Code of Conduct

We always act in compliance with the law and with ethical principles and rules. We respect the legally effective decisions of the public authorities.

We do not tolerate any unlawful or unethical conduct.

• Unlawful conduct means any act which contravenes (or circumvents) applicable law of a relevant country, or promulgated international treaties. An unlawful act is particularly conduct which satisfies elements of a crime, of an administrative transgression, or which conflicts with legally effective decisions of public authorities or internal regulations of the Group.
• Unethical conduct means any act inconsistent with the rules of common morality, though not necessarily contrary to the law.

We actively prevent and forestall both unlawful and unethical conduct in the Companies.

We make a maximum effort to prevent any unlawful conduct of individuals which could give rise to the criminal liability of a legal entity. Everyone is obliged to act in compliance with legal regulations in such a manner so as to prevent the commission of crime of individuals which could be attributed to a legal entity under sec. 8 of Act No. 418/2011 Sb, regulating the criminal liability of legal entities and proceedings against them, as amended.

Should an Coworker decide to commit a crime within the framework of fulfilling their work duties, the criminal act is attributable to and criminal liability arises for the Coworker, not a Company.

We treat all our co-workers with respect and dignity, fairly and politely. We value building a relationship based on mutual respect and trust with all Coworkers, while expecting our Coworkers to comply with all fundamental ethical principles and rules.

In relation to all our co-workers we recognize and respect international human rights treaties and laws such as: the principles of United Nations Global Compact, the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, Charter of Fundamental Rights of the European Union or European Convention on Human Rights.

We do not tolerate any forms of child labour. We do not employ minors under the age of 15 nor minors, who did not finish compulsory schooling and we always adhere to the laws on the employment of adolescents. Adolescent employees are prohibited to perform hazardous work, overtime, work at night or activities that endangers their personal, mental, physical or social development.

All forms of forced labour or other types of involuntary work are prohibited. We do not allow any practises, that would restrict free movement of our co-workers.

We create and develop a favourable work environment and conditions for our Coworkers. At the same time, we support our Coworkers in their professional and personal development, and we take an interest in the expansion of their skills and abilities.

In compliance with the relevant legislation (including legislative requirements on minimum wage or compensation for overtime), we provide fair compensation and fringe benefits to our employees. We comply with legislation on working hours including overtime.

We reinforce the development of diverse and inclusive company culture, as well as the associating of our Coworkers.

We respect the privacy of our Coworkers.

Coworkers are required to participate in trainings aimed at ensuring, among other things, that they always act in the desired manner, i.e. ethically and in accordance with legal and internal regulations.

Equality and respect are our utmost priority. Discrimination of any nature is unacceptable.

• We do not tolerate any form of discrimination whatsoever, be it based on gender, race, nationality, ethnicity, sexual orientation, religion, age, disability, or anything else.
• We do not discriminate against any Coworker or an applicant for a job on the grounds of their personal features unrelated to a work position (e.g. political opinions).
• All Coworkers have equal opportunities for promotion, for the development of their skills and education, as well as for professional opportunities.

Everyone must strictly observe all safety regulations, technical standards and processes at work. Details are provided for in an internal regulation.

We care about preserving the goodwill and reputation of all Companies and of the Group. 

All Coworkers are required to act with loyalty to each and every Company in the Group, and they must not damage their goodwill or reputation. Should anyone act as a representative of any of the Companies, they must always act with regard to the goodwill of the Company, and, as a matter of principle, they must only represent the standpoint of the Company, not their own standpoint and opinions. Anyone authorized to act on behalf of a Company is required to always act in compliance with the scope of the authorization, i.e. within its limits.

The goodwill of the Companies and of the Group is always jeopardized by violations of the law(unlawful conduct), particularly by acts bearing the elements of crime (fraud, bribery, scheming in public tenders), unfair competition practices, as well as unethical conduct or unreasonable criticism of the Companies.

When making decisions regarding business and internal matters, it is always necessary to take into account the possible reputational consequences of the intended acts.

We pride ourselves on our professionalism and always provide our services in compliance with the law and with professional rules and standards and with due quality. We wish to be successful, but not to the detriment of legal regulations and ethical principles. We treat our business partners with respect and dignity, fairly and politely. We always strive to meet the required quality, quantity, deadlines, and budget. We always inform our business partners truthfully and in a timely manner of all substantial facts influencing our mutual cooperation, and we heed the timely performance of our obligations.

We only cooperate with business partners who act in compliance with legal regulations and ethical principles, and whose legitimate needs can be satisfied with our quality services.

We endeavour to ensure that business partners of the Group be familiar with this Code of Conduct, and we require that they act in compliance therewith.

In relationships with our business partners, we also highly value mutual respect and fairness.

We vet our business partners and avoid business relations which pose a risk in terms of adherence to laws and ethics.

We avoid business relations with untrustworthy persons with doubtful reputations.

We vet our potential business partners in a manner permitted bylaw (due diligence), and we assess any possible risks that might arise from a contractual relationship at issue. Should the relationship be risky or in the case of any doubt, the relationship is not entered into.

We abide by the regulations fighting money laundering and promotion and the financing of terrorism (“AML”). We particularly comply with relevant legislation.

• Money laundering occurs when money or other property values originating directly or indirectly from criminal activities are put into lawful economic circulation so that their origin is disguised.
• The financing of terrorism occurs if money or other resources are provided for criminal terrorist activity or for the support of terrorist organizations.

Everyone is required to prevent money laundering and the financing of terrorism; for those purposes, everyone is particularly required to observe the following rules:

• to carefully vet the identity of customers and clients, business partners and other external entities that a Company intends to enter into a business relationship with;
• to avoid suspicious transactions, e.g. with entities with a non-transparent structure, or with performance which does not correspond to the objects of a business partner;
• to accept payments in cash only up the legal limit;
• to only accept payments made to the Company’s accounts published by the relevant tax authority in a manner allowing remote access, or to accounts at reputable banking institutions;
• to match incoming payments to corresponding fulfilments without undue delay and to post them.

We adhere to legal regulations providing for international trade, we respect the resolutions of the United Nations Security Council, as well as the decisions and regulations of the EU Council and the EU Commission regarding international sanction measures, if they are valid and effective in our country. We do not participate in transactions which conflict with sanctions imposed on states, organizations or persons, and/or which otherwise conflict with legal regulations governing international trade.

We comply with the legal regulations and standards for bookkeeping and financial reporting, as well as tax and customs regulations.

We consistently record all financial transactions and keep accounts thereof in accordance with the applicable rules and standards. Our priority is transparency and accuracy in accounting. Details on bookkeeping are set out in internal regulations.

We publish financial statements in a timely manner and fulfil our duties towards financial administration bodies.

We comply with the rules for fair competition, and we encourage and promote transparency and objectivity in public tenders and public contracts.

We neither make agreements nor coordinate our activities with other competitors in a manner which could unlawfully distort competition. In the case of mergers and acquisitions, we take care that no unlawful joinder of competitors occurs. We disapprove of all unfair competition practices, such as false advertising, bribery, the abuse of trade secrets and the like.

For those purposes, we particularly adhere to the following rules of conduct:

• not to enter into relationships and make contacts with competitors which might give rise to a suspicion of participation in prohibited agreements or provisions capable of distorting fair competition;
• not to enter into contracts with competitors which would restrain or co-ordinate conditions for mutual competition;
• not to co-ordinate with other competitors when participating in public tenders;
• not to disseminate untrue information about competitors or their products.

All Coworkers are required to avoid conflict of interest, which occurs when their personal interests may possibly collide with the interests of a Company.

A conflict of interest arises if the interests of any of the Companies conflict with the interests of a member of any of its bodies or the interests of an Coworker (or their close persons), and there is a risk that the person on the part of whom the conflict of interest occurs may give priority to their own interests (or the interests of their close persons) over the interests of the Company. Such situations are undesirable because one is required to only act in the best interest of a Company, disregarding one’s own interests.

It is irrelevant whether or not a person on whose part there is a conflict of interest actually prioritizes their own interest to the detriment of a Company. The mere existence of conflicting interests is undesirable.

Anyone who finds themselves in a situation of an existing or highly possible conflict of interest will immediately inform an Authorized Person, who will ensure that a reasonable remedial action is taken, e.g. by delegating the management of the(business) transaction to another person.

It is prohibited to carry out activities which might be regarded as corruption/bribery or undue influence for the purposes of obtaining an unjustified advantage for a Company.

Corruption means directly or indirectly asking for, offering, providing or accepting bribes which interfere with the due performance of duties or acts required from a recipient of the bribe (impermissible advantages or prospects thereof). A bribe is anything that serves to influence persons who have, or may have, decision-making powers with the aim of obtaining an unjustified advantage.

Examples of bribes:

• unreasonable gifts, trips abroad or expensive conferences with costs being covered, obtaining a job, activity allowances, and other forms of favours or values of various natures.

The following things usually are not bribes:

• petty courtesy gifts of low value provided occasionally within the framework of good relationships (petty marketing gifts, an invitation to a Christmas party, a symbolic significant anniversary present, such as a theatre ticket and the like).

It is, in particular, prohibited to request, accept/offer, promise or give bribes. We always treat and communicate with public officials and other persons representing public institutions, as well as with business partners from the private sector, transparently and in compliance with the law. Avoid influencing public officials, or representatives of business partners, by providing or promising bribes.

We adhere to the international anti-corruption standards listed in the UN Global Compact Initiative.

Donations, sponsoring

We provide purpose-linked funds in compliance with the principles of social responsibility expressed in this Code of Conduct, particularly in order to support the activities of the Gee-Gee Foundation, whose mission is to help our Coworkers who have fallen into difficult life situations, as well as their loved ones, particularly children. All projects are supported on a charitable basis.

Accepting gifts

Coworkers must not accept from business partners any gifts or other social favours of unreasonable value beyond the value of petty courtesy gifts.

When performing their activities for a Company, all Coworkers are obliged to consistently comply with legal and internal regulations, as well as with company rules regarding cybersecurity.

When performing activities for Company, nobody can engage in activities which might pose a risk to the cybersecurity of this Company, its business partners, clients, or anyone else.

Details are provided for in internal regulations.

Company also actively cooperates with all relevant public authorities if such cooperation is desirable in order to ward off cybersecurity events and incidents.

Everyone is obliged:

• to comply with all security measures and procedures, as well as to strictly adhere to rules related to setting passwords, access rights and permissions;
• to make a maximum effort to minimize the risk of cybersecurity events and incidents;
• to observe principles of cybersecurity in relation to the information systems of the Companies, and to take measures to minimize the risk of loss of, damage to, or abuse of data and the systems;
• to take suitable measures, within the scope of their competences, to prevent, detect and respond to possible cyber threats;
• in cases of a suspected, even contingent, cybersecurity incident or event, be it only potential, or of a breach of cybersecurity policies, to immediately inform Authorized Persons for the purposes of a prompt response and the mitigation of damages;
• to continuously educate themselves in the field of cybersecurity, and to regularly get information regarding new threats and defence practices in that area, in the extent corresponding to their job assignment (services provided);
• to actively cooperate with other Coworkers of a Company with respect to the issues of the prevention and resolution of cybersecurity events and incidents, in the extent corresponding to their job assignment (services provided);
• to immediately report any possible weak spots in the systems of a Company to Authorized Persons.

Everyone is personally responsible for:

• the protection of their access data, passwords, and other authentication means which they use in their activities, and which must not be disclosed to third persons.

Everyone is actively involved in:

• the enhancement of the level of cybersecurity of the Companies and their business partners;
• evaluating and updating cybersecurity protocols and policies, and in the implementation of new technologies in order to keep up with ever-changing threats and best practices.

It is important to us that handling personal data is always done in compliance with the law [for example in the EU countries particularly Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”)].

We only process personal data for legitimate purposes following from legal regulations, contractual relationships, or based on consent granted by personal data subjects. We take care to prevent unauthorized access to personal data.

Everyone is obliged to protect the personal data and privacy of the Coworkers and business partners of the Companies.

Details are provided for in internal regulations.

We protect information important for our business, as well as information important for the business of our business partners. This includes, in particular, trade secrets, operation information, and technical know-how.

We also protect intellectual property; we respect the patents, trademarks, copyrights, and other intellectual property rights of our business partners and of other persons.

When exploiting products of third persons, which are subject to protection by intellectual property rights, we ensure that the necessary licence rights be secured with regard to the intended purpose of use.

All Coworkers are obliged to protect:

• intellectual property rights, confidential information and trade secrets of the Companies, the duty of which survives any contractual relationship.

We protect the confidential information of our business partners; thus:

• no one can provide such information to third parties, or disclose it or make it available in any way whatsoever to third parties without the consent of the business partner.

Everyone may only use lawfully acquired and licenced information technologies and software. Everyone is only allowed to use software, hardware, and content in compliance with the relevant licences or terms of use.

The tangible and intangible property of the Companies serves to support Coworkers in completing work tasks and attaining the goals of the Companies. The tangible and intangible property can only be used in compliance with internal regulations.

Everyone is obliged to protect the tangible and intangible property of the Companies entrusted to them, to care for it as a diligent manager, and to comply with the legitimate purpose of the use of the property. Everyone is obliged to handle the property of business partners in a similar way.

Except as expressly allowed in internal regulations, neither tangible nor intangible property may be used for purposes outside the employment. Should a Company terminate the employment of or cooperation with an Coworker, he/she is obliged to return everything that is the property of the Company, including all materials and documents that are of a confidential or internal nature.

We comply with all legal regulations and standards in the field of environmental protection.

In order for the Companies in the Group to satisfy all their obligations in the field of environmental protection and sustainability:

• we always act in a reliable and ethical way, and we strive to minimize any adverse impacts of our activities on the environment;
• we continuously develop and adopt measures to enhance energy efficacy, to minimize the production of waste, and to decrease carbon emissions and water consumption;
• we place great emphasis on and encourage recycling, and we deem it important that everyone in the Companies recycles waste;
• we expect our clients and suppliers to share our commitments.

The Companies in the Group endorse the protection of fundamental human rights, and they do not partake in activities that encroach upon those rights. The Companies endeavour to act in a responsible way and to contribute to the development of their environs. The Companies respect the local laws, customs and traditions of the countries in which they operate. The Companies are open to and communicate willingly and in a timely manner with all stakeholders affected by their business activities.

The Companies have a long history of promoting and developing a smoke-free environment.

We actively support charitable and educational activities and provide long-term and systematic support to those activities. We particularly support organizations aiming to educate young people and develop their talents. The choice of institutions we cooperate with reflects the values and conservative approach expressed in this Code of Conduct.

We also help people who, through no fault of their own, have fallen into a difficult life situation which they cannot cope with by themselves. An example is the Gee-Gee Foundation.

In compliance with the relevant legislation (i. e. in the Czech Republic Act No. 171/2023 Sb., on the protection of whistleblowers [zákon č. 171/2023 Sb., o ochraně oznamovatelů] and in the Slovak Republic Act No 54/2019 Sb., on the protection of whistleblowers [zákon č. 54/2019 Z. z., o ochrane oznamovateľov protispoločenskej činnosti a o zmene a doplnení niektorých zákonov], the Companies have established an internal reporting system which serves to report unlawful and unethical conduct, and which can be used by the Coworkers, as well as by other entities that reliably become aware of unlawful or unethical conduct in any of the Companies.