Code of Conduct for Counterparties

The Counterparty undertakes to pursue its business objectives, while respecting the rules of law and order, ethics and human rights, in particular by applying the principal rules of conduct laid down below:

Compliance with law

Business and professional activities of the Counterparty shall be carried out in strict compliance with the law binding at all locations where these activities are carried out.


Ethical integrity

Business and professional activities of the Counterparty and the Counterparty’s employees (“employee” shall mean persons performing work on the basis of both employment contracts and civil law contracts) shall be conducted with respect for the values of integrity, in keeping with the principles of honesty, avoiding all forms of corruption and respecting the conditions and needs of the various entities involved.


The Counterparty shall promote, among its employees, the recognition and respect for acting in line with these rules.


Respect for Human Rights

All activities of the Counterparty and its employees shall be carried out with respect for human rights and public freedoms defined in the Universal Declaration of Human Rights.


The aforementioned primary rules translate into the following obligations:


Relations with and between employees

  • The Counterparty assumes responsibility for creating a work environment free from all forms of discrimination and behaviours showing any feature of violence directed against the people.
  • All employees shall be treated fairly and with respect by their superiors, subordinates and colleagues.
  • The Counterparty shall ensure a safe working environment for its employees, and undertakes to continuously update safety measures protecting against accidents and to strictly comply with applicable regulations at all locations where its activities are carried out.
  • All employees shall be responsible for unconditional compliance with the principles of occupational health and safety. They shall also be obliged to properly use the equipment assigned to them when performing hazardous work, to transfer to their colleagues and subordinates the knowledge in the area of work safety, and to encourage the application of appropriate precautions.
  • The Counterparty shall not allow minors to work. The Counterparty shall not employ minors or use in its business activities any products or services resulting from the work of minors, while taking care of the compliance with of regulations of the International Labour Organisation pertaining to the work of minors.


Obligations to third parties and the market

  • The Counterparty undertakes to refrain from any activities considered unfair competition, and undertakes to take care of the compliance with legal norms pertaining to the protection of competition rules.
  • The Counterparty shall not pay any bribes to authorities and public officials, and prohibits its employees from making and receiving from third parties undue payments of any kind, gifts, donations or favours not subject to the custom market activity, or that, due to their value, nature or circumstances may affect the development of trade, official and professional relationships, to which the company is a party.
  • The Counterparty accepts endeavours to achieve the highest quality of services provided as the guiding principle of its business activity.
  • The Counterparty shall do its best to meet expectations of its clients and shall make every effort to get to know their needs in advance.
  • Employees of the Counterparty shall be responsible for taking care of the company’s assets entrusted to them, while protecting them against any damage, loss, theft or improper, unlawful or unfair use.
  • The Counterparty guarantees maintaining the confidentiality of third parties’ data in its possession.


Obligations to the environment

  • The Counterparty undertakes to take care of the respect for the natural environment in the performance of its activities, and to minimize potential effects of these activities on the environment. The company shall provide its employees with all the necessary measures to achieve the aforementioned objective.
  • The Counterparty undertakes to strictly comply with environmental protection regulations.
  • The Counterparty shall be committed to the preservation of natural resources and protection of areas of special environmental, landscape, scientific or cultural value.
  • The Counterparty undertakes to act in a socially responsible way and to respect legal regulations of the country in which it carries out its activities.