1. Honesty, Integrity and Fair Play

Eksido and its employees are fully committed to the principle of honesty, integrity and fair play in the delivery of services and goods. All employees ensure that the business operations, applications for services, procurement or employee recruitment, are dealt with in an open, fair and impartial manner.

The Eksido Code sets out the basic standard of conduct expected of all employees and Eksido’s policy on matters like acceptance of advantages and conflict of interest of employees in connection with their official duties. The Eksido Code also applies to temporary and part-time employees employed by Eksido.

2. Equal Opportunity

Eksido is an equal employment opportunity employer. Employment opportunities are available regardless of race, color, sex, religion, national origin, age, disability or other legally protected status. This Principle applies to all aspects of the employment relationship, including recruiting, hiring, training, work assignment, promotion, transfer, termination, and wage and salary administration.

3. Safety and Health

Eksido is committed to an injury-free and illness-free workplace that is operated in an environmentally sound manner in compliance with all relevant laws and regulations that protect worker safety and the environment. Employees should perform work in a safe manner.

4. Fair Competition

Eksido’s policy prohibits any anti-competitive practices which can effect in bounding, restraining or distorting competition, as well as any practices of an unfair competition. Accordingly, our employees cannot agree (formally or informally) with competitors to:

  1. x prices or any other conditions of transaction
  2. to limit or control the production, commercialisation, technical development or investment
  3. to manipulate or divide markets or sources of provisioning
  4. to participate with fake offers in tenders or any other forms of competitions for offers
  5. to limit or restrain access to market and freedom of competition for other enterprises; to apply unequal conditions for equivalent performance to commercial partners, creating in this way a disadvantage in competition
  6. to condition signing of acceptance contracts by the partners for supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.

Our employees are prohibited from performing any act of unfair competition manifested through: misappropriating clients of a company by using the relations established with such clients within the function previously held at Eksido, dismissal or attracting employees of a company for the purpose of setting up a competing company to capture customers of that company or hiring employees of a company in order to disorganise of its work. At the same time, our employees must not take actions that harm the legitimate interests of consumers or other operations in breach of the competition law.

5. Governance and anti-corruption

Eksido has zero tolerance for corruption. All employees must never offer to provide anything of value directly or indirectly to government officials and business partners to secure an undue advantage. Eksido prohibits payment, offers of payment as well as anything of value directly or indirectly with the purpose of influencing or obtaining undue business or personal advantage.

Third parties will only be contracted to perform tasks which aid business interests provided:

  1. Fees to be paid are reasonable
  2. All arrangements are clearly documented
  3. Arrangements are in compliance with Eksido’s policies.

6. Financial Reporting

All transactions of Eksido must be duly recorded so as to permit preparation of clear financial statements in conformity with generally accepted accounting principles. No false or misleading entries may be made in the books and records of Eksido for any reason, and no employee may engage in any arrangement that results in such a prohibited act.

No undisclosed or unrecorded fund or asset of Eksido may be established for any purpose. No payment on behalf of Eksido (including those by cash) may be done without adequate supporting documentation or made with the intention or understanding that any part of such payment is to be used for any purpose other than as described by the documents supporting the payment.

From time to time, Eksido may publish or inform of policies on financial reporting, disclosure and compliance to reinforce the financial reporting expectations in the Eksido Code. All employees at any level are expected to implement and strictly follow these policies.

7. Agreements with Third Parties

Eksido does not condone activities that seek to gain an unfair competitive advantage. No individual may engage in any activity which violates any valid restrictive agreements entered into by that individual for the benet of a third party, and no individual may, directly or indirectly, use or disclose any confidential information or trade secrets of a third party that the individual obtained while employed by or associated with such third party.

8. Government Contracts and Services

Eksido is committed to complying with all applicable laws and regulations relating to government (public procurement) contracts and services and to ensuring that its reports, certifications and declarations to government officials are accurate and complete and that any deviations from contract requirements are properly approved.

9. Acceptance of Advantages

It is the policy of Eksido to prohibit all employees from soliciting or accepting any advantage from any persons having business dealings with Eksido (e.g. clients, suppliers, contractors). Employees who wish to accept any advantage from such persons should seek advice and permission from the Eksido Ethics Officer. Any gifts offered voluntarily to the employees in their official capacity are regarded as gifts to Eksido and they should not be accepted without permission. By default, employees should decline the offer if the acceptance could be perceived as against the interest of Eksido, or that of society, or lead to complaints of bias or impropriety.

For gifts presented to employees in their official capacity and of low nominal value ( maximum 100 EUR ), the refusal of which could be seen as unsociable or impolite, can be exceptionally accepted. In other circumstances, the employees should seek for a clear (i.e. in writing) and immediate ( within 5 days from the offer ) consent from the Eksido Ethics Officer to accept the gifts.

The Eksido Ethics Officer should keep proper records of the applications and permissions. Each permission will indicate the name of the applicant; the occasion of the offer; the nature and estimated value of the gift, and whether permission has been granted for the applicant to retain the gift or other directions have been given to dispose of the gift. The permissions must be signed and dated by both the Eksido Ethics Officer and the applicant.

10. Conflict of Interest

A conflict of interest situation arises when the “private interests” of the employees compete or conflict with the interests of Eksido. “Private interests” means both the financial and personal interests of the employees or those of their connections including:

  1. Family members and other close affiliates
  2. Personal friends
  3. The clubs, networks and societies to which they belong
  4. Any person to whom they owe a favour or are obligated in any way
  5. Former and future employers

Employees should avoid using their official position or any information made available to them in the course of their duties to benefit themselves, their affiliates or any other persons with whom they have personal or social ties. They should avoid putting themselves in a position that may lead to an actual or perceived conflict of interest with Eksido. Failure to avoid or declare any conflict of interest may give rise to criticism of favouritism, abuse of authority or even allegations of corruption.

In particular, employees involved in the procurement process should declare conflict of interest if they have beneficial interest in any company which is being considered for selection as Eksido supplier of goods or services. When called upon to deal with matters of Eksido for which there is an actual or perceived conflict of interest, the employee member should make a declaration in writing to the Eksido Ethics Officer. He should then abstain from dealing with the matter in question or follow the instruction of the Eksido Ethics Officer who may re-assign the task to other employees.

11. Misuse of Official Position

Employees who misuses their official position for personal gains or to favor their relatives or friends are liable to disciplinary action or even prosecution. Examples of misuse include a employee member responsible for the selection of suppliers giving undue favor or leaking information to his/her relative’s company with a view to giving away an undue advantage.

12. Information Handling

Employees are not allowed to disclose any classified or exclusive information to anybody without authorization. Employees who have access to or are in control of such information should at all times provide adequate safeguards to prevent its abuse or misuse. Examples of misuse include disclosure of information in return for monetary rewards, or use of information for personal interest. It should also be noted that unauthorized disclosure of any personal data may result in a breach of the applicable legislation on privacy.

13. Eksido Property

Employees given access to any property of Eksido should ensure that it is properly used for the purpose of conducting Eksido’s business. Misappropriation of the property for personal use or resale is strictly prohibited.

14. Outside Employment

Employees who wish to take up paid outside work, including those on a part-time basis, must seek the written (date and signed) permission and guidance from the Eksido Ethics Officer before accepting the job. Approval will not be given if the outside work is considered to be in conflict with the interest and values of the corporation.

15. Compliance with the Eksido Code

It is the personal responsibility of every employee to understand and comply with the Eksido Code. Every employee shall sign a declaration of Principle to this purpose. The Eksido Ethics Officer or other mandated employee will keep declarations of Principle. Higher ranked employees should ensure that their subordinates understand and comply with the standards and requirements stated in the Eksido Code. Any doubts of interpretation or problems encountered, as well as any suggestions for improvement, should be addressed to the Eksido Ethics Officer for consideration and advice.

Any employee who violates any provision of the Eksido Code will be subject to disciplinary action. In cases of suspected corruption or other criminal offences, a report will be made to the appropriate authorities.

16. Sanctions

Eksido can take prompt and appropriate remedial action in response to violations of the Eksido Code. Any employee who engages in conduct prohibited by the Eksido Code as determined by the Eksido Ethics Officer will be subject to discipline actions and sanctions in accordance with the labor law.

Once a complaint has been placed, the Eksido Ethics Officer will initially analyze it and s/he may meet privately with the applicant to understand the facts surrounding the issue. Following a fact-finding phase, an investigative meeting could be held with the employee alleged of the violation, to further ascertain the facts and receive observations. The decision should be issued in writing (date and signed), indicating a summary of the facts, reference to the specific violation and motivations.

  1. Warning;
  2. Private or public letter of reprimand;
  3. Transfer to other tasks or unit;
  4. Suspension from duties;
  5. Termination or removal.

In every case of violation, the employee will be fined for an amount estimated between a 1/5 (one fifth) and 5 (five) times the most recent monthly salary. The fine will be applied through a direct deduction from the employee’s following salary or any past credit s/he may have towards Eksido. The Eksido Ethics Officer shall report serious violations to appropriate government or legal authorities.

17. Reporting

Employees have a responsibility to promptly report to Eksido any violation of the Eksido Code. Eksido have put in place an appropriate mechanism as to allow employees to address communications to the Eksido Ethics Officer with the highest degree of trust and confidentiality.

Employees will not be disciplined or retaliated against in any way for reporting violations in good faith. Retaliation against any employee for reporting policy violations, or for testifying, assisting or participating in any manner to inspections is strictly prohibited. Any employee who believes he or she has been subjected to or has witnessed retaliation must immediately report the alleged retaliation to the Eksido Ethics Officer.

“Employees have a responsibility to promptly report to Eksido any violation of the Eksido Code. Eksido shall put in place an appropriate mechanism (i.e. complaints/suggestion boxes, telephone, emails, etc.) as to allow employees to address communications to the Eksido Ethics Officer with the highest degree of trust and confidentiality.
Employees will not be disciplined or retaliated against in any way for reporting violations in good faith. Retaliation against any employee for reporting policy violations, or for testifying, assisting or participating in any manner to inspections is strictly prohibited. Any employee who believes he or she has been subjected to or has witnessed retaliation must immediately report the alleged retaliation to the Eksido Ethics Officer.

18. Eksido Ethics Officer (EEO)

The Eksido Ethics Officer (EEO) is appointed inside Eksido. The EEO is a person of trust, independence and competence; s/he is prepared, trained and/or certified in dealing with matters related to the Eksido Code. The EEO performs his/hers duty with the utmost tact, confidentiality, respect, fairness and proficiency.

The EEO handles day-to-day compliance matters, including:

  1. Receiving, reviewing, investigating and resolving concerns and reports on the matters described in the Eksido Code;
  2. Interpreting and providing guidance on the meaning and application of the Eksido Code; and
  3. Reporting periodically and as matters arise to senior employee of Eksido on the implementation and effectiveness of the Eksido Code and other compliance matters, and recommending any updates or amendments to the Eksido Code deemed necessary or advisable.