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About the company

Code of Conduct for Business Partners

1. BACKGROUND, OBJECTIVES AND BINDING FORCE

TRANSPETROL, a.s., with its registered office at Šumavská 38, Bratislava 821 08, ID No.: 31 341 977, registered in the Commercial Register of the Municipal Court of Bratislava III, Section: Sa, File No.: 507/B ("TRANSPETROL") conducts its business activities in the spirit of responsible, correct and socially fair business.

This Code of Conduct for business partners builds on and follows the values of TRANSPETROL's Code of Conduct, in which TRANSPETROL, as one of the most important business entities in Slovakia and at the same time a strategically important part of the Slovak economy, accentuates its commitment to conducting business activities with respect to the principles of ethics, transparency and social responsibility.

Based on the fact that TRANSPETROL considers its business standards to be of paramount importance for the proper functioning of the business environment and society as a whole, TRANSPETROL hereby undertakes to uphold its business standards in all its business relationships.

The requirements set out in this Code of Conduct for Business Partners apply to all TRANSPETROL's business partners, in particular suppliers, subcontractors, service and consultancy providers, customers or any other contractual partners of TRANSPETROL ("Business Partners").

2. BUSINESS PRINCIPLES OF BUSINESS PARTNERS

TRANSPETROL's business partners are committed to adhering to the values and postulates of TRANSPETROL's Code of Ethics, in particular:

Ethics, Transparency, Corporate Social Responsibility, Compliance with applicable legislation, Protection of reputation, Prohibition of misuse of information, Prohibition of misuse of assets, Honest and fair approach, Protection of the environment, Prohibition of corruption and corrupt behaviour.

3. PEOPLE AND STAFF

2.1 HUMAN RIGHTS

TRANSPETROL's business partners undertake to fully respect and observe fundamental human rights and freedoms in the conduct of their business activities, in particular, but not exclusively, the right to life, the right to personal liberty and security, the right to freedom of expression and the right to information, the right to freedom of conscience and religion, the right to freedom of association and freedom of assembly.

2.2 EQUAL TREATMENT AND EQUAL OPPORTUNITIES

TRANSPETROL's business partners are committed to fully observe and respect the principle of equal treatment and equal opportunities in the conduct of their business activities.

TRANSPETROL's business partners undertake to refrain from any form of discrimination or unequal treatment on the basis of gender, ethnic origin, colour, age, sexual orientation, religion, nationality, political opinion, disability and pregnancy.

2.3 FAIR EMPLOYMENT PRACTICES AND PROHIBITION OF CHILD, COMPULSORY AND FORCED LABOUR AND ILLEGAL EMPLOYMENT

TRANSPETROL's business partners are committed to applying and adhering to a fair employment and remuneration policy. The business partners undertake not to violate the prohibition of illegal employment in the provision of services.

TRANSPETROL's business partners undertake to act in accordance with the relevant applicable legislation at all times with regard to the recruitment of employees, conditions of employment, wage policy, provision of employee benefits and employee training, working conditions, career development of employees or termination of employment of employees.

TRANSPETROL's business partners undertake to fully observe and respect the prohibition of all forms of child, compulsory or forced labour, as well as the prohibition of all forms of modern slavery, in the conduct of their business activities.

2.4 HEALTH AND SAFETY AT WORK

TRANSPETROL's business partners undertake to apply and comply with all occupational health and safety rules, which lay down the basic obligations of the employer as well as the conditions for ensuring occupational health and safety, in accordance with the applicable legislation.

2.5 FREEDOM OF ASSOCIATION AND COLLECTIVE EXPRESSION

TRANSPETROL's business partners undertake to fully respect and observe the rights of their employees to form, join and refrain from joining employee associations, as well as the employees' right to collective bargaining.

In this regard, the Business Partners also represent that no employee will be discriminated against or otherwise penalized in the proper exercise of these rights.

4. CONDUCT OF BUSINESS PARTNERS

3.1 FIGHT AGAINST CORRUPTION

TRANSPETROL's business partners are committed to conducting their business without any form of corruption, bribery or corrupt behaviour.

TRANSPETROL's business partners declare that they will refrain from any form of corruption and bribery, including the offering, giving or receiving of bribes, gifts, benefits, compensation, which could constitute a violation of applicable law or could be perceived as an attempt to influence a business decision or otherwise influence the recipient's actions or work obligations.

This obligation of the Business Partners may also include acting through the employees of the Business Partners or any of their organisations or agents.

3.2 PROHIBITION OF MONEY LAUNDERING AND PROHIBITION OF FINANCING AND SUPPORT FOR TERRORISM

TRANSPETROL's business partners undertake to fully apply and comply with the legislation on the prohibition of the laundering of the proceeds of crime, as well as the legislation on the prohibition of the financing and support of terrorism or any other criminal activity, in the course of their business activities.  

3.3 COMPETITION

TRANSPETROL's business partners undertake to conduct their business activities in accordance with all fair competition rules as well as in compliance with all applicable competition laws.

TRANSPETROL's business partners also undertake to take all necessary measures to prevent illegal or unethical practices in their business relationships, in particular practices aimed at withholding payments or chaining debts.

3.4 TRADE RESTRICTIONS, EMBARGOES AND INTERNATIONAL SANCTIONS

TRANSPETROL's business partners are committed to fully comply with all export and import restrictions, trade restrictions, trade controls, trade embargoes and sanctions, including rules relating to the trade of dual-use goods, in the course of their business activities.

TRANSPETROL's business partners undertake to disclose to TRANSPETROL without undue delay all relevant information concerning any measures that may be applicable to them or to their affiliated or otherwise related companies or organisations.

3.5 PROTECTION OF PERSONAL DATA, INFORMATION SECURITY AND PROHIBITION OF INSIDER TRADING

TRANSPETROL's business partners undertake to fully comply with all legal regulations in the area of personal data protection, in particular Regulation No. 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as well as Act No. 18/2018 Coll. on the protection of personal data and on the amendment and supplementation of certain acts.

TRANSPETROL's business partners undertake to treat TRANSPETROL's information provided to them in the course of business cooperation (except for that which is publicly available) as confidential and in accordance with TRANSPETROL's relevant requirements as well as the standards for the protection of confidential information.

TRANSPETROL's business partners are obliged to take appropriate and adequate measures to ensure the integrity and confidentiality of the information, as well as to protect any intellectual property rights, in the interest of the security of the information.

TRANSPETROL's business partners also undertake to refrain from any unauthorized use of confidential information in order to obtain any benefit, profit or advantage and also to refrain from any unauthorized disclosure and dissemination of confidential information to third parties.

3. 6 ENVIRONMENT

TRANSPETROL's business partners are committed to treating the environment responsibly and considerately at all times in their business activities, in compliance with all environmental legislation, and to upholding the values of sustainable development.

3.7 ASSET PROTECTION AND ACCOUNTING

TRANSPETROL's business partners undertake to treat TRANSPETROL's assets to which they have been granted access or which they have been allowed to dispose of or dispose of in an economical, responsible and appropriate manner in the course of their business activities.

TRANSPETROL's business partners undertake to keep responsible accounts and prepare financial statements in accordance with applicable law and generally accepted accounting practices and principles, and to keep proper and transparent records of business transactions in the course of their business activities.

3.8 PRODUCT AND SERVICE REQUIREMENTS

TRANSPETROL's business partners are committed to providing their products and services in accordance with the requirements of applicable legislation, industry and sector standards and to the highest possible quality that can be expected for the type of product or service.

3.9 CONFLICT OF INTEREST

TRANSPETROL's Business Partners undertake to actively avoid situations that could constitute a conflict of interest, and in particular to avoid situations in which the Business Partners' business interests, or the business interests of their affiliated or related companies or organisations, could conflict with TRANSPETROL's interests.

TRANSPETROL's business partners agree to immediately report to TRANSPETROL any situation, circumstance, relationship or transaction that they are concerned may create or give rise to a conflict of interest  

TRANSPETROL's business partners also undertake to actively avoid any situation that could affect their ability to act in the best interests of TRANSPETROL or that could hinder the objective and efficient performance of the agreed work or service.

3.10 COMMUNICATION STANDARDS

TRANSPETROL's business partners undertake to conduct all communications, regardless of their form, in a manner that meets the strictest requirements of ethics, morality, decency or standards and norms of decent behaviour.

5. COMPLIANCE WITH THE CODE OF CONDUCT FOR BUSINESS PARTNERS

TRANSPETROL's business partners are committed to fully comply with this Code of Conduct for Business Partners, taking due account of their operational size, corporate structure or the nature and riskiness of their business activities.

In order to enforce and apply this Business Partner Code of Conduct as well as TRANSPETROL's business standards, TRANSPETROL's Business Partners declare that they are fully committed to enforcing this Business Partner Code of Conduct in relation to all their employees, suppliers, subcontractors or any other business partners in the course of their business activities.

In order to comply with this Code of Conduct for Business Partners, TRANSPETROL's Business Partners also declare that they undertake to take appropriate measures to demonstrate compliance with this Code of Conduct (e.g. by adopting their own Code of Conduct or a Code of Conduct for their Business Partners, etc.).

Should any violation of this Code of Conduct for Business Partners arise, please contact the Office of the Chief Executive Officer.

Bratislava, November 2023
About the company