06 September 2021
Aim
The Emtex Code of Ethics and Business Conduct (CEBC) provides basic requirements for business conduct and serves as a foundation for Emtex policies, procedures, guidelines, and work instructions, and company values. The CEBC not only contains actual guidelines that employees are expected to adhere to in the conduct of Emtex’ business, but also information about how this CEBC functions, including who administers the CEBC, who can provide guidance regarding the CEBC, and how violations may be reported, investigated, and punished. We, at Emtex, truly care for our customers and respect the people with whom we work, and must therefore remain vigilant that our words and actions reflect the right behavior, guided by our company values.
Emtex aims to attract and retain employees who are passionate about delivering their work with leadership, fairness, honesty, and according to high-quality standards. We recognize that we have a responsibility to each other and to our customers to uphold our principles of integrity. We achieve this objective by conducting our business honestly and transparently. We encourage an open culture where ideas and information can be exchanged, advice can be sought, and concerns can be raised, without fear of retaliation. This will allow us to serve our customers to our best potential, provide opportunities to our employees, and create sustainable financial results.
Compliance with our CEBC is about creating this exact environment. Emtex expects its employees to exercise reasonable judgment when conducting its business, and encourages its employees to refer to this CEBC frequently to ensure that they are acting within both the letter and the spirit of this CEBC. Emtex understands that this CEBC will not contain the answer to every situation the employee may encounter or every concern the employee may have about conducting Emtex’ business ethically and legally. In these situations, or in case of any questions or concerns about this CEBC, Emtex encourages each employee to speak with his or her supervisor or manager (if applicable). Whenever Emtex becomes aware of a violation of the CEBC, Emtex will act to address the problem and prevent future occurrences. Corrective and preventive steps might be taken, depending on the circumstances, and could include training, counseling, disciplinary actions, and even termination of employment.
Every employee must be familiar with and follow relevant laws, regulations, and Emtex policies and procedures that govern the business activities in which the employee engages. Furthermore, it is the personal responsibility of each employee to read, understand, and adhere to the CEBC. Updates of the CEBC may be provided periodically. Guidance and support is available to help employees understand the CEBC and to help them make the right decision when faced with an ethical dilemma. When in doubt about the meaning of the CEBC or its application to specific circumstances, employees are encouraged to seek advice with their supervisor or manager.
No employee shall engage in any unlawful activity in conducting Emtex’ business or in performing his or her day-to-day company duties, nor shall any director or employee instruct others to do so. Ignorance of the law is no excuse. Employees are encouraged to speak out and report any concerns or suspicion that the CEBC is being or will be violated. Independent of anonymous reporting, one should provide as many details as possible, so the issue can be addressed thoroughly and promptly. In addition, one has a responsibility to cooperate in any investigation following violation of the CEBC or local law. Emtex does not tolerate any form of retaliation against or adverse consequences for anyone who seeks advice or raises a concern regarding this CEBC, or assists with an investigation. Any employee who engages in retaliation risks disciplinary action, which could include termination of employment.
Bribing and Corruption
All Emtex services must be undertaken professionally and honestly, in accordance with agreed company standards, methods, and policies. In order to maintain its independence of judgment, Emtex does not permit or condone bribes, kickbacks, or other improper payments, transfers, or receipts. No director or employee should offer, give, solicit, or receive any money or other item of value for the purpose of obtaining, retaining, or directing business or bestowing or receiving any kind of favored treatment. Emtex does not engage the services of third parties to offer bribes, illicit commission or kick-backs on its behalf. No gift, hospitality, or entertainment should be offered or accepted if they influence improperly or create the appearance of an improper influence on business decisions. Gifts, hospitality, or entertainment shall not exceed what is usual in normal business relations and must be avoided if acceptance could be damaging to the reputation of Emtex, based on common sense.
All findings must be adequately documented and no untruthful or misleading reports or certificates issued. Findings and opinions issued by Emtex are to be supported.
Privacy
Emtex collects, processes, and discards personal information complying with local laws and Emtex privacy policies. Personal information should be collected only for legitimate business purposes, shared only with those who are allowed access, protected in accordance with security policies, and retained only for as long as necessary. Emtex must also ensure that third parties with access to personal information are contractually obligated to protect it.
Fair Treatment
At Emtex, all employees are expected to treat their fellow employees with respect, dignity, and fairness. Employees must be truthful and respectful at all times in dealing with their staff members, colleagues, and management. This not only extends to Emtex’ customers and suppliers, but also to its employees and management. A safe, clean, and welcoming place is provided where different thoughts, abilities, experiences, and individual characteristics enrich the work environment and potentiates better business decisions. Every employee has to promptly report unsafe or hazardous conditions and comply with all policies, laws, regulations, and standards relating to conditions of employment, including those concerning hours, wages, and other working conditions, and comply with applicable workspace safety.
Emtex provides equal opportunities for employment, and bases employment decisions on qualifications, skills, and achievements. Emtex does not tolerate discrimination based on characteristics such as age, gender, race, ethnic background, sexual orientation, gender identity, national origin, or religious beliefs, and does not tolerate any kind of harassment, abuse, or bullying.
Emtex conducts its business using competitive and fair market practices. It does not engage in any understanding or agreements with competitors with the effect of biasing or improperly influencing the markets in which it operates. Emtex does not engage in discussions regarding pricing, contractual terms, market allocations, division of territories, or customers. Emtex does not discuss competitive bid processes with competitors, and does not market its services and capabilities in a deceptive or misleading way, or makes disparaging or untruthful allegations regarding competitors. Emtex does not obtain confidential information on competitors by using illegal or unethical means.
Social media includes any digital communication channels that allow individuals to create and share content and post comments. Employees must comply with all policies in their use of online media, and should be polite and respectful. Employees should be mindful of the content created, shared, and posted. Always use good judgment when engaging in social media.
Environment and Sustainability
Emtex endeavors to reduce the impact of its activities on the environment by promoting the efficient use of natural resources, reducing and preventing pollution, and minimizing emissions of harmful substances and greenhouse gas emissions. Employees must be provided with durable working environments, conditions, and equipment. Employees are expected to report and record any work-related accident or pollution incident as required by Emtex policies or relevant laws. No employee will be penalized for reporting an accident or pollution incident.
Financial Integrity
Information recorded in Emtex’ financial records must be true and fair, timely, and accurate. All transactions must be properly and accurately recorded and book entries must be supported by proper documentation issued by bona fide parties. All records must be retained in accordance with applicable laws and Emtex policies.
Property
Loss, theft, and misuse of Emtex’ assets has a direct impact on Emtex’ reputation, business and its profitability. Employees and directors are expected to protect Emtex’ assets that are entrusted to them and to protect Emtex’ assets in general. Employees and directors are also expected to take steps to ensure that Emtex’ assets are used for legitimate business purposes only, in accordance with Emtex policies. It is not permitted to use Emtex assets or resources for any form of personal benefit or to perform work for an external party. Employees must apply the same degree of care when being exposed to customers’ intellectual property.
Employees should set up complex passwords and should never share these. Confidential information should not be stored on unapproved Internet or cloud services. Employees should never talk about intellectual property and confidential information in public places, nor share with external parties.
Use of e-mail, internet, and other modes of electronic communication may be monitored and audited by Emtex (when permissible under relevant privacy laws) when suspicion of abuse arises.
External Communication
No employee shall speak on behalf of Emtex, discuss or disclose any information regarding Emtex to the media, to financial analysts, to current or potential investors, or issue any public statement on behalf of Emtex, unless specifically authorized to do so. Personal opinions, with regards to religion and politics, or any form of objectionable content cannot be expressed on Emtex letterhead, e-mail, or in any other context where such opinions or materials could appear to be attributable to Emtex. When participating in online discussion forums and social media, Emtex employees must comply with the CEBC.
Confidentiality
Confidential information includes all internal work instructions, standard operation procedures, guidelines, trainings, e-mails, and other information that has been marked as confidential by Emtex or its suppliers or customers. Nonpublic information that might be of use to competitors or harmful to Emtex or its customers if disclosed is also confidential information. Emtex respects confidential information of other companies and individuals, and does not permit the inappropriate collection of others’ proprietary information. Emtex takes appropriate measures to prevent accidental disclosure, and only acquires and maintains the personal data of employees, customers, and business partners to the extent required for the effective operation of its business or for complying with legal requirements. No employee should seek access to personal or confidential data, unless for a legitimate business purpose. Discussions of competitive information with employees of competitors must be avoided in all circumstances, and nonpublic information must be kept confidential. This obligation continues after the end of the employment relationship.
Employees may only disclose confidential information when authorized by Emtex or required by applicable law, rule, or regulation or pursuant to an applicable legal proceeding. Employees shall use confidential information solely for legitimate business purposes, and must return or discard (if applicable) all of Emtex’ confidential and/or proprietary information in their possession to Emtex when they cease to be employed by or to otherwise serve Emtex.
Employees must not pursue any personal investment or business opportunity on the basis of nonpublic information regarding Emtex, its customers, or suppliers. Employees are prohibited from trading in shares of customers while in possession of confidential information. It is forbidden to pass any confidential information, or give investment tips to third parties or close relatives on the basis of insider knowledge obtained in the course of employment.
Conflict of Interest
Conflict of interest occurs when a personal activity, relationship, or business involvement interferes or appears to interfere with the ability to fulfill job responsibilities. Business decisions are made based on what is in the best interest of Emtex, and require all employees to proactively and promptly disclose actual or perceived conflicts of interest.
All employees should never allow personal gain or benefit to prevent from doing what is in the best interest of Emtex. Any potential conflicts should be reported. To prevent conflict of interest, employees should avoid supervising or taking part in the hiring or promoting of a family member, and avoid holding a position with access to or influence over performance appraisals, salary information, or other confidential information related to a family member. These situations should also be avoided in connection with another employee or a prospective employee with whom one has a close personal relationship outside Emtex.
Emtex recognizes and respects the right of its employees to engage in outside activities which they may deem proper and desirable, provided that these activities do not impair or interfere with the performance of their duties to Emtex or their ability to act in Emtex’ best interests. Employees must avoid situations that present a potential or actual conflict between their personal interests and Emtex’ interests.
Any material transaction or relationship that reasonably could be expected to give rise to a conflict of interest should be reported promptly. If in doubt, employees should seek guidance. Some potential conflicts of interest can be resolved with prior approval or appropriate clearance by Emtex.
Violation
Emtex’ management shall periodically monitor compliance with the CEBC, and, when appropriate, impose and enforce appropriate disciplinary measures for violations of the CEBC. Disciplinary measures for violations of the CEBC will be determined in Emtex’ sole discretion and may include, but are not limited to, counseling, oral or written reprimands, warnings, probation or suspension with or without pay, demotions, reductions in salary, termination of employment or service, and restitution.
If any employee believes that actions have taken place, may be taking place, or may be about to take place that violate or would violate the CEBC or any law, rule, or regulation applicable to Emtex, he or she must bring the matter to the attention of Emtex. Employees are expected to cooperate with Emtex in any investigation of a potential violation of the CEBC, any other company policy or procedure, or any applicable law, rule, or regulation.
When reporting suspected violations of the CEBC, Emtex prefers that employees identify themselves in order to facilitate appropriate steps to address the report, including conducting any appropriate investigation. However, we also recognize that some people may feel more comfortable reporting a suspected violation anonymously. He or she may do so, and Emtex will use reasonable efforts to protect the confidentiality of the reporting person subject to applicable law, rule, or regulation or to any applicable legal proceedings. Persons who make reports anonymously should provide as much detail as possible to permit Emtex to evaluate the matter(s) set forth in the anonymous report and, if appropriate, commence and conduct an appropriate investigation.
Emtex expressly forbids any retaliation against any employee who, acting in good faith on the basis of a reasonable belief, reports suspected misconduct. Emtex will not discharge, demote, suspend, threaten, harass, or in any other manner discriminate against, such an employee in the terms and conditions of his or her employment. Any person who participates in any such retaliation is subject to disciplinary action, including termination.