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Policy on Ethical Standards and Business Conduct SOFTICO S.R.L.
- MISSION AND VALUES
Mission of SOFTICO S.R.L. (hereinafter – the “Company”) consists in the implementation of European and global management standards in business processes, as well as in the Company’s desire to comply with the requirements of anti-corruption legislation and the highest business standards of economic activity.
The values of our Company are:
Professionalism and respect. Our team consists of high-level professionals dedicated to their work, whose aim is to provide the best quality services to our clients. In our work, we respect and consider both the interests of our clients and employees.
Leading by example
We must show by our own behaviour what it means to act with integrity and in line with the applicable laws and this Policy.
Responsibility
We take full responsibility for the quality of the products/services we provide to our clients.
Unity and teamwork
Our team is our most important and valuable resource, which is why our joint efforts allow achieving the better results.
Transparency and integrity
In our day-to-day activity, we stand by the highest standards of integrity and transparency. We also declare our team’s compliance with the laws and regulations which are applicable to our business.
- INTRODUCTION
Objectives of the Policy
The Policy sets Company’s expectations to the behaviour of our employees in their daily work.
Who Must Follow the Policy
The policy applies to all employees of the Company. We also count on compliance with the Policy by all our contractors who may be involved in the performance of work/providing services to the Company.
Raising Concerns and Asking Questions
When in doubt in a difficult ethical situation, ask questions and initiate discussions of legal or ethical issues and issues related to the quality of work and the work environment. You can discuss any issue with your immediate supervisor, the Company’s management, the compliance officer and the legal department. You can also ask such questions and raise concerns – anonymously – by emailing compliance@softico.tech
The Company prohibits the use of any negative influence measures against any employee who reports a violation or participates in an investigation of a possible violation of our policies or the law.
If you believe that you or your colleagues are being retaliated against, please contact the Compliance officer. Не will take all necessary and reasonable measures to solve this issue.
Violations of the Policy
Breaches of the Policy or the law can result in severe consequences for the Company and our employees, ranging from reputational damage to civil and criminal law liability, and/or sanctions by regulatory authorities. The Company takes every report of a violation seriously and will assess a reported violation in an impartial manner in accordance with this Policy and the law to determine next steps. Where appropriate, the Company will take disciplinary action against employees breaching the Policy or doing other illegal activities, up to termination of employment.
Failure to comply with the Policy by our counterparty may result in the termination of our cooperation with him.
- COMPLIANCE WITH LAWS AND REGULATIONS
Integrity and Anti-Bribery
The Company is conducting its business in a fair and transparent manner. This is achieved through implementation of policies and procedures to prevent unethical behaviour and conducting regular employee trainings.
The Company has zero tolerance to corruption and fraud. Company employees must not pay, solicit, arrange or accept illegal benefits, including facilitation payments and illegal benefits intended for their own benefit or that of their family, friends, associates or acquaintances. Empoloyees also must not commit, participate in, or facilitate the commission of any corruption offense, whether in the context of their work activities or outside, and must not act in a manner that may be considered as a corrupt behaviour.
Interaction with Public Officials
Our basic principle in the relations with the public officials is to act in a lawful and transparent manner, and in accordance with the mission and values of the Company. We do not give illegal benefits to public officials or their representatives or related persons to receive any unlawful benefits for our business.
Conflict of Interest
Employees should always avoid conflict of interest – situations when their personal interests interfere with the performing professional duties in the interests of the Company. Below are some examples of the conflict of interest:
- using information obtained through performance of official duties for the purpose of obtaining personal gain;
- transferring information on the Company’s contractors to third parties who are not authorized to receive such information;
- hiring close relatives and friends in personal submission or facilitating their promotion;
- assisting in the establishment of business relations with contractors where the employee of the Company holds a position in the governing bodies or owns a share in the authorized capital, etc.
You should inform the compliance officer if there is a potential possibility of a conflict of interest arising, or if you became aware about the actual or potential conflict of interest involving Company emloyee.
Gifts and Entertainment
Accepting or providing gifts, entertainment, and other business courtesies can easily lead to a conflict of interest or even constitute an illegal benefit if they aimed at inducing person’s action or decision.
Some non-cash gifts, business meals and entertainment with clients, as well as invitations for local events can be appropriate. Before accepting or providing any gift in relation to Company’s activities, you should obtain an approval of the compliance officer or your manager. In case it is not possible to obtain such approval before accepting the gift, the approval must be received immeditely after accepting the gift.
Corporate Social Responsibility and Charitable Contributions
We do our best to contribute to society in innovative and safe ways. We also encourage our employees to provide volunteer services in order to help the communities where we live.
Any charitable contribution or other social investment by the Company must be fully recorded in the Company’s books. Before providing any charitable contribution on behalf of the Company, you should obtain an approval of the compliance officer or your manager. Any charitable contribution requested by a public official must undergo more intense scrutiny as they can be (or can be seen as) an illegal benefit in disguise.
Political Activities
Contributions to political parties, public officials or candidates for public office on behalf of the Company are expressly prohibited.
Antitrust and Unfair Competition
The Company takes its obligations in the fields of antitrust, unfair or restrictive trade, a monopoly on the market, cartel laws, competition and price discrimination very seriously. We do not agree with competitors on prices, where to sell, or on other competitive matters.
Communication with Public
Our main value is the integrity and transparency of our business. For this reason, communication with the public is very important for our Company. We do our best to ensure that only authorized employees can speak on behalf of the Company and that their words are true and provided in a timely manner.
Before giving an interview or publishing any Company-related information in media, you should obtain an authorization from the Legal department.
Interaction with Business Partners
The Company deals only with business partners who have high ethical standards and share our commitments and values. We always check the information about our potential and existing business partners and their qualifications.
Protection of Company Assets
Every employee is responsible for the protection of Company assets against loss, theft or another misuse. All of the Company’s assets must only be used for legitimate business purposes.
The Company may make personal use of Company assets by employees on an occasional and limited basis only as long as Company’s relevant policies are followed, there are no measurable increased costs as a result of the use. Use of Company assets for personal gain is prohibited.
Equal Opportunity for Employees
We treat our employees equally and provide equal employment opportunities to everyone. We do not tolerate any discrimination in the workplace based on the gender, age, racial background, marital status, education, religion, sexual orientation, medical conditions, place of origin, political affiliation or other factors.
The possibility of promotion depends only on employee’s qualification, level of expertise and professional competence.
Employee Non-Discrimination
In their dealings with colleagues and third parties, employees must show respect and tolerance for varied cultures, beliefs and backgrounds. Employees must avoid behaviour that constitutes harassment, sexual harassment, bullying or abuse of authority, or that could be perceived by others as such. Such prohibited conduct may include offensive jokes, name-calling, slurs, physical violence, offensive pictures, intimidation, etc.
Confidential Information and Protection of Personal Data
The unauthorized release of confidential information (e.g., information about Company’s clients, business plans or financial performance) can cause the Company significant damages. For this reason, every employee should ensure, as the case may be:
- That sensitive Company information is labelled as “confidential”.
- That employee does not discuss confidential information in public places.
- That confidential information is secured when working in an open environment, including public places.
- That before the disclosure of such information, the employee has obtained legal department’s for such actions.
- We always comply with European legislation on the protection of personal data held by the Company.
We guarantee that:
We process personal data in a transparent manner.
- The personal data is collected for specified, explicit and legitimate purposes.
- The personal data is collected only in a limited amount necessary in relation with the purposes for which they are processed.
- The personal data is accurate and kept up to date.
- We keep personal data for no longer that it is necessary for relation with the purposes for which they are processed.
- The personal data is processed in a manner that ensures an appropriate level of data security.
- Access to personal data is limited to authorized employees who have a clear business need to access that data.
Intellectual Property
The employees must respect both an intellectual property of the Company and others and must not use third-party copyrighted materials, like software, images, videos, and music, without a license or permission.
- FINAL PROVISIONS
This Policy does not replace the Company’s existing regulations, provisions, instructions, orders, orders, etc.
The Company has the right to make changes to the Policy at any time and to respond appropriately to manifestations of violations of this Policy.
