Code of Ethics - Trustpack
UAB "Trustpack" CODE OF ETHICS AND CONDUCT
I. GENERAL PROVISIONS
- The Code of Ethics and Conduct of UAB Trustpack (hereinafter referred to as the Code of Conduct) describes the norms that must be observed by employees of UAB Trustpack (hereinafter referred to as the Company). The basis of the norms of conduct: ethical and lawful behavior.
- Our Code of Conduct is a company promise and a document summarizing the values and business principles we promote. It is an expression of the professionalism that the company's employees must cultivate in their activities and that is expected from partners. The obligation to follow the Code of Conduct and compliance with the rules set forth therein is one of the essential conditions of cooperation and employment relations.
- With the Code of Conduct, we aim to:
- To reveal and consolidate the company's values, operating principles and standards of conduct.
- To establish the basic principles of the company's relations with customers, business partners, state, public and municipal institutions (their representatives), competitors, shareholders and company employees.
- The Code is based on our company's Vision, Mission and Core Values, helps to foster them, and shows how employees should behave towards colleagues, customers, business partners and other members of society.
- Each of our employees, upon receiving information about any non-compliance (violation) of the company's rules, obligations or promises, as well as about any circumstances that would indicate that there is a real threat to the interests of the company, its employees, customers, business partners or shareholders of the company, must immediately inform their direct manager or the company's CEO.
II. OPERATING PRINCIPLES
- We respect each of our clients, colleagues, and business partners, and we commit to acting respectfully and honestly so that they have no doubts about the reliability of our cooperation.
- We adhere to the principles of fair business. We operate transparently, reliably and honestly, separating public and private interests.
- We avoid conflicts of interest (i.e. situations where an employee has to choose between the company, its clients, partners or personal interests). If a conflict of interest arises, the immediate supervisor or the company's CEO is always informed. The pursuit of personal financial interests while performing work functions at the expense of the company, its clients, partners or public finances is not tolerated in the company.
- Environmental protection
- As a responsible business actor, the company is committed to actively reducing its environmental impact, including continuous measurement and assessment of environmental impact.
- We aim to ensure that all employees are properly informed and trained on environmental protection requirements. Each of our employees must strive to reduce waste and any other impact on the environment.
- In our activities, we strive to conserve natural resources, raw materials and energy, choose and responsibly purchase and use products, responsibly manage waste and reduce its amount, and support and actively contribute to national environmental initiatives.
- Compliance with legal acts
- 10.1. Compliance with legal acts is an absolute requirement applicable to the company and its employees.
- 10.2. Each employee must be thoroughly familiar with the legal acts regulating the performance of his/her work functions. Managers must provide their subordinates with the necessary explanations and advice on the application of legal acts in the performance of work functions.
- 10.3. The Company expects employees to comply with all laws designed to protect health, safety and the environment, to obtain all necessary permits, and to perform their work in strict compliance with the requirements of relevant legal acts.
- Employee relations and personal commitments
- Employees must behave professionally during work: be correct, polite, follow the rules of communication ethics, and behave in a way that their actions do not harm the Company's business reputation.
- During their time off work, employees also avoid any situations in which their inappropriate behavior could be associated with the company and its reputation.
- Politeness and helpfulness are the main principles of collegial communication. Showing negative emotions, raising your voice when speaking, or using violence against another employee (both psychological and physical) is never tolerated. Any form of harassment of another person is strictly prohibited. Unethical, malicious, or other negative behavior of employees and partners does not go unnoticed or unappreciated.
- Discrimination
- Every employee has the right to be treated fairly, collegially and respectfully by their managers, subordinates and employees performing the same or similar duties. Our company members do not tolerate any discrimination or harassment (based on race, religion, belief, national origin, gender, disability, age, marital status, etc.). All employees of the company act in accordance with the principles of the Code of Conduct.
- The company does not tolerate discrimination against employees based on their political, religious, sexual and personal views, as well as family/health status or condition. The criteria on which the company makes a decision on employment are the employee's personal qualities (honesty, decency, etc.) and his work competence.
- Conflict of interest
- Business transactions must be conducted in the best interests of the company. No natural or legal person connected in any way with an employee may unfairly take advantage of their relationship with the employee or their position to gain an advantage from the company.
- Situations that may create a conflict between the employee's responsibilities towards the company and his personal interests must be avoided. An employee must avoid any circumstances that could cause damage to the company's reputation or other material and intangible interests of the company.
- Participation in any legal form (including investment in such an entity or holding any financial interest in such an entity) in the activities of another entity competing with the company, without the written consent of the company, is incompatible with employment relations in the company.
- All conflict situations related to labor relations within the company are resolved immediately and decisively. The company does not prohibit its employees from engaging in activities that do not and cannot negatively affect the interests of the company and the proper performance of the employee's work functions. However, the employee must inform in writing about such activities before they begin, in order to avoid a conflict of interest.
- Relations with customers, partners, representatives of public institutions
- Our relationships with clients, partners, and other institutional representatives are based on respect, honesty, professionalism, mutual trust, fairness, prioritizing the client's interests, compliance with obligations, information, and prioritizing negotiations over legal actions.
- Company employees must do everything possible to prevent any manifestations of corruption.
- Information and communication with the public
- The company discloses all information about its activities in strict accordance with the requirements established by the legal acts of the Republic of Lithuania and based on such principles as authenticity, regularity, efficiency, and balance between private and public interest.
- The company's employees must refrain from disclosing any information to representatives of the mass media, except in cases where a corresponding written order has been received from the company's CEO.
- Information is provided to the mass media on behalf of the company, as well as to any third parties who are not the company's clients or partners, only by the company's general director or a person authorized by him.
- Confidential information related to the company's activities and its partners is kept strictly confidential by each of the company's employees.
- Bribes, Gratuities, Business Lunches and Gifts
- The Company never seeks to gain a business advantage through illegal means. It is strictly prohibited to offer or give bribes to third parties in the Company's activities.
- No employee may make any payments, give bribes, or offer unfair financial benefits to clients or other persons performing public functions, in order to maintain commercial relationships by providing services or receiving other benefits.
- While performing their work functions, the company's employees are strictly prohibited from accepting any gifts, and are also prohibited from giving or receiving money from any clients, business partners, or their representatives, or from concluding contracts for personal consideration.
- Company employees must not provide any hidden privileges to customers, business partners, representatives of the state or municipality, or public institutions.
- Employees are strictly prohibited from rewarding customers, business partners, representatives of state or municipal or public institutions, and other third parties with whom the company has business relations with expensive gifts and all other forms of illegal payments, services, or other remuneration for favorable decisions made or not made.
- An employee of the company who suspects that any third party (client, colleague, etc.) is trying to involve or use him in concluding an illegal transaction must report this to the company's CEO.
- Business lunches and business gifts to employees must comply with the general business expense policy and the rules and requirements of the government agency or legal entity in question. Third parties must not be used to circumvent the provisions of the aforementioned policies.
- Incitement to profit
- The term “benefit” includes: gifts, loans, tax benefits, awards, positions, employment, transactions, services, support, etc.
- The company prohibits managers or employees from inciting any benefit from customers, suppliers, or any person related to the company's business.
- Acceptance of benefits
- Managers and employees must refuse to accept benefits offered in connection with their position if accepting the benefits could affect their objectivity or force them to act contrary to the interests of the company, or if this would result in complaints of bias.
- Managers or employees (by informing the company's CEO in advance) may consider and voluntarily accept the benefit provided only if: • The benefit received will not affect the recipient's performance; • The recipient will not feel obligated to do anything in return for the giver; • The recipient can openly discuss the benefit received without any reservations; • The nature of the benefit received (e.g., promotional or campaign gift, on holiday occasions) and its value are such that refusing it would be considered an unfriendly or impolite act.
- Offering of benefits. Any payments, agreed favorable conditions or other advantages granted by managers or employees in the course of conducting company business must be in accordance with the company's prevailing policy regarding such matters and such actions must have the prior approval of the company's CEO.
- Entertainment. While entertainment is an acceptable form of business and social behavior, managers or employees should decline invitations to meals or entertainment that are too frequent to avoid embarrassment or loss of objectivity in conducting company business. If it would be impolite to decline an invitation, the employee may accept it by arranging with the company’s CEO to allow him or her to respond in kind.
- Use of information technology
- The company does not tolerate the use and storage of any information that degrades the honor and dignity of a person, as well as any other illegal information, in IT tools and data storage media located on the company's premises.
- The Company encourages employees to use information technologies (computers, IT networks, mobile phones, e-mail, Internet) responsibly. Employees must remember that when using information technologies, they are responsible for protecting the Company's information, loss, damage or destruction of technologies.
- Computer equipment located on the Company's premises and owned by the Company may not be used to write comments on the Internet (including blogs and social networks) or to respond to comments from other persons.
III. IMPLEMENTATION OF THE CODE
- UAB Trustpack has approved this Code of Conduct so that all employees properly comply with the principles and norms established therein.
- Every employee is required to read and comply with this Code of Conduct. Failure to comply with the provisions of this Code of Conduct may result in penalties, including dismissal, as provided for in applicable laws.
- We fully support our employees who conscientiously comply with the provisions of the Code of Conduct, especially when they face external pressure to violate them.
- Employees must promptly and appropriately respond to any violations of this Code of Conduct and inform their immediate supervisor or the Company's CEO. The Company maintains complete confidentiality of individuals reporting violations of this Code of Conduct and ensures their protection as provided for by law.
- The company's management constantly monitors compliance with the Code of Conduct and, if necessary, implements specific monitoring programs.