Corporate Ethics and Anti-Corruption Policy SEG

The codex of corporate ethics and anti-corruption policy (hereafter – the code) was developed to assist in doing fair business and prevent from violation of the legislation.

SEG Team

The codex contains standards and requirements of the company in the observance of ethics and business principles.

In cases when current legislation can be used, the legislation principles are of primary importance. The codex determines the company’s relations with authorities, natural and juridical individuals.

Employees must carry out provisions of code not only during working hours but also at events which concern interests of the company/or when employee is perceived by third parties as a representative of the company.

Clients of the company are expected to accept and share aspiration for conducting fair and transparent business taking into account their actions can have a serious impact on reputation of the Company – one of the most important assets of the Company.

Legal and methodical principles

While working out the Code we follow

  • Current legislation and guidelines of Department of Labor
  • United Nations Organization Convention against corruption
  • The Councilof Europe Convention on criminal corruption
  • The US Foreign Corrupt Practices Act
  • UK Bribery Act 2010

Terms, definitions, abbreviations

Employee is a physical person entered into labour legal relations with the Company.

The Company is Stimex Engineering Group.

Customer is any economic subject that has business relations with the Company including state authorities, private entrepreneurs, suppliers, joint venture partners which purchase goods of the Company or use services of the last one.

Conflict of interests is any situation in which personal interest or activities of employee as well as his nearest relatives prevent from efficient fulfillment of labour obligations in the interests.

Personal interest is kind of interest that prevents employee from acting for the benefit of the Company that is to bring profit in favour of employee or his nearest relatives while fulfillment of labour obligations such as cash income or other values except salary and other rewards received from the Company.

The main principles of Business Conducting

The Company informs of the most important principles and values of conducting fair business and aims at its activity to follow their strict fulfillment namely:

Responsibility to employees

  • respect for every employee of the Company
  • nonadmission of offences and persecutions
  •  creation and maintenance of safe workplace
  • accomplishment of personal data confidentiality
  • social responsibility, prompt payment of salary and deducting of taxes to corresponding budgets
  • improvement of training system and employees’ motivation
  •  providing with reporting of individual working results

Responsibilities to a client

  • adherence to  professional  standards of  doing business
  • protection of client’s private information
  • performance of legal duties
  • nonadmission of position abuse
  • not providing ungrounded and illegal privileges to clients
  • dissemination of information, which disgraces clients’ reputation.

General business responsibilies

  • never give or  take bribes
  • run a business with clients, suppliers and competitors fairly
  • stand by the Code and laws concerning protection of competition, anti-monopoly, striving against corruption and laundering of money
  • chose business partners, clients and suppliers carefully
  • Provide true information in marketing and advertising campaigns.

Employeesresponsibilities to the Company

  • care about good name of the company, do no damage to the company’s activity and reputation
  • perform working duties in good faith
  • keep to the company’s regulations
  • do not use domestic information in personal purposes
  • do not compete with the company for personal profit
  • protect private property of the company
  • use resources of the company carefully and effectively.

Responsibilities to the society

  • aim at conducting  business legally and responsibly
  • respect and follow laws of country, in which the company operates
  • conduct open and transparent bussines.

The company claimst that all above principles of the Code are equal and so they are followed without preferences or priority one before other.

Anti-corruption campaign and conflicts of interests prevention

As well as in Ukraine and abroad while cooperating with clients, public authorities, other structures and individual persons, employees of the company are not permitted to perform acts, which are against the legislation of Ukraine and the Code and legal standards of the countries, in which the Company conducts its business.

Employees acting in the name of the company or for the benefit of the company are forbidden to offer, convey or accept any   incentives if it can bring about conflicts of interests of employees, violate the law or do harm to business reputation of the company.

For the purpose of nonadmission such actions the Company develops and takes measures for revealing and removing of shortcomings and strengthens internal control.

Respecting customers’ or partners’ principles the company gives preferences to those who support rules of the given corporate ethics.

In case if there is information about a customer’s violating the principles of human rights protection, the company has right to break relations with the customer.

For getting information about competitors, customers and partners the company acts only legally.

The company will be obliged to everybody for carrying out the principles of the Code and it hopes to have mutually beneficial relations with all customers.

The company believes that the third parties will also give information to the main contact person about violating the Code.

Information disclosure

While performing duties of service employees do not have any rights to disclose commercial classified information, information about privacy and health of their co-workers.

After finishing working for the company employees are committed to non- disclosing commercial classified information or using it for personal purposes as it is a reason for bringing to account.

Employees do not let illegal use of internal information. Getting access to such information employees follow regulations of the company and the Code.

Employees keep in line with the rules of access and security of software information data of the company.

Disclosing of company’s commercial classified information and internal information is carried out according to the laws of Ukraine, the statute and internal documents of the company.

Protecting employees’ interests the company gives a guaranty not to take revenge including dismissal, reduction, losses of privileges and so on towards a person, who informed the company about corruption or abuse of the employee’s rights.

If an employee considers that he is pursued he can make an inquiry directly to the manager.

Measures for prevention of corruption

Limit giving /taking presents and carrying out of expenses on representation

Expenses on representation are carried out according to the normative acts of the company.

Presents for company’s employees, customers, business partners and persons working for the government must not have an influence on making business decisions.

Employees of the company are allowed to give presents if the present is not considered to be a bribe.

All expenses on presents must be truly calculated and reflected in bookkeeping reports of the company.

The company is allowed to have:

  • business lunches, dinners and others activities providing that purpose of the meeting is business.
  • corporate gifts which have logo of grantor (diaries, calendars etc.) and gifts given during annual professional and other holidays (New Year, Christmas, birthdays)
  • gifts and rewards for achievements and contributions to development from Companies, governmental, charitable or  religious organizations within cost fixed by requirements of legislation.

Besides, it must be  taken into account that:

  • gifts must be connected with legitimate interests of the Company or connected with public or professional holidays.

Decision concerning giving gifts or other material benefits is made in accordance with standard acts of the Company and principles of given Code.

Non-involvement in  politics

The Company does not take part in any political parties, organizations and funds connected with them and also It does not make any payments to support them.

Employees of the Company can take part in politics if it does no harm to the interests of the Company and makes no conflict of interests.

Interaction with representatives action of state and governmental organizations

Cooperation of the company with law enforcing bodies and other bodies of State Authority, municipal authorities and their representatives and also with governmental organizations and their representatives is executed strictly within current legislation.

The Company doesn’t make any illicit payment to the advantage of the abovementioned bodies, their representatives and other individuals through intermediaries including payments for holiday, entertainment, transport and other charges in order to gain and maintain advantage in business.

The Company refrains from material incentive of representatives as well as from cash payments in order to influence his decision in favor of the Company.

Cost accounting

Requirements of the legislation and standards of keeping records are observed in the Company. Every fact of economic activity is to be recorded.

Falsification of accounting statements as well as other kinds of records or supporting documents is not allowed.

All financial transactions are recorded in the report with necessary level of specification.

Employees whose duty is to keep accounts are responsible for preparing and giving full and reliable information.

Responsibilities of employees and other individuals in the field of corruption counteraction

The Company employees learn principles of the given Codex and undersign obligation to follow them.

Employees have to follow restrictions and requirements provided by the Codex:

  • concerning gifts
  • sponsorship
  • participating in politics
  • concerning contacts with representatives of governmental  and public organizations, contracting  and third parties.
  • non-admission of conflicts
  • record-keeping

Responcibility for non-fulfilment or not proper fulfilment

All employees of the Company irrespective of the position are responsible for non-fulfilment or not proper fulfilment of  the given Code within limits distinguished by current legislation of Ukraine and standard acts.

Official investigation is held in case of corrupt acts suspicion. The results are brought to the attention of the company`s management.

The Company is authorized to apply to the Court in case of infringement of the Code principles and impair by individual.

The Company reserves the right to apply to the law-enforcement authorities to bring the individual to administrative or criminal responsibility.

On a decision of the company`s management information on existing offences of the given Code can be placed in the public domain (in compliance with legislation on Personal Data Protection) including on the corporate or official websites of the Company, on the Internet and mass-media.