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Code of business ethics

Vostok-Service GROUP OF COMPANIES is considered a leading provider of modern high-quality safety AND OCCUPATIONAL SAFETY PRODUCTS to industrial enterprises and individuals IN RUSSIA, CIS and Europe.

1. VOSTOK-SERVICE mission

In this regard, the Company recognizes its responsibility for proper fulfillment of all its obligations to its partners, customers and employees.

High-quality and timely satisfaction of society’s needs in modern protection and occupational safety products is a source of profit, further development of the company and welfare of its employees and shareholders.

In its activities, the Company aims at making work conditions comfortable, safe and more effective.

The main value of the Company is its staff – the people able to work together, develop and grow with the company.

2. AIMS AND OBJECTIVES OF THE CODE

This Code of Business Conduct and Ethics of Vostok-Service (hereinafter the Code) is designed to capture and monitor implementation of the basic tenets of the relationships between the employees of the company, develop ethical norms of business practice, and achieve acceptance and understanding of the values ​​adopted by the Company.

The aim of the Code is to establish professional, respectful and responsible relationships among employees, customers, partners, investors and shareholders.

The Code’s challenge is formation of a single behavioral, moral and ethical concept for employees and other persons acting on behalf of the Company within the business.

The Code stipulates basic rules and regulations recommended for effective operation of the Company, growth of its credibility in Russia and abroad, as well as supportive and conflict-free activities of all employees.

3. FIELDS OF APPLICATION of the CODE

The requirements of the Code apply to all employees and other persons acting on behalf of the Company.

Compliance with the rules of the Code is mandatory for all employees and other persons acting on behalf of the Company.

The Code does not contain restrictions concerning privacy of its employees and other persons acting on behalf of the Company.

Provisions of the Code shall not contain any discriminatory elements concerning ethnic, gender or any other characteristic.

4. general requirements of the code

4.1. REQUIRED OF company EMPLOYEES

Each employee of the Company shall, when hired, familiarize with the provisions of the Code and confirm in writing their understanding and acceptance of its demands.

Each employee of the Company shall clearly know and understand what issues of his/her working practice require application of this Code.

Each employee of the Company shall be informed, whom and how he/she may and should contact in case of dispute and issues concerning application of the Code.

Each employee of the Company shall know what measures and sanctions could be imposed by the Ethics Committee and Management of the Company in case of violation of the Code.

Each employee shall know that he/she is entitled to anonymity in case the Ethics Committee and Management of the Company are notified of the Code violation.

4.2. REQUIRED OF OTHERS ACTING ON BEHALF OF the COMPANY

The Company’s staff and management have the right and should require f non-regular employees acting on behalf of the Company to comply with the rules of the Code and report in the prescribed manner about Code violations.

4.3. REQUIRED OF MANAGEMENT Of THE COMPANY

Line managers and top managers of the Company are required to ensure, within their area of responsibility, that the Company's employees and other persons acting on behalf of the Company know the rules and regulations of the Code and monitor abidance thereby.

Line managers and top managers of the Company are required to confirm the real, not declarative, nature of abidance by the rules and regulations of the Code by their behaviour and actions.

Line managers and top managers of the Company are required to provide timely training in the Code standards, take measures to prevent Code violations and remedial actions concerning Code violations.

5. CODE MANAGEMENT

5.1. ACTIVITIES OF Vostok-Service ethicS committee

The Ethics Committee of the Company (hereinafter the Committee) consists of the Executive Director, Sales and Marketing Manager, Human Resources Manager, and is headed by an Executive Director of the Company.

The Committee is responsible for monitoring abidance by the rules and regulations of the Code by the staff, management, and other persons acting on behalf of the Company.

Amendments to the Code are conducted in collegial manner in a meeting of the Committee, if a specific change is approved by a Committee simple majority.

Implementation of committee decisions is monitored by the Human Resources Manager.

5.2. HOW AND WHERE TO ask QUESTIONS OR provide INFORMATION

Each employee of the Company or person acting on behalf of the Company has the right and duty to report on contemplated or actual violation of the Code.

In case of contemplated or actual violations of the Code, an employee of the Company or a person acting on behalf of the Company may report it to his/her line manager, Human Resources Manager or the Ethics Committee of the Company.

Confidentiality of the report is guaranteed by the provisions of this Code.

An employee of the Company or a person acting on behalf of the Company may report on contemplated or actual violation of the Code verbally, in writing or via e-mail.

An employee of the Company or a person acting on behalf of the Company has the right to know about the action taken in response to his/her message.

5.3. Possible and acceptable steps to eliminate violations of the CODE 

Each contemplated violation of the Code must be prevented, and actual - punished. Control is carried out by the Human Resources Manager.

Each report on contemplated or actual violation of the Code must be carefully checked. Control is carried out by the Human Resources Manager.

The Code guarantees a ban on any retaliatory measures against a person who reported on contemplated or actual violation of the Code.

Sanctions against the person responsible for the violation of the Code are determined by the Ethics Committee and may include measures under applicable labour laws to the extent of dismissal. Implementation of Ethics Committee decisions is monitored by the Human Resources Manager.

6. code fundamental principles

6.1. conduct of business IN ACCORDANCE WITH NORMS of THE applicable law and code

The business policy of the Company is based on the regulations of the applicable law of the Russian Federation, CIS countries and Europe as well as the provisions of this Code.

The basic principles of business conduct in the Company are fair competition, respect for human honour and dignity, openness and integrity in the conduct of affairs, creating an atmosphere of trust and cooperation, development of skills and talents of our employees, maintenance of the corporate culture, encouragement of initiative and personal responsibility, security in the workplace, and environmental protection.

6.2. maintenance of the Company’s GOOD name and IMAGE

Each employee of the Company and the person acting on behalf of the Company should enhance the prestige of the Company, the value of its tangible and intangible assets by his/her activities.

The protection of the Company’s assets, image and good name shall not depend on personal, family and other third party interests and circumstances of the Company's employees and persons acting on behalf of the Company.

In order to protect the image and good name of the Company, the employees of the Company and persons acting on behalf of the Company should be extremely attentive when accepting and giving business and corporate gifts. In this case, one must rely on the relevant paragraphs and articles of applicable law and explicitly take into account restrictions imposed by the law. Information about such restrictions is available in the Legal Bureau, or Human Resources management.

Accepting or giving business or corporate gifts shall in no way involve corruption.

Cash or its equivalent can never be accepted or given as a business or corporate gift.

Souvenirs with Vostok-Service logo are always appropriate business or corporate gifts.

Presenting expensive gifts that are not considered to be Company souvenirs shall be approved by line manager.

6.3. avoidance of CONFLICTS OF INTEREST

Employees of the Company and persons acting on behalf of the Company should avoid conflicts of interest that may affect their judgment, objectivity and loyalty to the Company.

Employees of the Company and persons acting on behalf of the Company must obtain permission from the line manager concerning extra activities, to enter into any part-time position in any commercial Company in addition to working in the Company to avoid conflicts of interest.

Employees of the Company and persons acting on behalf of the Company shall periodically inform their line managers about their participation in third party’s activities and confirm permission for such activities.

Employees of the Company and persons acting on behalf of the Company must avoid actions and relationships that may be contrary to employment duties or interests of the Company as well as working and consulting activities in the Company competitors.

Employees of the Company and persons acting on behalf of the Company shall avoid participating in any business decision of the Company associated with organizations that employ their relatives.

Employees of the Company and persons acting on behalf of the Company shall avoid direct or indirect participation in the profits of an organization, which is a competitor, partner, customer of the Company or any financial relationship with such an organization.

6.4. PROTECTION OF CONFIDENTIAL AND inside information OF THE COMPANY

Confidential and inside information of the Company is considered to be its intangible asset. Access to such kind of information and the limits of its use are regulated by special documents within the Company.

Business, management, financial, marketing, manufacturing, technical information as well as personal information about employees of the Company is considered to be confidential.

Every employee of the Company needs to know what kind of information is considered to be confidential or inside information. Advice concerning the degree of confidentiality of any information may be obtained from your manager.

Intentional or accidental disclosure of confidential or inside information is considered to be a serious violation of the Code and entails application of administrative sanctions, including dismissal.

6.5.  POSSIBILITIES AND LIMITATIONS OF the USE OF COMPANY’s ELECTRONIC RESOURCES

In today's global world, efficient and competent use of electronic resources of the Company is of great importance for its development.

Use of the Company’s electronic resources (corporate email, intranet sites, and other internal network servers) shall not contradict the rules and regulations of the Code.

Employees of the Company and persons acting on behalf of the Company should protect the Company's electronic resources from unauthorized access and use outside the needs of business activity.

Safety and information technology management has the right to control information received and transmitted through electronic resources without warning employees of the Company.

Company employees are advised not to tell anyone internal user codes, remove or install computer and other programs on office equipment, and make all efforts to avoid any harm to the Company's information security.

6.6. abidance by the rules of INTERNAL CONTROL, FINANCIAL AND business REPORTING

Employees of the Company and persons acting on behalf of the Company are responsible for abiding by the rules of internal control, financial and business reporting within their official duties.

Employees of the Company and persons acting on behalf of the Company are required to keep records and provide reports of all financial and business transactions, in which the Company's assets were used or will be used.

Any use of financial and business resources of the Company shall be coordinated with the manager and, if necessary, with the Company's management in the prescribed manner.

Employees of the Company and persons acting on behalf of the Company must know the storage regulations for internal and service documentation of the Company and comply with them.

Employees of the Company and persons acting on behalf of the Company are strictly forbidden to misrepresent the financial and business information when using it in reporting documents.

Misrepresentation of financial and business information is considered to be a serious violation of the Code and entails application of administrative sanctions, including dismissal.

6.7. PREVENTION of POLICY of DOUBLE STANDARDS AND ANY ACTIONs of discriminatory nature OR actions that OTHERWISE IMPINGE people’s civil rights IN THE COMPANY

Company employees and other persons acting on behalf of the Company are entitled to respectful, non-discriminatory treatment in the workplace.

Any infringement on the rights of the Company’s employees and other persons acting on behalf of the Company concerning age, physical abilities, gender, sexual orientation, health, marital status, race, ethnicity, religion are strictly prohibited.

Any form of sexual harassment and intentional detriment to an employee’s work activities due to a probable or actual conflict of a sexual nature are strictly unacceptable in the Company.

Neglecting of this rule is considered a serious violation of the Code and entails application of administrative sanctions, including dismissal.

6.8. DRESS-CODE OF EMPLOYEES AND PERSONS ACTING ON BEHALF OF the COMPANY

The Company has adopted a business style of dress. Clothing should not distract employees and partners from their business activities, but rather enhance efficiency, and encourage adherence to a business style of communication between employees, partners and customers.

No overtly sexual or sloppy dress style is admissible. Informal style is allowed only at informal corporate events, about which invited guests and staff are additionally informed.

6.9. conduct of BUSINESS OUTSIDE THE RUSSIAN FEDERATION

The policy of business conduct outside the Russian Federation implies mandatory compliance with applicable law of foreign countries, abidance by the rules of this Code, respect of national specifics and traditions, fair competition and promotion of partnership.

6.10. ENVIRONMENTAL PROTECTION, HEALTH AND SAFETY

The Company is not only a leading provider of equipment for security and safety at the workplace, but also a source of innovation in this field in Russia, many CIS countries and abroad. Therefore, it pays particularly close attention to environmental protection, human health and safety at the workplace.

All employees and persons acting on behalf of the Company are required to know the adopted measures and requirements of applicable law for environmental protection, human health and safety at the workplace and comply with them.

Intentional violation of these requirements entails not only disciplinary but also civil and criminal responsibility.