need for specific professional consulting services from our Company, our decisions are based on a criteria of expertise and competency, and we avoid conflict of interest, even a potential ones;
• we establish business relationships with suppliers who demonstrate their sensitivity to the matters of a corporate and social responsibility;
• we guarantee equality of opportunity when choosing suppliers and business partners, whereby we take into account their compatibility and capabilities with regard to the size and needs of our Company, and we advocate the establishment of partnership relations with companies that are at the same time our suppliers and/or clients;
• we advocate the contracts concluded with our suppliers to be fair, above all in terms of payment terms and compliance with all relevant regulations.

 

 

7.2. Principles of ethical behaviour of employees and associates of the Company

 

The mutual relations of the Company's employees, meaning all forms of their mutual communication, are based on a mutual respect, trust, cooperation, decency, responsibility and patience.

Equally, relations between employees at different levels of responsibility must be based on mutual loyalty, respect and the principle of confidentiality.

 

All employees are obliged to act impartially and decently, respecting the personal dignity of each employee. The Company does not approve the use of position or authority within the organization to achieve any goals that are outside the scope of their function.

 

The Company's employees are expected to cooperate with their superiors and act in accordance with the operational guidelines received from them, avoiding unprofessional actions and behaviours.

 

Employees with special authorizations are responsible for all employees within their organizational unit, and they should gain their trust based on their own exemplary behaviour, performance, openness, and social competence.

Their task is to provide clear, ambitious, and realistic goals, with the maximum possible responsibility and independence of workers in their work. In their actions, they are obliged to adhere to the principle of clarity of criteria regarding the evaluation of employees.

 

Employees are obliged to create a workplace-atmosphere that will be in accordance with the abovestated values and to cooperate as a responsible team, constantly improving interpersonal relations.

 

Incivility, abuse, and discrimination based on age, gender, religious belief or political opinion or preference, ethnic or national affiliation, linguistic or racial origin, social position, marital or family status, education, disability, sexual orientation or any other basis, circumstances or reasons, are prohibited and represent a serious threat to the dignity of the individual.

 

In accordance with all the above, employees and associates of the Company in their activities are obliged to act in such a way that they:

• respect applicable laws and regulations,
• follow the principles of business ethics so that they provide their services and perform their duties honestly, responsibly and pay attention to maintaining a high professional level,
• in the performance of its business activities, the Company and its employees consistently avoid activities that could damage the trust of the client in relation to the Company, and distance themselves from the practice of unfair competition,
• during their work, the Company's employees behave in a way that does not damage Company's reputation, refraining from disseminating confidential information outside the work environment and avoiding activities aimed at creating a conflict of interest between them and the Company,
• know and respect the regulations on the protection of personal data, perform their work in accordance with this, and at the same time respect business secrets and confidentiality, even after the termination of their employment or other relationship with the Company,
• they are aware that their behaviour always represents the Company and its mission, so in their personal life and outside of working hours they take into account that they do not act in violation of the applicable laws, generally applicable principles of good behaviour and this Code of Ethics.
• do not abuse information or material resources of the Company for their personal benefit, and in their work they always act in such a way as not to damage the Company and its good reputation,
• avoid all activities that create a conflict of their own interests with the interests of the Company.

 

7.3. Principles of behaviour in relation to employees

 

Respecting an individual

 

We believe that respecting the personality and dignity of each employee is the basis for development of working environment that is based on the mutual trust, loyalty and contribution of each and every employee, and therefore:

• we adopt employment procedures and personnel-management procedures that are based on honest and consistent attitude towards everyone, preventing favouritism, abuse, and discrimination on any ground;
• we guarantee equal opportunities for professional growth and development, access to training programs, courses for knowledge-renewal and assignment of functions, from the very stage of candidate-selection;
• we give to all our employees a possibility to express individuality and creativity in their work;
• we strive to achieve excellence, both in quantitative and in qualitative view;
• we respect professionalism and dignity of each and every employee;
• we address the maximum attention to defining the goals, enabling their better understanding and acceptance, in order to encourage fair and transparent behaviour in business;
• we create objective and transparent incentive-systems who reflect realistically achievable goals;
• we facilitate the work by simplifying the products, procedures and communication channels,  and we keep health and safety of our employees by adopting and utilizing effective measures;
• we encourage policies that facilitate the private and professional life of all our employees, prioritizing flexibility and implementing initiatives to balance work and personal commitments and  needs, aware of the fact that this balance represents a foundation that benefits each and every employee;
• we estimate success of the person performing responsible positions by taking into consideration their conformity with ethical principles that they apply in relation to employees.

 

Valuation and motivation

 

In the intention to make the honesty, equality and merits as foundations for assessment, evaluation, motivation and career-development of our employees:

• we recognize that the set of social, organizational, and technical skills of each employee represents our core strategic resource;
• we adopt systems for assessing the behaviour, skills, knowledge and potential of our employees according to criteria of transparency, merit-evaluation and respecting differences in order to strengthen motivation and to assign fair rewards so as to encourage achieving excellence in the results;
• we are developing training-programs directed on individual needs in belief that listening the needs of our employees is necessary for defining the training-process;
• we provide to each person conditions necessary for it to perform its job in the best way, by encouraging permanent skills-improvements, developing abilities for teamwork, and by contributing to achieving business objectives;
• we ask our employees to cooperate in the responsible use of all resources that they use in own work.

 

Listening and dialogue

 

We consider listening and dialogue as foundations that create confidence and therefore:

• we encourage the strategic role of internal communication, and we base our communication on the criteria of accuracy, completeness, simplicity          and transparency;
• we develop instruments for sharing information and encourage the exchange of experiences within the Company;
• we undertake to develop, in those who have certain responsibilities, a special sensitivity and ability to perceive the needs of employees;
• we launch initiatives to establish solidarity in order to help colleagues who have found themselves in difficulties, and in order to achieve socially significant goals.

 

8. Ensuring the security of information and data

 

Complete protection of the security of all documents and data in written and electronic form is achieved by appropriate technical and organizational means available to the Company, in order to prevent unauthorized access to such data and information and their unauthorized processing, misuse, loss, theft or accidental deletion.

 

All our hardware and software solutions that perform the function of storing or managing data in electronic form are protected against possible attacks and misuse at the appropriate technological level, and have backup copies.

 

All electronic data transmissions are subject to strict rules for protected and secure transmissions using modern tools designed to secure data transmission.

 

9. Protection of personal data

 

All personal data that we use or come across in our business is subject to personal data protection regulations. Compliance with the requirements of the applicable legislation is regularly monitored and controlled. To the greatest extent possible, we respect the rights of persons whose personal data we collect and process.

 

10. Confidentiality

 

One of our highest priorities is to preserve the secrecy of all contractual terms and entrusted or established facts related to the performance of our activities, in order to maintain impartiality and loyalty towards our clients and all other third parties.

 

We respect data confidentiality and privacy of our clients, our employees and other business partners. We work in accordance with applicable laws, guidelines, and always apply and maintain an appropriate level of confidentiality and privacy.

 

11. Environmental protection policy

 

Like all business entities, the Company affects the environment with its business activities, and therefore we have created our own strategy to eliminate negative impacts and for use environmentally friendly technologies.

 

Accordingly, we decline to waste resources, and we oblige to take into consideration the influence of our decision to the environment, and in this regard:

• we guarantee full and comprehensive compliance with international and national regulations on environmental protection;
• we are continuously looking for new and effective solutions in the field of environmental protection;
• we undertake to apply the best practices in the field of environmental responsibility, and we strive to conscientiously use the resources necessary for our business by implementing the environmental management system and the system for progressive improvement of the energy efficiency throughout our business activities;
• we strive to continuously improve the environment, by monitoring the environment-data and by sensibilisation of our employees;
• we are aware that our responsibility towards the environment and the society extends to the entire supply chain and for this reason we want to motivate our suppliers and subcontractors to apply the policies of environmental protection and policies of protection of human rights and employee’s rights;
• we support suppliers whose business is based on the ecological and social sustainability and who apply the necessary measures and instruments to reduce the negative impacts of their business on the environment;
• we encourage our suppliers to adopt responsible attitude and to develop awareness on ecological, social, and ethical risks and possibilities that arise from their business operations.

 

12. Control of compliance with the Code of Ethics

 

Every employee, client or business partner of the Company could report business and behaviour that is contrary to the provisions of this Code of Ethics.

 

Information about the applicant shall be considered as a confidential information, and the submission of an application, especially by an employee of the Company, in good faith, cannot be a reason for its sanctioning.

 

Applications are submitted to the Ethics Commissioner, as a person appointed for this purpose by a special written decision of the Company's Management Board, in one of the following ways: (i) by filing the application directly at the seat of the Company, or (ii) by registered mail to the seat of the Company, or (iii) electronically to the e-mail address , which is published on the Company's website.

 

The written notification or complaint must indicate that it contains certain complaint, and should contain a detailed description of the event/situation, and if possible, evidence from which it transpires that the complaint is founded. If the provided description of the event/situation and/or evidence is incomplete, the Ethics Commissioner may request from the applicant to amend the complaint, if possible.

 

The Ethics Commissioner is responsible for dealing with complaints, and after carrying the procedure, it submits a report to the Company's Management with its reasoned findings and opinion, and at the same time proposes the Company's Management to make an appropriate decision.

 

13. Entry into force

 

This Code of Ethics shall be published on the Company's website, through the Company's internal network, and on the bulletin board, and will enter into force within eight days after the date of publication.

 

All amendments to this Code of Ethics will be valid and binding only if they are prepared in writing and published in the prescribed manner.

 

 

If any provision of this Code of Ethics is or would become invalid due to it being contrary to the laws and regulations, that are and/or could become binding after the adoption of this Code of Ethics, this shall not affect the validity of the Code of Ethics in its entirety.

 

In such a case, the Company will amend the Code of Ethics as soon as possible in a way that the invalid provision shall be replaced by a valid one, considering the meaning and purpose of the replaced provision.           

 

With the entry into force of this Code of Ethics, the previous internal acts of the Company that regulate the matter regulated by this Code of Ethics in a different way (compared to the conditions of this Code of Ethics) cease to be valid in their entirety.

 

 

In Zagreb, 01.01.2024

 

For the Company

Vanja Mutvar, director