Code Of Ethical Conduct Policy

This policy text is indented for clearly setting forth all commitments of SC.Kablutronik SRL for ethical rules and its approach to this matter and this policy applies to all companies under Teleset Group.

OUR CORE VALUES

SC.Kablutronik SRL employees are expected to have attitudes and behaviors intended for safeguarding and improving the reputation of its companies and credibility of its corporate structure. All group company employees as well as individuals and enterprises to deliver service on behalf of the company are expected to adhere to all applicable laws and legislation and to act in accordance with fundamental moral principles such as honesty, reliability and respectability in all decisions and behaviors.

The rules and practical principles set forth in the current policy apply for all individuals and enterprises which deliver services for or on behalf of SC.Kablutronik SRL including employed staff, contracted personnel, outsources, consultants, and companies from which attorneyship and public accountancy services are received.

COMPLIANCE WITH LAWS

SC.Kablutronik SRL implements and records all of its domestic and international activities/transactions in accordance with national and international legislation. It submits or reports all information, which is requested by regulatory institutions and agencies assigned as per law, accurately, in full and in time.

It shows attention to remain in equal distance in relationships with any public institution and agency, non-governmental organization and political party, and to fulfill its obligations in accordance with such awareness of responsibility.

DISCRIMINATION AND HARRASMENT

SC.Kablutronik SRL attaches great importance to developing and maintaining a fair, healthy and safe working environment in compliance with all laws and regulations for personnel. All personnel and their contributions to the company are valued. Top priority is given to ensure that equal opportunities are safeguarded and zero tolerance is given to any discrimination, physical or verbal harassment in accordance with its Human Resources policy.

Any discrimination among personnel based on race, gender, color, nationality, religion, sect, age, disability, sexual orientation, political opinion or similar reasons is unacceptable in group companies. Accordingly, personnel is recruited, assigned, promoted, trained and waged solely based on their qualifications, performance, skills and experience.

Any violation of physical integrity through sexual behaviors and/or harassment for sexual purposes without any physical contact is evaluated as sexual harassment, and any offensive or humiliating behavior addressed at the disability of an employee with a physical disability is evaluated as harassment of disabled. Any behavior corresponding to these definitions is strictly forbidden. SC.Kablutronik SRL shows zero tolerance to the personnel who exhibit such behaviors as well as personnel who disturb those who file a complaint/make notification or help with the investigation in this regard.

CHILD LABOR

SC.Kablutronik SRL bans employment of minors below 18 years old in positions requiring hazardous work. The ban imposed by the company on child labor complies with standards of International Labor Organization and Labor Law.

BRIBERY AND CORRUPTION

Employees of the group companies may not offer, give or promise any bribe, gratuity or any other illegal payment/interests to any public institution or commercial enterprise, their personnel or any other person/organization, and may not permit these to be done.

Employees of group companies may not by any means receive bribe, gratuity or any other illegal payment from any customer, supplier or any other person/organization with which company has a business relationship, and they may not accept any offers which provide or may provide them or anyone close to the with personal interests.

GIFTS AND PROMOTIONS

Gifts and promotions which may be given to persons and organizations in a business relationship with the company are determined upon approval of Board of Directors. Seeking further permit is not necessary for distribution of gifts and promotions already in this scope. Additionally, gifts, entertainment, opportunities and meal offering promised, given or provided to a public official or any other authorities of institutions in a business relationship with the company should be reasonable, legal, fully relevant to business, in accordance with courtesy requirements and in line with commercial conventions and general practices. Maximum limit for these kinds of expenditures is set to 100 $, which may not be exceeded unless approved by Board of Directors.

Company personnel may not misuse their authority, which is vested in them for their position, for directly or indirectly obtaining pecuniary or non-pecuniary personal advantages, may not accept complimentary or borrowed money from institutions and organizations with which the company is in a business relationship or may not have them cover their travel expenses, activity expenditures or similar payments. Nonetheless, on the condition that the personnel has not made a request to have so and it does not affect their impartiality and decision making in their position, they may accept promotions, consumable materials or similar gifts with a total value not exceeding 100 $ for each calendar year and enterprise offering such gifts; any gifts above such limit may not be accepted without approval of Department Manager and/or Board of Directors. In the evaluation to be carried out in such circumstance, it will be taken into consideration whether the gift is traditional in the relevant geography or branch of industry and is given openly without any expectation of obtaining special advantages.

AVOIDING CONFLICT OF INTEREST

Conflict of interests arise from conflicts or potential conflicts in the private interests of personnel with the interests or Teleset Group. If personnel obtain improper personal interests by virtue of their position, this is also a conflict of interests.

All personnel have the personal responsibility given below and are obliged to act as specified below in circumstances where use of company sources, name, identity and power for personal interests and and other conditions which may adversely affect SC.Kablutronik SRL reputation should be avoided:

Identifying and monitoring conflict of interest.
Taking necessary steps to avoid conflict of interest.
Notifying supervisors of any conflict of interest upon becoming aware of one.
Staying away from interests in scope of conflict of interests.

SC.Kablutronik SRL personnel, their family members or close relatives are forbidden from obtaining personal interests by benefitting from the position in the company, and from entering into close relationship with persons or organizations that may benefit from their business decisions or confidential information.

Personnel of SC.Kablutronik SRL may not obtain any benefit for themselves, their family members or relatives from company operations, use company property, information or positions for their personal interests or compete with the company.

Personnel are obliged to notify their supervisors of their first degree relation to individuals who have the relevant decision making authority in customer or supplier companies.
Participation in domestic/abroad trips or special organizations held by persons or organizations with whom a business relationship is maintained or prospected is subject to approval from supervisor.

In the event of a kinship between the personnel, attention is paid to ensure that there is no horizontal or vertical organizational link between them upon recruitment, rotation, promotion and assignment; and the personnel in such conditions may not affect any decisions of promoting or assigning their spouses or close relatives working in group companies.

Approval of Board of Directors is necessary for personnel who wish to provide group companies with vendor, contractor, consultant or similar services after quitting their position in Teleset Group. In such case, it is mandatory that actions are in line with interests of Teleset Group, moral and ethical codes are adhered and any conflict of interest is avoided before and after such process.

INFORMATION SAFETY AND ACCURACY OF RECORDS

SC.Kablutronik SRL companies secure intellectual property rights of products, processes and software developed at its companies, and respect patents, trade secrets, copyrights, trademarks, software or other intellectual and industrial property rights of its customers, suppliers, competitors and other firms.

Customers may not use information and contracts that are not available to the public and belong to suppliers and other persons and companies with which business relationship is maintained, for any other means than their specified purpose, and may not disclose these to third parties without necessary permission.

Company personnel may not disclose the information and documents obtained by them for their work to any other internal or external persons or authorities or use them directly or indirectly for any other means than their specified purpose. Requests for confidential company information from third parties may not be responded without approval of senior management.

Personnel are obliged to refrain from using personal information of company personnel and candidates applying for positions for any other means than their specified purpose, to safeguard these and to avoid disclosing them to third parties without approval of the relevant individuals.

SC.Kablutronik SRL prepared and archives all records of its companies accurately, in full and in compliance with relevant principles, standards and legal obligations. In this scope, all personnel are obliged to ensure accuracy and legal conformity of records, documents and certificates in any operation.

WORKER HEALTH AND WORK SAFETY

SC.Kablutronik SRL targets fully ensuring worker health and work safety in all of its activities. SC.Kablutronik SRL takes all necessary measures and fulfills its responsibilities for awareness raising and auditing in order to minimize the risk of exposure to factors posing accident, injury and health risks.

Personnel should act in accordance with the relevant rules, procedures and instructions developed in this scope and help relevant departments with taking necessary measures.

It is forbidden to bring any belongings and/or materials which are illegal or may pose hazard against the workplace and/or personnel.

ENVIRONMENTAL CONSCIOUSNESS

SC.Kablutronik SRL pays ultimate attention to protect the environment in activities of itself, its suppliers and business partners; carries out various activities to raise awareness on environment.

It uses natural resources and energy resources efficiently and avoids wastage. It keeps waste and contamination sources arising from its activities under control and ensures the compliance of its practices with legislation and standards.

It researches and makes use of recycling and recovery opportunities.

SOCIAL RESPONSIBILITY

With its understanding of social responsibility, SC.Kablutronik SRL gets involved in activities aimed for health, welfare and happiness of the society and supports projects realized for a better society and environment.

It acts with consciousness to matters that are relevant to the society and aims for contributing to improving them.

DUE DILIGENCE

Personnel are obliged to exercise due diligence in fulfilling the work undertaken by them as per employment contract, and take initiative to obtain/improve the qualifications required by the work and acquire necessary knowledge.

Personnel are to fulfill their duties in compliance with relevant regulations, terms of reference, rules, procedures and instructions. They are responsible for any damages they may inflict on the company due to their intent, negligence and incaution.

Personnel are responsible for distributing any work given to them to their subordinated staff members and ensuring that these are concluded in time, and fulfilling the instructions of their supervisors in the best manner.

Each employee should be aware of that they represent the company and is obliged to protect the reputation of the company against third parties and refrain from actions and behaviors which may put the company in a difficult position. Unless expressly authorized, personnel may not behave or give statement in a manner that may bind the company.

Personnel are obliged to manage their relationship other relevant personnel, business partners and stakeholders in accordance with business ethics and codes of conduct, they may not disrupt the business harmony through behaviors which may disturb or harm other personnel.

Personnel should expend efforts to behave fairly with goodwill and understanding in order to safeguard company interests and provide mutual benefits.

No employee may obtain benefits from, enter into private business relationship with, request or make payment from or to third parties in relation to their work.

They are to be attentive to all material and non material assets of the company inclusive of its information and information systems as if these are their own property, and they are to protect these from any loss, abuse and damage.

OBLIGATION TO REPORT VIOLATIONS

Personnel who become aware of or suspect from the violation of the rules specified in the policy are obliged to report these as follows:

Subordinated Director (verbal/written)
Human Resources Manager (verbal/written)
hr@kablutronik.ro (written)

Persons who reported the violation and manage the process of reporting and investigation are obliged to pay maximum attention to honesty, objectivity and confidentiality. Intended false and/or slandering reporting is evaluated as the violation of ethical codes.

TRAINING

Trainings on this policy are a part of the orientation of new personnel. Current personnel are informed on the manners to adhere to and implement the policy. Cooperated individuals and organizations are to receive this training as a part of their orientation program