Code of Ethics
Pogon 37

Eurobeton Company Code of Ethics

INTRODUCTORY PROVISIONS

Article 1.
In order to protect the reputation of Eurobeton dd (hereinafter referred to as: the Company), with the aim of providing services for the sale of products from the company’s product range and with the aim of achieving the Company’s vision of being a reputable and recognizable company that operates in accordance with the positive regulations of the Republic of Croatia and European practice through its business methods, business success and quality of services provided, the President of the Company’s Management Board adopts the Code of Ethics.

Article 2.
The values ​​expressed in this code are an expression of the business culture that is the result of many years of tradition in business. Thanks to the constant improvement and improvement of its products, the Company has reached high business standards year after year, acting responsibly, honestly and correctly, with full respect for clients and partners and respecting the rules of the profession and professional ethics, all with the aim of achieving maximum results and maintaining the Company’s reputation.

Article 3.
This Code of Ethics establishes the fundamental ethical values ​​and principles of good business conduct and operations. Through it, the Company expresses its values ​​and strives to align individual behavior with them. The Code of Ethics applies to all employees and the Company’s Management Board.
The Code of Ethics is public and through it all stakeholders and interested parties can become familiar with the behavior they have the right to expect from the Company.
This code has been developed in accordance with international conventions and principles related to the protection of human rights, the protection of workers’ rights, labor law and the fight against corruption, and prescribes the manner of doing business and conduct in accordance with them.

FUNDAMENTAL ETHICAL VALUES AND PRINCIPLES

Article 4.
The fundamental principles of good business conduct are based on the following principles and ethical values:

  • honesty
  • integrity
  • professionalism
  • transparency
  • decency
  • security
  • avoiding conflicts of interest
  • environmental responsibility
  • excellence
  • equality
  • equity
  • responsibility
  • value of a person
  • responsible use of resources.

Article 5.
Employees are obliged to apply the above principles as the highest values ​​of action in their relations with colleagues, clients, business partners, suppliers, competitors, as well as in their relations with the environment and the community.

PRINCIPLES OF CONDUCT IN RELATIONS WITH CLIENTS

Article 6.
The client who is the user of the Company’s products is the main backbone of the business and therefore must always be in the first place and in the center of attention.
The company has set as its permanent goal the maximum fulfillment of clients’ needs and expectations and the constant growth of the number of clients as a result of the satisfaction of existing clients and the high level of quality of products and services.
In their relationship with the client, the Company’s employees act professionally and politely, promoting the Company’s business values.

CONFIDENTIAL INFORMATION AND TRADE SECRETS

Article 7.
A trade secret is information that is designated as a trade secret by law or other regulation, the Statute and other acts of the Company, and which represents information whose disclosure to an unauthorized person could have harmful consequences for the business interests of the Company.

Article 8.
Persons who, as part of their work in the Company, gain access to or handle confidential data are obliged to maintain the confidentiality of the data during and after the termination of their duties or service, as long as the data meets the elements of confidentiality or until they are released from the obligation to maintain confidentiality by decision of the data owner.

TRANSPARENCY

Article 9.
The transparency of our actions, communication and contracts is the foundation of our behavior, in order to enable all our partners to make independent and conscious solutions and decisions.
The Company’s operations must be visible and recognizable.

PROHIBITION OF DISCRIMINATION

Article 10.
We do not discriminate against our clients based on their race, color, gender, religion, or national origin, with the general principle that all clients are treated equally.

Article 11
Striving to build an open and confidential relationship, with discussion and avoidance of conflict, the Company responds to inquiries and complaints/claims in a timely manner, striving for substantive, rather than strictly formal, solutions to disputes and ambiguities. The Company always has an ear and time for clients’ questions and suggestions, giving them importance and trying to implement them if possible.

In the event of financial difficulties of clients, the Company, taking into account its own interests, will act as a partner and express readiness for discussion and strive to avoid disruptions in business. Clients are also expected to report difficulties in a timely manner and cooperate fully, in accordance with mutual interests.

PRINCIPLES OF CONDUCT IN RELATIONS WITH EMPLOYEES

Article 12
The Company’s respect for the personality and dignity of its employees stands out as the foundation for developing a work environment imbued with mutual trust, loyalty and the commitment of each employee.
for the purpose of protecting the integrity of persons in the Company’s working environment, means are adopted and the necessary actions are taken to preserve the safety and health of workers.
The company does not use child labor or any form of forced or compulsory labor. Employment relationships are voluntary and based on mutual consent.
Workers are guaranteed freedom of association and the right to collective bargaining.

PRINCIPLES OF WORKER CONDUCT

Article 13.
When performing their jobs and work tasks, employees are obliged to act in accordance with the employment contract and the law, and to follow the decisions and instructions that regulate the Company’s operations.
They are obliged to perform the assigned tasks in accordance with the regulations and rules of the profession and to promptly and efficiently execute the orders of the Company’s Management Board, manager and/or superior relating to the Company’s operations and to perform the tasks of the position they hold without a special order.
Workers may be required, in accordance with their professional abilities and skills, to perform tasks that are not included in the job description of the position to which they are assigned, in exceptional or urgent cases.

OBLIGATIONS AND CONDUCT IN AND OUT OF THE WORKPLACE

Article 14.
The employee shall act professionally, impartially and decently. He/she must be careful not to diminish his/her personal reputation or the client’s trust in the Company in the performance of his/her duties, and must not, through his/her conduct, negatively affect the Company’s reputation or knowingly participate in activities that are contrary to the law, the Company’s acts and this Code. He/she must take care of his/her professional appearance and appropriate appearance in front of clients and third parties.
Employees of the Commercial Affairs Sector and all those who work with clients are required to dress appropriately, and exceptionally, on one day a week (Friday), they are allowed to dress more casually.

Article 15
Relations between workers are based on mutual respect, trust, cooperation, courtesy and patience. Workers do not interfere with others in the performance of their duties. Workers exchange opinions and information on individual professional issues.
A superior encourages his subordinates to perform their duties in a quality and efficient manner, to have mutual respect, appreciation and cooperation, and to have an appropriate attitude towards the client.
The employee must provide information to the client in a correct, thoughtful, helpful and well-intentioned manner, always keeping in mind the goals and objectives of the business policy and the reputation of the Company.

Article 16
Employees are expected to be professional, competent, objective and independent in their work, confidential and secret in their business, and data protection, honesty in their work and business, avoiding conflicts of interest, respecting human rights and environmental protection, and responsible management of the Company’s assets.
Every employee must be familiar with the provisions of this code.
The company strives to use equality and merit as the basis for assessing, evaluating, motivating and developing the careers of its employees.
Through constant education, training and efforts to improve the efficiency and quality of work, the worker should achieve a high level of professionalism and expertise, while respecting ethical principles and the dignity of the profession.

PROHIBITION OF DISCRIMINATION, HARASSMENT AND SEXUAL HARASSMENT

Article 17
Discrimination in employment, occupation, and promotion or demotion at work is expressly prohibited. In the spirit of equal treatment and consistent behavior towards all, favoritism, abuse, and discrimination of workers on the basis of gender, sexual orientation, language, religion, race, skin color, national or social origin, property status, birth, social position, political and trade union affiliation, age, marital and family status, health status, physical or mental disabilities, disability, genetic inheritance, gender identity or expression are prevented.
Discrimination is the treatment by which a worker/person is placed or has been placed or could be placed in a less favorable position than another worker/person on the basis of the previous paragraph in a comparable situation.
Harassment is any unwanted behavior caused by any of the grounds from paragraph 1 of this article, which aims or actually represents a violation of the dignity of a person/worker and which causes fear, a hostile, humiliating or offensive environment.
Sexual harassment is any verbal, non-verbal or physical conduct of a sexual nature, which has the purpose or effect of violating the dignity of a person/worker and which creates an intimidating, hostile, humiliating or offensive environment.

EVALUATION AND MOTIVATION

Article 18
The Company guarantees the same opportunities for professional development and growth and access to education and gives all workers the opportunity to express their individuality in their work, while appreciating the diversity and uniqueness of everyone as a basic contribution to the development of the Company.
The employee is obliged to ensure a high quality of professional work, improving professional skills and participating in professional development necessary for personal advancement and increasing the efficiency of the Company’s operations.
Respect for the personality and dignity of each worker is the foundation for developing a work environment imbued with mutual trust, loyalty and commitment of each worker. We create objective and transparent reward systems by anticipating possible and achievable goals. We facilitate work by simplifying procedures and forms of communication and guaranteeing health and safety through increasingly effective measures. We encourage policies that balance private and professional life, stimulating forms of flexibility and implementing initiatives to reconcile private and work obligations, aware that the private sphere is a fundamental part of every person’s life.

COMPANY ASSETS

Article 19
It is the duty of employees to safeguard the values ​​and assets entrusted to them. They are not allowed to use the Company’s assets, funds and property for personal gain or for inappropriate purposes, and they are not allowed to perform work for their own account that distracts them from their proper daily work activities.
Workers are required to use all resources they use in their work responsibly.

CONFIDENTIALITY AND SECRECY OF DATA

Article 20
It is a fundamental business principle that the reputation and trust of clients and business partners is based on confidentiality in performing business activities and the responsibility to maintain the confidentiality of data and information.
Confidential data and information about clients, suppliers, business partners, external collaborators and the company’s operations, as well as other sensitive data, the disclosure, transmission or other similar action of which would violate the confidentiality and secrecy of the data, must not be disclosed.

Article 21
Without prior and express approval from the Company’s Management Board, employees may not disclose information to the public or give statements and interviews to representatives of the media, or to third parties.

RECEIVING AND GIVING MATERIAL AND OTHER GIFTS

Article 22
Employees may not accept gifts, rewards or services from clients or other persons with whom the Company has a business relationship, except when they are gifts of symbolic value (up to 70 euros). When accepting symbolic gifts, it is important to avoid interpreting them as a means of coercion or a form of reciprocation.
If he receives a gift that exceeds the symbolic value and cannot be attributed to the usual relations of kindness, the worker is obliged to immediately inform his superior, who will make the appropriate decision.

CONFLICT OF INTEREST

Article 23
According to the principle of trust that the Company has towards its employees, and in the spirit of business transparency, employees are obliged, when fulfilling their duties, to avoid making decisions or carrying out actions that are contrary or in apparent conflict with the interests of the Company and are therefore incompatible with official obligations.
In the event of a conflict of interest, the employee is obliged to immediately inform his/her superior, especially in relations with clients, suppliers and competitors.

DATA RELIABILITY AND ACCURACY

Article 24.
Workers are required to keep records and record all data in a reliable, accurate and complete manner, in a timely and correct manner, following prescribed procedures. Each record should truthfully reflect the data from the basic documentation, which should be carefully preserved for verification purposes.
If an employee becomes aware of errors, omissions or falsification of records or data, he or she is obliged to immediately inform his or her superior.
Data on costs must accurately, precisely and completely show the actual costs incurred in accordance with the execution of actions.

PRINCIPLES OF CONDUCT IN RELATIONSHIPS WITH SUPPLIERS

Article 25
Employees in the organizational parts of the Company entrusted with the task of selecting suppliers and purchasing goods and services are required to adhere to objective, impartial and transparent criteria of judgment/procedures focused on competitiveness, quality, benefit, integrity, expertise, price, honesty, durability and the ability to guarantee effective and ongoing assistance and service.
We guarantee equal positions in the selection of suppliers and commercial partners, taking into account their possibilities to harmonize and adapt to the Company’s dimensions and needs.

PRINCIPLES OF BEHAVIOR IN RELATION TOWARDS THE ENVIRONMENT

Article 26
One of the foundations of the Company’s responsibility policy is environmental protection. This includes both direct (resource consumption, emissions of harmful substances and waste directly related to our operations) and indirect impacts that the Company has on the environment (activities and behaviors that the Company cannot directly control, since they are carried out by third parties with whom it comes into contact, as well as clients and suppliers).
In this sense, the Company guarantees full and thorough compliance with environmental protection legislation. We clearly express our opposition to energy waste and pay attention to the consequences of our decisions on the environment, striving for responsible and efficient use of resources.

IMPLEMENTATION AND CONTROL

Article 27.
The Company’s goal is to supplement its strategies, policies and business procedures with generally accepted principles and ethical values ​​from this code, and to verify and control the compliance of actions and behavior with generally accepted ethical norms.
Newly employed workers will be informed about the Company’s Code of Ethics upon employment.
In assessing the work of those with responsible duties, consideration will also be given to respecting the ethical principles on which the relationship with employees is based.

Article 28.
Each organizational structure monitors and guarantees compliance of its actions and operations with the principles and values ​​of this code. Therefore, in its area of ​​competence, it is directly responsible for the adoption of work plans and projects that clearly express the principles of behavior by which the Company is guided in its relations with clients and partners, respecting the interests of all.
Therefore, each function is obliged to conduct line controls within its jurisdiction and is responsible for detecting violations and non-compliance within its organizational part, as well as for reporting them to the competent person.

COMPLAINTS PROCEDURE

Article 29
To file a complaint about the behavior of employees on and off duty, which they believe is contrary to the provisions of this code, employees may contact the competent person (Company Secretary) or any other competent person of the Company (manager, executive director or management).

In the event of a complaint being submitted to another competent person in the Company, the latter will forward the complaint to the person responsible for receiving complaints, who is obliged to conduct the procedure for examining the merits of the complaint.

TASKS OF THE COMPETENT PERSON FOR RECEIVING COMPLAINTS

Article 30
The tasks of the person responsible for receiving complaints include the following:

  • promoting ethical behavior in employee relations and in employee relations with stakeholders,
  • monitoring the implementation of the Code of Ethics in the Company,
  • receiving, considering and analyzing complaints about violations of the Code of Ethics,
  • receiving complaints from workers and interested parties about unethical behavior by workers and possible conflicts of interest,
  • conducting a procedure for examining the merits of complaints,
  • keeping records of complaints received.

PROCEDURE FOR EXAMINING THE GROUNDS OF A COMPLAINT

Article 31
The person responsible for receiving complaints is obliged to conduct a procedure for examining the merits of the complaint within 8 days of receiving the complaint. The procedure is carried out independently or, if necessary, a committee is appointed to examine the merits of the complaint. It is necessary to examine the allegations and circumstances of the complaint, request statements from the complainant and the employee against whom the complaint was filed, and, if necessary, statements from other witnesses, and take all actions necessary to establish the facts.
The competent person for receiving complaints is obliged to carry out the procedure of examining the merits of the complaint also on the basis of an anonymous complaint.
The competent person shall prepare a report on the conducted examination, which shall be submitted to the President of the Management Board/Management Board/Company’s lawyer for a decision on further action and the severity of liability and sanctions in the event of a determined violation of ethical regulations and behavior contrary to the provisions of this code.
If the complaint concerns the person responsible for receiving complaints, the procedure for examining the merits of the complaint is carried out by the Administration.
All information determined in the process of examining the merits of a complaint is confidential.

FINAL PROVISIONS

Article 32
Each organizational unit of the Company monitors and guarantees the compliance of its actions and operations with the principles and values ​​of this Code of Ethics.

Article 33.
By concluding an employment contract, employees also accept the provisions of this Code of Ethics.

Article 34.
This Code of Ethics enters into force on July 1, 2024.

Gordan Miller
Company Director