Objective, scope, and responsibility
Code of ethics of Studenac d.o.o. (“the Code”) reflects the fundamental values of Studenac d.o.o. ("the Company“) and its employees in relations within the Company as well as in relations with external entities.
The goal of the Code is to provide guidelines on what is expected of employees of the Company and for persons who, on any other basis, perform work for or on behalf of the Company, and provides guidelines related to business conduct.
The Code is based on respect for fundamental human rights and ethical principles:
- Compliance with legal norms
and enables the members of the Supervisory board and Management board, all employees, third parties (associates, customers, suppliers, business partners) and all other interested persons insight into the ethical rules that the Company applies in its business. By applying the highest standards of business ethics and corporate social responsibility the Company wants to cultivate employee loyalty, build strong relationships with suppliers and other business partners, strengthen their trust, respect, and build a strong reputation and integrity in accordance with best practices.
All employees of the Company are always obliged to comply with the rules of the Code as well as other internal acts of the Company and the relevant legal regulations of the Republic of Croatia. All other external participants are expected to act in accordance with the rules of the Code.
The management of the Company is responsible for adopting, amending, and revoking of the Code.
Principles of behavior
Respect for human rights
Respect for human rights is one of the fundamental principles on which business of the Company is based. We support the protection of internationally recognized principles of human rights. Violation of human rights in any form is unacceptable. The relationship between employees and the relationship between employees and their superiors must be based on the mutual respect and adherence to positive regulations and ethical values, applying the principles of tolerance, fairness, trust, open and honest communication. The obligation is to comply with all applicable legal provisions on wages and working hours of employees, and it is unacceptable to encourage child or forced labour. We respect and accept the right to association and the right to work in a safe, healthy, and humane environment.
Protection against discrimination
Any form of discrimination is prohibited in accordance with the Labour Law and the Law on suppression of discrimination. Any form of discrimination based on gender, race, religion, age, political affiliation, union membership, nationality, citizenship, language, disability, marital status, or sexual orientation is prohibited.
Any form of behaviour based on intimidation of employees is prohibited, especially if as a result, employees are forced to perform actions that are not in accordance with the internal acts of the Company. Any verbal, non-verbal or physical form of behaviour aimed at or resulting in the violation of a person's dignity or the creation of an intimidating, hostile and offensive work environment is prohibited.
If an employee believes that he is a victim of abuse or any form of discrimination at the workplace, employee can contact the person nominated by the employer to receive complaints which are related to the protection of employee dignity.
We strive for excellent results, but we never try to achieve them through illegal or unethical business practices. The Company's goal is to succeed through open and fair competition on the market.
Compliance with laws and rules on fair market competition and anti-corruption laws as well as laws that prevent money laundering and all other relevant legal regulations is also one of the principles woven into business of the Company. To ensure that the third parties with whom we enter business relations are aware of the provisions on the need for compliance of our business, these provisions represent the mandatory content of our contract form. To ensure that employees are familiarized with the same provisions and their implementation in practice, the Company organizes training for employees with the aim of familiarization with this area.
Prevention of bribery and corruption
The Company firmly opposes corruption and bribery, and strictly prohibits bribing others to obtain business opportunities or other advantages.
Employees of the Company are prohibited from promising or giving things of value to any third party and to government or public officials to secure an unfair advantage or unfair influence on any decision, to offer anything to obtain permits or approvals, to retain or obtain employment, to gain any advantage or attempt undue influence on decisions. It is also forbidden to accept or to ask for things of any value that could have influence on deciding on behalf of the Company. The Company may not have agents or representatives who would participate in such activities on behalf of the Company. Business partners and suppliers are required to operate without any form of corruption or fraud.
It is our responsibility to create and maintain a culture throughout the value chain that encourages action to be taken if fraud or corruption is suspected.
Detailed guidelines for prevention of bribery and corruption can be found in "Anti-bribery and corruption policy".
Prevention of uncompetitive behaviour
The company is obliged to comply with all laws and regulations on market competition and is prohibited to participate in any agreement or arrangement whose purpose is to prevent, limit or disparage competition. Competitive action must always be justified by reasonable business decisions. In carrying out daily activities involving the Company's competitors and business partners, employees must be aware of and comply with the provisions of the Law on the protection of market competition.
Compliance with trade regulations
The Company is committed to comply with the trade regulations, especially the Law on the protection of market competition, the Trade law, and the Law on the prohibition of unfair trade practices in the food supply chain.
Responsible persons must ensure that they know the laws and regulations governing the business unit for which they are responsible and must be prepared to deal with the regulatory risks that may arise.
Prevention of money laundering
Money laundering is the process of concealing the nature and source of money or other assets related to criminal activities such as drug trafficking, terrorism, bribery, or corruption by integrating illegal money or assets into the flow of trade so that they appear legitimate or in such a way that it is not possible to determine the true source or owner. Persons involved in criminal activities try to hide criminal earnings or try to make them look legitimate by "laundering" them through legitimate companies.
We must recognize the signs of money laundering and ensure that we do not encourage or support the process of concealing the source of illegal funds through our legitimate business.
Detailed guidelines for prevention of money laundering can be found in "Prevention of money laundering and financing of terrorism policy".
Responsible decision making
Integrity starts at the top of the organization, and all Responsible persons must gain respect through appropriate behaviour, which also means that each Responsible person must emphasize the importance of ethics and following the rules and promote them by personal example. When making decisions in daily work and performing work tasks, personal interests must never be put before the interests of the Company in order not to compromise the reputation of the Company.
Prevention of conflicts of interest
A conflict of interest occurs when personal relationships, participation in outside activities or interests in another business influence or is perceived to influence the illegal decision-making.
The reputation of the Company, as well as the reputation of the employees of the Company, must not be endangered by entering into agreements or deals that represent indirect or direct competition with the Company. Use of position to obtain improper benefits or opportunities, including loans, investment opportunities, contractual opportunities, personal transactions, or employment is prohibited.
It is prohibited to engage or employ a person simply because the person is a family member or friend. Engagement or employment of family members and friends is allowed if they are candidates with the best qualifications and in compliance with relevant regulations and internal procedures. Bias should not be allowed, and all employees should be rewarded according to their merits and abilities.
The conflict of interest should be considered in the event of a change of workplace within the Company. To avoid conflicts of interest, it is not allowed to work as a supplier for the Company or represent the interests of any supplier. We must not participate or influence, directly or indirectly, on any request, in negotiations or decisions related to customers and suppliers who are family members.
An employee is obliged to exclude himself from the decision-making process that may in any way lead to a conflict of interest between an employee and the Company and is obliged to inform the Company in situations where a conflict of interest may potentially arise.
Gifts and hospitality
Giving and receiving gifts and hospitality is not prohibited under Company rules if the following criteria are met jointly:
- it is of reasonable, nominal value,
- it is given for a legitimate business reason,
- it is not intended to improperly influence us or a third party.
It is not allowed to accept or to ask for a gift that could affect our ability to make objective decisions in the best interest of the Company. It is not allowed to solicit or enter contracts based on any gift, service or courtesy from a customer, supplier, consultant, service provider or third party. Except for justified gifts such as promotional materials of small or nominal value (unless they are luxury gifts) or other forms of hospitality in accordance with standard business practices, no gifts or hospitality are permitted. Accepting cash or cash equivalents is prohibited.
In case of receiving a gift for which is considered that exceeds the allowed value, the recipient of the gift is obliged to notify the Compliance officer of such receipt. If the Company determines that such a gift or gifts are not customary in business, as well as if it is culturally inappropriate to refuse or return a gift that is not customary in business, the Company gives an employee the opportunity to hand over the gift to the Company or keep the gift and pay a donation for charitable purposes.
If gifts or hospitality do not fit into the above categories or an employee is unsure whether they are appropriate or inappropriate, employee must seek prior approval from their direct supervisor and Compliance officer before offering or accepting them.
Detailed information and amounts, related to gifts and hospitality, for employees, are defined in "Rules for gifts, hospitality and donations", appendix of Code of ethics.
Relations with government and public officials
Government officials and any person employed in a government institution, officials employed in regional or a local government, and especially representatives of public institutions and holders of public duties, as well as representatives of political parties, should never receive gifts and hospitality that could question their independence.
A facilitating payment is a financial payment that is made with the intention of expediting an administrative process. It is a payment made to a government or public official that acts as an incentive for the official to complete some action or process expeditiously, to the benefit of the party making the payment.
The Company rejects the practice of applying such payments and will not make such payments when requested.
Corporate social responsibility is part of long-term business strategy of the Company. We strive to contribute to positive changes in society, recognize the challenges of society and promote changes by listening to the needs and expectations of the community. In accordance with applicable regulations and internal rules, the Company provides donations to needy groups and individual organizations that help solve social problems.
The Company may not accept or request direct or indirect compensation in exchange for a donation. We approach donations responsibly and communicate transparently. It is not permitted to solicit or accept donations for charitable or other altruistic purposes from existing or potential third party unless the Company chooses to support a campaign for specific purposes.
Political contributions and donations
We are committed to political neutrality, and we are against any material and financial support of political parties and, in accordance with our rules, political donations are strictly prohibited. Employees of the Company must not associate their personal connection with political parties with their status in the Company.
Responsible information management
One of the key responsibilities in business of the Company is respect for privacy, including personal data as well as other information we come across in our work, which have the characteristics of confidential information.
Respect for privacy and data protection
Protecting the confidentiality and integrity of personal data is one of the key foundations of a reliable business relationship. The Company must process personal data fairly and legally and provide access to this data only, when necessary, considering the conditions prescribed by the Law on the implementation of the general regulation on personal data protection. Access to personal data is permitted only to those employees of the Company who must have it. If the Company must share personal data with third parties as part of contractual obligations, we ensure that they adhere to the same strict terms and duties regarding privacy protection.
Handling of confidential information
The Company and all employees must protect all confidential information and ensure that there is no unauthorized access to this information or that it is used in an unauthorized manner.
Confidential information is all information in any form, tangible or intangible, that has been disclosed or may be disclosed to an employee by the Company, in writing, verbally or by observation, that is not public, is the property of the Company, or is a trade secret or confidential by its nature and all data that an employee received from the Employer or created during his employment within the Company.
Data on the Company's financial position and financial transactions, data on the Company's customers, suppliers and business partners and data on contractual relations, data on the Company's projects and business plans, data on the status, salary, social and health status of employees, all data whose disclosure could cause significant damage to the Company are always considered confidential information.
If it is necessary to disclose or provide confidential information to other employees of the Company, it is necessary to inform the recipients that it is of a confidential nature. Confidential information must not be shared with third parties, unless authorized and necessary for business reasons. All persons outside the Company who receive such information must sign a confidentiality agreement. In all cases where confidential information is shared, we must notify the direct supervisor and the person responsible for the information, prior to release. Supervisors must ensure that all members of their team comply with the Company's rules regarding the protection of information. It is also necessary to protect systems and networks and take care not to reveal passwords or accidentally grant access to any resources. Employees of the Company and third parties, as well as legal internal and external auditors, are also required to maintain the confidentiality of information. When government authorities request confidential information, it can only be provided if the request is made in writing, if it meets applicable legal requirements, and is approved by a direct supervisor. Ultimately, obligation is to protect the confidential information of former employees and other third parties. Property rights and information of other companies that have not been publicly disclosed must be respected. Patents or copyrights may not be infringed, including documents, materials, presentations, and other written materials. The same obligation to protect the confidential information of the Company exists after employees leave the Company.
Rights and obligations of employees
Employees and Responsible persons are the implementation agents of this Code, therefore they must:
- be thoroughly familiarised with the provisions of the Code,
- understand that the Code is implemented in the Company's business activities and as an internal regulation that establishes rights and obligations of employees,
- apply the provisions of the Code and act in accordance with all applicable laws and regulations in the context of their workplace,
- promote the principles of conduct prescribed by this Code.
Responsible persons in a managerial position are expected to lead by example by respecting the principles and provisions of this Code and must ensure that the principles and provisions of the Code are available to employees and third parties with whom they enter in business relations.
Employees may contact their direct supervisor or Compliance officer directly for any questions or advice related to the provisions of the Code. Employees who report non-compliance with the Code must not be exposed to retaliation.
The report of unethical behaviour must be submitted to the Compliance officer appointed by the Company. The Compliance officer is responsible for processing reports of non-compliance and incidents as well as monitoring the implementation of the principles and provisions of this Code of ethics.
Report of non-compliance and incidents
Every employee of the Company is obliged to report to the Compliance officer any non-compliance that is noticed or that may occur, or any incident that occurs. Such notice will contain a description of the event, the place and time of the event, a list of participants and witnesses, information on causes and consequences. The Compliance officer will conduct an internal investigation of the non-compliance or incident, during which he will question the participants and witnesses and then make findings and recommendations with the aim of preventing such events in the future.
Violation of the Code
Violation of the Code by employees of the Company represents a violation of their obligations from the employment relation, due to which the employer can initiate the procedure for cancelling the employment contract and claim damages that the Company suffered due to such behaviour of an employee.
The Company may amend this Code at any time to improve its effectiveness in the fight against illegal and unwanted practices.