CORPORATE ANTI-CORRUPTION AND ANTI-BRIBERY POLICY
1.1. RETAL considers its reputation for conducting business in a fair and ethical way as one of its core assets, and commits to apply all efforts to maintain its good name.
1.2. The term “RETAL” as used herein means RETAL INDUSTRIES LIMITED, a company organized and existing under the laws of the Republic of Cyprus, having its registration number HE 115887 and registered office at Epimitheos 6, Industrial Area A, 3056 Limassol, Cyprus, and its direct and indirect subsidiaries (each a “Company”).
1.3. The mandate of this Policy covers all Companies of RETAL and their directors, managers, officers, and employees of RETAL (the “employee” or the “employees”).
2. PURPOSE AND SCOPE
2.1. The purpose of this RETAL Corporate Anti-Corruption and Anti-Bribery Policy (the “Policy”) is to reiterate the commitment of RETAL and each separate Company to comply with the anti-corruption and anti-bribery international principles and standards, laws, rules and regulations applicable in the countries where RETAL conducts its business, including those provided for in the United Nations Convention against Corruption, the Civil Law Convention on Corruption of the Council of Europe, the Criminal Law Convention on Corruption of the Council of Europe, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, laws and regulations in the countries where RETAL Companies carry out their operations, and to ensure that the business of each Company and RETAL in general is conducted in an honest and socially responsible manner.
2.2. Corruption in its general sense is any dishonest activity in which a person acts contrary to the interests of the state or entity and abuses his/her position in order to receive or maintain any personal benefit or advantage for him or herself, or for another person or entity.
2.3. Bribery means:
- the promise, offering, giving, or authorizing to promise, offer, or give, to a public official, company, organization and other types of entities, an individual, an officer or an employee of an entity (the “recipient”), directly or indirectly, of an undue advantage, for the recipient himself, herself, itself or another person or entity, in order that the recipient act or refrain from acting in the exercise of his or her official duties, his, her or its business purpose or his or her management or employment duties in order to obtain or retain business or other undue advantage in relation to the conduct of the Company’s business; and
- the solicitation or acceptance by an employee of the Company, directly or indirectly, of an undue advantage, for the Company’s employee himself or herself or another person or entity, in order that the Company’s employee act or refrain from acting in the exercise of his or her statutory, management and/or employment duties.
2.4. This Policy is intended to supplement the applicable laws, rules and regulations prohibiting and establishing liability for corruption and bribery in the countries of operation of RETAL. The definitions of corruption and bribery set forth in Sections 2.2. and 2.3. are without prejudice to any other definitions or interpretations of the said terms under the applicable laws that shall be incorporated into the definition of the terms given herein above. Such terms may have different interpretation in different countries. In case of concern, please refer to Legal Department specialists for advice prior to launching any activity, which may be qualified as related to corruption or bribery to ensure your actions are in compliance with the present Policy and the applicable laws and regulations in respective country.
3. ANTI-CORRUPTION AND ANTI-BRIBERY STATEMENTS
3.1. The employees of the Companies of RETAL are strictly prohibited from acts of corruption and bribery.
3.2. In particular, but without limitation, the employees of the Companies are strictly prohibited from promising, offering, giving, or authorizing to promise, offer or give, soliciting or accepting bribes in the course of performance of their duties, including without limitations carrying out sales and procurement operations with customers, contractors, other business partners of the Company, and liaison with governmental bodies and public officials.
3.3. The prohibitions set forth herein apply irrespective of the form of the bribe (cash payments as bribes, kickbacks, service fees, agency remuneration, pecuniary gifts, the provision of services or other benefits, offering of employment to a relative of the person being bribed, grant of a contract or another business opportunity, etc.) and grantor or recipient of the bribe which could be without limitation a governmental or other public body or official, political party or another nonprofit organization, institution or foundation, including their members, officers, and employees, public or private corporation, company, its directors, officers, or employees, private entrepreneur or individual.
4. RECORD KEEPING
4.1. All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with due accuracy and completeness, and must be kept in compliance with the applicable laws and accounting principles.
4.2. No accounts must be kept “off the record” to facilitate or conceal improper payments.
4.3. Employees of the Companies shall undertake due care and diligence in respect of entering into any contractual relationship with a potential counterparty pursuant to the procurement, risk management and other internal procedures of their respective Companies.
5. GIFTS, MEALS, HOSPITALITY AND ENTERTAINMENT
5.1. RETAL acknowledges that promotional expenditures, including gifts, meals, hospitality and corporate entertainment, may be necessary from time to time to improve the overall impression of the relevant Companies and RETAL in general on the market, to present the products offered by the Companies in a more efficient way, and to build up new business relationships. Any such expenditures shall be preapproved by the senior management of the relevant Company. Such expenditures shall be modest, infrequent, reasonable and proportionate, and must not create any obligations whatsoever for a Company, customer and/or its employees. The gifts of money shall never be provided.
5.2. As regards to receiving gifts the following rules shall apply: (a) gifts and favors shall never be solicited; (b) minor gifts that cannot be misconstrued as being a bribe may be accepted if they do not put the recipient under any obligation or affect his/her impartiality; (c) the gifts of money shall never be accepted; and (d) where offeror of a gift is not a business partner or potential business partner (including their parent, subsidiary or an affiliate) of the relevant Company, acceptance of any gift from such offeror is prohibited in the course of business.
5.3. When deciding whether certain promotional expenditures are appropriate, employees also must take into account any past, pending or future business or administrative matters that are within the recipient’s realm of influence. The timing and context surrounding such gifting must be weighed in order to assess whether any particular gifting could objectively be perceived to be a bribe.
5.4. All promotional expenditures shall be properly documented and recorded in the accounting books of respective Company.
5.5. Notwithstanding any provisions of this Section 5 to the contrary, the employees shall not receive gifts in any form that may somehow influence on the due performance of an employee’s obligations with respect to the offeror of the gift or a third party represented by the offeror.
6.1. It is sometimes permissible to make donations directly to a government agency or public organization (rather than to an individual government or public organization official) as part of a charitable effort or to promote goodwill through such actions as providing free product to a government agency picnic or government-sponsored celebration. Any such expenditures shall be preapproved by the senior management of the relevant Company and by the appropriate management body of the Company if necessary according to its charter document.
6.2. For donations for government agencies or public organizations the following rules shall apply: (a) there is no expectation that the donation is given in exchange for any return favor or business advantage from the government or public organization (quid pro quo); (b) the donation is not made directly to an individual government official, and there is no indication that the donation will be redirected to an individual official’s personal use; and (c) the donation is infrequent and reasonable in amount under the circumstances.
6.3. Donations to private charities shall not be made in the name of a government official, as a donation to an official’s favorite charity, could be viewed as a bribe.
7. REPORTING AND WHISTLEBLOWING
7.1. If an employee becomes aware of any actual violation of this Policy or believes that such violation will be committed, or if such reporting is expressly required by this Policy, the employee should report the said circumstances or his/her good-faith complaints and concerns as soon as practicable. Employees at all times should support, assist, and cooperate with the officers engaged in the investigation of the reports.
7.2. The Company welcomes good faith initiative of any third party to report any actual or suspected violation of this Policy and concerns.
7.3. All reports and notices may be sent via RETAL whistleblower channel at the Company’s website at www.retalgroup.com, by email at [email protected] or by post to
RETAL INDUSTRIES LIMITED
to the attention of Chief Legal Officer
Epimitheos, 6 Industrial Area A,
Limassol, 3056, Cyprus
7.4. The Company shall support its employees and appreciate third parties (further - “whistleblowers”) raising genuine concerns on the matters related to commitment of acts of corruption and bribery they have become aware of, even if they turn out to be mistaken. Any form of retaliation or harassment against reporting employees is strictly prohibited. The Company’s management and officers shall take disciplinary actions against any and each of the employees who threats or is engaged in retaliation, retribution or harassment of any person who has reported or is considering reporting a concern in good faith.
7.5. In order to enable the Company to effectively evaluate and investigate the report, whistleblowers are urged to provide a detailed description of the matter. All notices may be submitted anonymously, however, reporters are encouraged to provide the Company with their names and contact details (email, telephone number), since it may help in the investigation and let the Company inform the whistleblower of the results thereof.
7.6. All reports and notices shall be received and processed in accordance with RETAL whistleblowing protocol. The Company shall do its best to maintain confidentiality of the identity of the reporting person to the extent it is allowed to do so by the applicable laws and such practice does not preclude prosecution of violators and the appropriate legal procedures.
8. ADVICE AND INTERPRETATION
8.1. Each Company shall appoint an employee that will be in charge of advising other employees on application and interpretation of this Policy as well as processing of the reports made pursuant to Section 7.1 and passing them to the senior management of the relevant Company. Unless another officer is appointed, the Company’s Chief Executive Officer (Manager, General Manager, etc.) (“CEO”) shall be responsible for the due performance of that function.
8.2. The Companies are encouraged to arrange trainings with respect to this Policy for their employees from time to time, as may be reasonably necessary or required by law.
8.3. Any other internal rules and policies adopted by the Companies that are impacted by this Policy, shall be interpreted consistent herewith.
9. EXECUTION AND MONITORING COMPLIANCE
9.1. The CEO of the relevant Company must ensure: (a) applicability of this Policy to all employees, agents, consultants, and any other third party intermediaries when acting on behalf the Company, and (b) compliance of the Company’s activity to the provisions of this Policy and the applicable laws.
9.2. For this purpose, the CEO: (a) may issue specific anti-corruption guidelines to conform to local laws, but such guidelines must always meet or exceed the principles outlined in this Policy; (b) shall monitor the effectiveness and review the implementation of this Policy, considering its suitability and adequacy for the applicable business environment.
9.3. All employees of the Companies are welcomed to provide their feedback to their supervisors on this Policy and suggest ways in which it might be improved. Such feedback shall be collected by the Company’s CEO and passed to RETAL Chief Legal Officer with a proposal on amendment or modification of this Policy.
10.1. Any employee who violates any provision of this Policy shall be liable to disciplinary sanctions, civil and/or even criminal liability per local acts of the relevant Company and the applicable laws.
10.2. In addition to Section 10.1, failure to report any actual or potential violation of this Policy by an employee having direct knowledge of such violation, as well as hindering investigations of such violations in any way may give rise to the liability as stated above.
10.3. The Companies shall impose disciplinary actions, including termination of employment, at their reasonable discretion, subject to the relevant circumstances and pursuant to the applicable laws.
10.4. The Companies shall reserve their right to report any violations of this Policy committed by their employees to the appropriate law enforcement bodies. This right is without prejudice to any other remedies that may be available to the Companies under the applicable law, including imposition of disciplinary sanctions on the employees as stipulated in Sections 10.1. – 10.3.
WHISTLE BLOWING CHANNEL
RETAL strives to be a transparent and ethical company and welcomes any of its employees and external stakeholders to report in good faith any actual or suspected violation of our Policies and any other irregularities, potentially detrimental to RETAL and its business, that they may observe. For this purpose, RETAL has created the following whistle blowing channels through which a violation report can be made:
RETAL INDUSTRIES LIMITED
to the attention of Chief Legal Officer
Epimitheos, 6 Industrial Area A,
Limassol, 3056, Cyprus
We urge the person or ‘whistleblower’ to provide an as detailed as possible description of the matter to allow a proper investigation.
All violation reports may be submitted anonymously, however whistleblowers are encouraged to provide contact details since it may help the investigation and allow RETAL to inform them of the results. If provided, RETAL will endeavor to maintain confidentiality on the whistleblower identity unless otherwise specified by the law.
If the whistleblower is a RETAL employee, he/she will not be retaliated in any way for report being made in good faith.
All reports shall be received and processed properly, objectively and fairly in accordance with RETAL whistleblowing protocol.
RETAL is strongly committed to respecting and preserving the environment in both our operations and across our value chain. In that respect, we will operate in strict compliance with all applicable environmental laws and endeavor to continuously improve our performance on the following topics which are material to our business: energy and carbon footprint, circular economy, water consumption, waste and emissions.
ENERGY AND CARBON FOOTPRINT
RETAL recognizes climate change as a major threat to the environment and to our society and actively seeks to mitigate its impact on climate change by improving its energy and carbon efficiency throughout our processes and value chain in order to reduce our direct and indirect greenhouse gas emissions (GHG). To reach this objective, we will:
- Calculate and monitor our corporate carbon footprint and publicly disclose it through relevant channels.
- Seek to constantly reduce our corporate carbon footprint (direct and indirect GHG emissions) through the following mitigation strategies:
- Optimization of our energy consumption through:
- application of energy efficiency best practices,
- monitoring of energy efficiency performance, and
- seeking other optimization opportunities.
- Continuously increasing the amount of renewable energy we use.
- Reducing the amount of raw materials in our products (light-weighting).
- Engaging and collaborating with our PET and HDPE resin suppliers to calculate their carbon footprint and adopt mitigation strategies.
- Seeking to reduce or eliminate the use of fossil fuels in our operational energy consumption.
- Optimization of our energy consumption through:
- Fostering the use of recycled PET resins in our products as they have a much lower carbon footprint than the virgin resins.
- Seeking to continuously optimize the logistics of our raw material and final products.
At RETAL, we are conscious that we are an important link in the value chain leading to plastic pollution. As such, we aim to actively contribute to the eradication of this problem by fostering a plastic circular economy by:
- Whenever possible, proactively increasing the content of recycled resins in our products,
- Contributing to plastic circular economy initiatives through partnerships with our stakeholders, and
- Raising awareness among our employees on best practices to foster plastic recycling
WASTE, WATER and EMISSIONS
Although RETAL’s operations have a very low impact on their local environment, we are committed to continuously:
- Reducing our waste and fostering recycling or reuse whenever possible,
- Optimizing our water consumption and minimizing the level of contamination of our waste water, and
- Preventing and minimizing acoustic contamination and atmospheric emissions to preserve the quality of life of our local communities.
To implement this environmental policy, RETAL will set quantitative and qualitative targets and will report periodically on progress through relevant channels.
This policy will be reviewed periodically and updated, as necessary.
GRIEVANCE AND VIOLATION REPORT
RETAL encourages its employees and external stakeholders to report any concerns or suggestions that they may have regarding this policy and our impact on the environment, using our whistleblowing channel.
Approved by the Board of Directors of
RETAL INDUSTRIES LIMITED
Effective as from 01 November 2018
RETAL CODE OF BUSINESS CONDUCT
We at RETAL strongly believe that the adherence to high ethical standards and responsible behavior are essential for the development and maintenance of a successful and sustainable business.
This Code of Business Conduct (Code) outlines the principles and rules RETAL declares as the basis of its internal and external affairs, the foundation of all that we do, and the way we should reach our goals.
The content of the Code provides guidance and rules for our management, employees, contractors, and all others who are engaged with us in business and who share in our values and our approach.
The Code applies to all directors, officers, employees and representatives, hereinafter referred to as “employees” of the companies – members of RETAL including RETAL INDUSTRIES LIMITED and the legal entities under its control, each of which is referred hereto as the “Company” or “RETAL”.
All employees at RETAL must be familiarized with the Code and regularly reminded of its content. Directors, officers, and employees holding management positions are urged to continuously promote the values and principles declared in the Code. Violation of the Code and underlying internal policies and regulations may result in disciplinary action, including termination of employment.
Suppliers, service providers, and other contractors are called upon to adhere to the provisions of the Code when doing business with RETAL.
KEY PRINCIPLES AND VALUES
RETAL considers the following as its key values:
Fairness and respect - We value and treat each other with fairness and respect.
Taking ownership - Being accountable, dedicated and responsible for our actions.
Quality first - We do everything at RETAL with a strong attitude for high quality and continuous improvement.
Customer centric - We are a customer centric company, ensuring that our actions contribute to value for our customers.
Collaboration and partnership - We effectively partner and collaborate with customers, suppliers, and other stakeholders.
RETAL expects its management, officers, employees, and others who are charged with upholding the Code to ensure that every action they take in their position or role with the Company does not damage the Company or put its reputation at risk, is in line with the principles of the Code, is consistent with the Code, is in compliance with all applicable law, and positively impacts the Company.
The values of RETAL are reinforced by the principles and rules of business and professional behavior declared in this Code.
GUIDANCE AND CONCERNS; NON-RETALIATION STATEMENT
It is the obligation of the management at RETAL to provide guidance to employees on the interpretation and implementation of the provisions of the Code. Employees are urged to seek guidance from their immediate manager, Legal and HR functions, and the chief executive officer of the Company on the application of the Code and any underlying policies and regulations related to their job duties and professional responsibilities.
We expect and welcome all interested parties to share their good faith concerns regarding any violations of the Code or its underlying policies.
All managers and employees are obligated to promptly and properly report any violations they see or are aware of, to be proactive in preventing any wrongdoings, and to mitigate any risks to the Company.
RETAL also encourages its external stakeholders to report any suspected or actual violations of the Code and/or its underlying policies.
All reports and concerns, including those sent anonymously, may be provided:
- to the immediate manager or chief executive officer of the Company,
- to the head of the Legal function of the Company,
- to the head of the HR function of the Company,
- through RETAL whistle-blowing channel at [email protected], or
- by post to the Chief Legal Officer at the headquarters of RETAL:
RETAL INDUSTRIES LIMITED
To the attention of Chief Legal Officer
Industrial Area A
RETAL will not retaliate or allow any retaliation of any kind towards employees who report in good faith an actual or suspected violation of the Code and/or the underlying policies, regardless of the consequences for RETAL and its business. Any form of retaliation of a whistleblowing employee is a violation of this Code and should be reported immediately through the whistleblowing channel.
INVESTIGATION AND DISCIPLINARY MEASURES
All reports about violations and concerns will be properly considered with due care by the applicable corporate officers and senior management. The identity of reporters will be kept confidential to the extent allowed by the applicable laws and consistent with the goals of the investigation.
Proven violations of the Code and its underlying policies will be followed by disciplinary sanctions imposed in accordance with applicable law and may include dismissal. Apart from disciplinary actions, certain violations may lead to civil actions initiated by the Company against violators for compensation of damages and/or injunctive relief. Additionally, the Company may report to local law enforcement authorities any suspected violations of law that are discovered during the course of the relevant investigation.
PEOPLE AND WORKPLACE
HUMAN RIGHTS, RESPECT, AND FAIRNESS
RETAL is committed to respecting human rights and the fundamental principles and rights at work as defined in the United Nations’ Universal Declaration of Human Rights, the International Convention on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the International Labor Organization’s Declaration on the Fundamental Principles and Rights at Work.
Employees and contract workers in RETAL’s operations must always be treated with respect and fairness. Any type of violence, discrimination, unlawful child labor, forced labor, or other illegal labor practices are strictly prohibited.
RETAL recognizes, in accordance with local laws and regulations, its employees’ right to:
- Timely payment of fair and equitable wages and benefits, and
- Freedom of association and collective bargaining.
All people at RETAL are expected to share the values of the Company, to work with integrity and fairness, to treat colleagues, business associates, and partners with respect, and to be objective, diligent, and responsible in all affairs and activities while working in in any position for the Company.
RETAL does not tolerate physical violence, verbal abuse, bullying, threats, harassment, or offensive and disrespectful conduct. Employees witnessing violations of the Code are urged to immediately report their complaints and concerns to the HR function and/or senior management.
ANTI-DISCRIMINATION, DIVERSITY, AND INCLUSION
At RETAL, people are treated equally and fairly, based on their knowledge, professional qualifications, experiences, performance, and without regard to gender, race, color, ethnicity, national origin, sexual orientation, age, religion, disability or any other status protected by law. We do not discriminate and do not deny equal opportunity. We comply with all applicable laws governing labor relationships.
RETAL operates on two continents and diversity is one of the main characteristics of our workforce. RETAL considers its employees as the most important resource driving the company forward to help it reach its objectives. We welcome the good faith sharing of knowledge between our employees, we highly value the exchange of experience, and we support collaboration, teamwork, a friendly and cooperative working environment, and the appreciation and tolerance of cultural differences.
HEALTH AND SAFETY
RETAL puts the health and safety of its employees first, is strongly committed to the mitigation of occupational risks, and seeks continuous improvement by providing adequate workplaces, equipment, training, and procedures.
Health and safety is everyone’s responsibility. RETAL expects all of its employees, regardless of their position, activity, or the urgency of the task, to strictly obey all safety rules and regulations, comply with manufacturing and user guidelines, avoid unnecessary risks, and report unsafe conditions and/or any violations of these rules to senior management, the HR function, and/or the responsible safety officer.
RETAL will seek to continuously reduce its impact on the environment by decreasing, when possible, its consumption of energy, water, and other natural resources and by minimizing its emissions.
All RETAL companies must always comply with all applicable environmental laws and regulations. Officers and employees are expected to consider the environment in their day-to-day actions.
EXTERNAL COMMUNICATION, SOCIAL MEDIA
All public statements on behalf of RETAL are only to be made by authorized officers in the appropriate manner and time. Employees should always avoid statements or behavior which damages or risks the reputation and good name of RETAL and should always separate their personal viewpoints and opinions from the Company’s official position, including when using social networking platforms. Use of the name of RETAL, its logos, and trademarks should always comply with corporate identity policies as authorized by the Company’s management.
We expect people at RETAL to remain compliant with the Code when they are out of the office but are working within the scope of their employment with RETAL.
FAIR COMPETITION PRACTICES / ANTI-TRUST
We will compete with market players and deal with our customers and suppliers in strict compliance with the applicable competition and anti-trust laws and regulations. RETAL shall avoid unlawful anti-competitive activities and shall use only legitimate practices to succeed in business.
As unethical and unsustainable behavior can severely harm RETAL’s reputation and the reputation of its customers and provoke business disruption, RETAL will seek to gradually enforce compliance with its ethical and sustainability standards within its supply chain.
RETAL aims to continuously monitor the sustainability standards and performance of its suppliers and seeks to help them improve it, when necessary, using a collaborative and trust-based approach.
RETAL is a customer-centered company. Our goal is to produce and deliver products of the highest level of quality meeting all the applicable standards.
RETAL strives to ensure that all employees are sufficiently trained and have the required resources to:
- produce products that comply with the relevant quality standards,
- preserve that quality standard throughout our operations, and
- identify and report any wrong-doing or situation that may put at risk the quality of RETAL products.
Quality is everybody’s responsibility. We expect and encourage our employees to properly report any concerns that they may have in this regard to their immediate managers and to the chief executive officer of the Company.
BUSINESS ETHICS AND INTEGRITY
LEGAL COMPLIANCE; MONEY LAUNDERING
RETAL shall always be compliant with applicable law. The RETAL companies and their employees must obey all applicable laws and regulations in force in their countries and relevant to their business and conduct. Along with that, all officers, employees, and contract workers must adhere to all existing internal rules and policies.
RETAL shall not allow the use of its business for money laundering and shall comply with all relevant laws and regulations, including without limitation, reporting and record keeping obligations.
CORRUPTION AND BRIBERY
RETAL has a zero-tolerance policy towards any form of bribery or corruption in its business and maintains the appropriate internal policies prohibiting such actions.
RETAL strictly prohibits employee engagement in activities that are contrary to the interests of the Company and prohibits the abuse of a position to receive or maintain any personal benefit or advantage. RETAL prohibits bribery in any form, including those made to a public official, business partner, or individual, whether made in the form of money or service, to gain an undue advantage. Further, RETAL prohibits the solicitation or acceptance of such an undue advantage by an employee in exchange for refraining from, or acting contracting to, his or her statutory, managerial, and/or employment duties.
Employees are required, and all others are urged, to report violations and concerns related to corruption and bribery to the senior management and/or through the whistleblowing channel.
RETAL enjoys expressing its gratitude to its employees and associates and is grateful to everyone who wants to show appreciation of our work and business with a souvenir or other non-monetary gift. We allow the making and receiving of gifts as a goodwill gesture and sign of respect or gratitude. However, such gifts should always be symbolic, of nominal value, never in the form of cash or loan, and should never seek to influence the business decisions or other actions of the recipient. Local policies of RETAL and our business partners may be more restrictive and prohibit the making or receiving of gifts to employees of specific functions. Anyone who is about to make or receive a specific gift should ensure the gift is appropriate and compliant with the relevant practices. An employee may seek advice from a HR or Legal function specialist as needed.
CONFLICT OF INTEREST
RETAL’s managers and employees have the obligation to always act in the best interest of the Company. They must always try to avoid conflicts of interest or the appearance of it through the timely identification, disclosure, and management of any such conflicts.
A conflict of interest is a situation where the personal interests of an officer, employee, or third party (relatives, customers, suppliers, etc.) could influence the employee’s professional judgment and negatively affect his or her capacity to perform in the best interest of RETAL, or where it could be perceived as such.
A conflict of interest can arise where the presence of a personal relationship can influence our ability to act in the best interest of the Company. It can also arise when our assessment of a circumstance could be affected or appear to be affected by the possibility of a personal benefit. Even in those cases where we do not receive a personal benefit, the mere appearance of a conflict of interest may negatively affect our credibility.
RETAL’s employees must properly report any actual or potential conflict of interest to the supervising manager and/or HR or Legal function of the Company and aim to resolve the situation in a fair and transparent way while keeping the Company’s interests as the first priority.
USE OF COMPANY PROPERTY; PROHIBITION OF FRAUD
RETAL expects all of its managers, officers, and employees to protect the Company’s property, to use it in a proper, responsible, and professional manner, and only for a legitimate business purpose, unless and only to the extent explicitly permitted otherwise by internal rules or regulations or as authorized by management.
Company property includes both tangible and intangible assets and resources such as, but not limited to, land plots, buildings, premises, production facilities, offices, and other equipment, vehicles, communication devices, raw materials, goods, funds, receivables, intellectual property, information and databases, paper and electronic communication, company time, and other assets available at RETAL. To the extent permitted by law, RETAL may monitor the compliance with these regulations, including video surveillance and inspection of email communication, data, and files located on the Company’s equipment, devices, and corporate networks.
Any kind of fraudulent activity is strictly prohibited. Employees may not misuse or embezzle corporate property and resources, falsify corporate records, or submit fabricated or intentionally altered medical, travel, or other documentation.
DATA PROTECTION AND PRIVACY
RETAL upholds and takes very seriously the principles of privacy and confidentiality in the use and handling of personal data.
RETAL is committed to respecting the privacy of the personal data of its directors, officers, employees, job applicants, and other individuals who provide their data to RETAL. Only authorized personnel are authorized to process personal data and shall do so only for legitimate business purposes and in strict compliance with all applicable laws and regulations.
Confidential and proprietary information is any non-public information which, if subject to unauthorized disclosure, may harm the Company’s interests or favor the competition and deprive the Company of business opportunities.
All employees, especially those with management functions, must take all necessary measures to protect all confidential and proprietary information concerning RETAL or any of its business associates from unauthorized disclosure and use. Such information may only be used when required by a business need and only for the benefit of the Company.
RECORDS, BOOKKEEPING, AND REPORTING
The accuracy of the Company’s records and reporting is essential for the Company’s decision-making process, credibility, and sustainable business development. Officers and employees must ensure the accuracy and completeness of the data they create, record, and report. All business activities must be properly documented in accordance with applicable standards and internal rules. Holders of the corporate data must observe all document retention policies and procedures and, when applicable, cooperate with internal auditors and other authorized specialists carrying out audits and investigations.
IMPLEMENTATION AND GOVERNANCE
The Code and its subsequent versions will be communicated externally through the corporate website and internally to all RETAL employees to ensure its understanding and the proper implementation.
The Sustainability Steering Committee, a specially designated internal body, shall constantly monitor the sufficiency of the provisions of the Code for adherence of the Company to its principles. This Code will be periodically revised and updated, as necessary.
Approved by the Board of Directors of
RETAL INDUSTRIES LIMITED
Effective as from 01 November 2018
RETAL CODE OF CONDUCT FOR SUPPLIERS
As stated in its Code of Business Conduct, RETAL intends to run its operations and business in a responsible and ethical way across its value chain and expects business partners and suppliers to uphold the same principles. To enforce that commitment, RETAL has created this code of conduct for suppliers (The “Code”).
RETAL expects any suppliers of products and services, directly or indirectly engaged in a business relationship with RETAL to abide with the ethical principles and standards contained in this Code. RETAL expects its suppliers to effectively communicate the Code within their own organizations, as well as within their supply chain that is relevant to the products and services provided to RETAL.
IMPLEMENTATION AND COMPLIANCE
The Code will be available to all stakeholders on RETAL’s website and will be distributed to all RETAL personnel. Relevant employees will also be provided with adequate training and additional information to ensure the Code’s correct enforcement.
RETAL, in a collaborative, transparent and trust-based approach, intends to monitor and verify suppliers’ performance on Ethics, Environment, Human Rights, Labour Conditions, and Sustainable Procurement through various means, such as, but not limited to, CSR assessment platforms, desktop evaluation and/or announced on-site audits, in order to ensure compliance with the Code and to help them improve when needed.
RETAL expects suppliers to allow and cooperate in the monitoring and verification of their performance against the Code.
In case of non-compliance with the Code’s provisions, RETAL expects its suppliers to implement the relevant corrective actions.
Suppliers shall report in good faith any concerns or violation of this Code to their direct RETAL contact person or through the RETAL whistle-blowing channel: [email protected]
All reports will be duly investigated, and corrective action implemented when necessary. For more details on our whistle-blowing channel go to: https://www.retalgroup.com/policies/#policy3
- Suppliers shall conduct their business and interact with RETAL in an ethical, transparent and responsible way following values of integrity, honesty and fairness.
- Suppliers shall ensure knowledge of and compliance with all applicable legislation and regulation in all the jurisdictions in which they operate, in particular, money-laundering and fair competition laws.
- Suppliers shall eliminate and prevent any type of corruption and/or bribery in their sphere of influence, as well as conflicts of interest.
- Monetary gifts from suppliers to any RETAL employees are strictly forbidden. Gifts in form of goods, services or other are allowed but shall always be symbolic and not exceed an economic value of 50 EUR.
Human rights / Labour conditions
Suppliers must ensure the respect of human rights as stated in the Universal Declaration of Human Rights within their organization, supply chain and sphere of influence.
Suppliers shall respect Fundamental Principles and Rights at Work:
- Suppliers shall not employ or exploit children, shall not use or benefit from any form of forced or bonded labor.
- Suppliers shall recognize and respect their workers’ right to associate and collectively bargain without any type of discrimination against workers who join, or not, trade unions.
- Suppliers shall provide their employees with fair and decent working conditions in regards with working hours, remuneration, benefits, leaves and holidays.
- Suppliers shall not discriminate or deny equal opportunity to its current and future employees based on criteria such as gender, race, colour, ethnicity, national origin, sexual orientation, age, religion, disability or any other status protected by law.
- Suppliers shall ensure that their workplace are free from any type of harassment and abuse.
Health & Safety
Suppliers shall provide their employees and people working in their facilities a safe and hygienic workplace along with the relevant protective equipment, training and procedures to prevent occupational accidents and illnesses.
Suppliers shall ensure that all the products and services they provide comply with the legally applicable quality and safety standards as well as RETAL requirements stipulated in the purchase contact.
Suppliers shall respect all applicable environmental laws and endeavor to minimize the impact of their activities on the environment and local communities. RETAL encourages its suppliers to focus on mitigating climate change through the reduction of their direct and indirect greenhouse gases emissions.