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Why do we need the Code of Business Conduct?
The Code of Business Conduct is a demonstration of our commitment to achieve and maintain ethical standards at the highest level wherever we operate. The Code of Business Ethics determines what they expect from Europack employees, business partners and suppliers, and provides guidance on how Europack employees should experience Europack values in their daily work around the world.
How does the Code of Business Conduct apply in different countries?
Europack, a global business operating in many countries of the world, accepts that laws and regulations differ from country to country, even from state to state. Each of us must take responsibility to ensure that the laws of the country we work in are followed. If there is any conflict between the guiding principles set out in the Code of Business Conduct and the local laws in the country where you work, we should follow and apply whichever higher standard of conduct sets.
Code of Business Ethics
The Code of Business Conduct applies without exception to anyone working at Europack. This also applies to all temporary and / or indefinite-term contracted personnel, regardless of their position, position or seniority. Each of us has a responsibility to be aware of the content of the Code of Business Conduct, and if there is anything you are not sure about, you should speak to your Department Manager. Each of us must make sure that we fully understand what is expected of us in our positions and how the policies contained in the Code of Business Conduct apply to us.
In addition to Europack employees, we should not be in contact with any contractor, agent, consultant, supplier, customer, business partner or other third party whose business practices contradict the Code of Business Conduct.
If you want any third party to act with Europack, it is your responsibility to ensure that they are aware of the Code of Business Conduct and agree to act accordingly. If possible, to comply with the Code of Business Conduct, you must request a contract from them and actively manage third parties. Any violations of the Code of Business Conduct by third parties or examples of inconsistent behavior with Europack Values (as will be noted later) should be reported to your Department Manager. You should try to eliminate such behavior and consider terminating the relationship when necessary.
Please note that the appointment of a professional consultant or consultant must first be approved in accordance with the Group Approval Guide. No consultant or professional advisor can be appointed without this pre-approval.
In the countries where we operate in a joint venture, we will try to proactively influence our business partners in order to adopt similar principles with our business partners. All employees are required to comply with the Code of Conduct and the policies included in it (including new employees joining Europack through acquisitions or contract earnings). Failure to comply with the Code of Business Conduct may result in disciplinary penalties that may lead to termination.
If you are responsible for supervising or managing your colleagues in Europack, you have additional responsibilities to:
• You are a good role model for those who report directly to you and demonstrate good ethical behavior, for example;
• Anyone who reports directly to you is aware of the Code of Business Conduct and has the opportunity to discuss their applications according to their positions and of course their concerns – you may consider making this part of the annual assessment;
• Is the Code of Business Conduct actually followed by those who report to you? If you take this into account when setting goals and business projects and become aware of the violation of the Code of Conduct, you should immediately take action by communicating the matter to your own department manager or local legal department.
Getting Help and Advice
We may feel like an easier way to remain silent or to ignore unethical behavior, but our commitment and commitment to integrity means that a legal or ethical issue that should be addressed should not be ignored.
Each of us is responsible for reporting any conduct or any potential or actual violation that violates the Code of Conduct or Europack values and business principles. This task applies to a situation where you are aware of a problem directly with you or a colleague or a third party related to Europack.
Whenever possible, you should first consider talking to your Department Manager about any legal or business conduct issues.
If you are uncomfortable talking to your department manager or if it is not suitable under these conditions, you can also get advice and guidance from:
• Law (Company Law Department)
• HR team,
• Group Internal Audit;
• Your local senior management team.
There is some useful contact information in the Reference section, which you will find on page 34 at the end of this Code of Business Conduct.
You can also take advantage of the “Speak Up” facility, whose details are on page 6.
Q: Does the Code of Business Ethics contain everything I need to know?
A: You will find examples of situations that may arise during your employment throughout the Code of Conduct, along with guidance on how Europack expects you to act in these situations. However, it is impossible to cover every possible scenario that may arise, and as a leading professional organization in the world, Europack expects each of its employees to take personal responsibility to act in accordance with the principles contained in the Code of Business Conduct.
“Questions and Answers” aims to respond to certain situations that may arise and show how we expect you to behave more generally.
“Speak Up” is a company-wide service for our employees to confidentially raise concerns about actions and behaviors that they think may be inappropriate, unsafe, unethical or even illegal regarding issues they think they cannot raise through department managers or normal procedures.
Our reputation is based on the standards we set for the quality of the products we offer, our business controls and practices, our ethics and integrity. If these standards are violated, we will weaken our reputation and risk the safety and future success of the business. We can’t let this happen. We all share the responsibility of running our business in a professional, safe, ethical and legal manner.
The key to achieving this is to have an open, honest communication culture that our employees can share with department managers or supervisors when they think these standards are being violated and potentially feel themselves at risk for themselves, their colleagues, our customers, our business and our reputation.
Although we believe that we have such a culture, we want to make each of our employees feel strong about “speaking out loud” on these issues. However, this is not always that simple. Whatever the reason, people sometimes feel that they cannot “speak out”.
The Speak Up program provides them with a reliable way to uncover issues where our employees feel safe and that their colleagues or customers, business partners, standards or reputation are at risk.
All issues are handled by independent experts who are not employed by Europack. Communication with Speak Up is completely confidential and although it is more useful to provide a more comprehensive investigation of your personal information, there is no requirement to provide your information unless you are comfortable doing so. Each report is directed to a specially trained ‘case manager‘ who conducts a secret investigation of the reported subject.
In many countries, the Speak Up helpline provides services in multiple languages with Kazakh, Russian and English-speaking operators, such as in Kazakhstan.
If you would like feedback or update, you can contact Speak Up using a unique tracking number about 14 days after your original report is prepared. Europack does not accept any retaliation to report a problem, raise concern, or assist in the investigation. Those who are found to retaliate against any person who expressed their concerns in good faith will be subject to disciplinary action.
Q: My manager asked me to do something that I think was not true. I tried to argue with him, but he told me to continue. I am afraid that my manager will make things difficult or lose my job if I call Speak Up.
A: If you become aware of an issue that interests you, we always encourage you to talk to someone. If you cannot talk to your department manager about this or other senior colleagues on this topic, we recommend that you call Speak Up. Any issues you report or raise will be investigated and we will not accept any retaliation against you for reporting this matter. You should do the right thing and report the matter.
VISION & VALUES
Our Vision and Values convey the spirit of Europack and what we represent into words. It guides our employees’ decisions, actions and behaviors; It is evidenced by our service experiences that we offer to our customers globally every day, and guide our performance and growth.
Our vision – determines who we want to be a first-class personal hygiene equipment provider, known for our excellent employees, excellent services and excellent results.
Our mission – determines how we can achieve this.
At Europack, everyone is committed to providing the most efficient service for the common benefit of our customers, shareholders and employees.
Principles That Guide Us – determines the principles that guide us in making our decisions Safety, Health and the Environment Comes First – To never compromise the health and safety of our customers and employees and to manage the environmental impact of our business responsibly;
Service for Customers and Consumers – to gain the constant loyalty of our customers by constantly showing why we are the first choice for quality, service, value and innovation;
Developing Our People and Valuing Diversity – recognizing the diversity and contribution of our employees. We create a competitive working environment and provide opportunities and support for everyone’s development, learning and success .;
Profitable Growth – providing value to our shareholders through disciplined, sustainable growth, backed by strong management, contributing to and strengthening the benefits of our global scale.
Continuous Focus on Performance and Efficiency – to be the lowest cost and most efficient provider while working relentlessly to deliver the highest quality and performance.
Our values – determine what we believe collectively and guide our behavior.
Openness, Trust and Integrity – we always set the highest ethical and professional standards. We want all our relationships to be built with integrity, respect, fairness and open dialogue and transparency;
Passion for Quality – we are passionate about personal hygiene and we are proud to achieve it. We strive to increase ideas, learn from mistakes and develop ideas, innovation and practices that will help us improve and manage our market;
Winning with Teamwork – we encourage individual ownership, but we work as a team. We value the expertise, individuality and contribution of all our colleagues in the pursuit of shared goals, to support each other and to share good practices easily;
Responsibility – We take responsibility for our actions individually and as a Group. Every day, everywhere, we try to make a positive contribution to our customers’ health, well-being, the communities in which we work and the world we live in;
We Can Succeed – We approach the opportunities and challenges we face with a positive and commercially conscious “We Can Succeed” motto.
If you are facing a situation where you are not sure about the correct course of action, you may find it helpful to ask yourself these questions:
1. Is the action legal?
2. In line with Europack Values?
3. Does it contradict our Principles that guide us?
4. What do others think about this?
5. Would you be comfortable if it were published in the newspaper?
If you still have concerns after considering these points, get guidance and advice from your Department Manager, your local HR team or your local Legal team.
Remember, by contacting “Speak Up” you can discuss any concerns or issues you may encounter at any time.
PERSONAL HONESTY Conflicts of Interest
Employees, as a Europack employee, should take care to ensure that no real or perceived conflict of interests arises between their duties and non-business interests.
Conflicts of interest can arise in many ways.
Other business interests and subsidiaries: Recruiting for other companies while being employed by Europack or affiliated with other organizations can cause conflicts of interest.
• Having financial interests in another company or organization;
• Having a Management Team Member or consultant position;
• Service outside of your position at Europack;
• Having a second job.
If any of the above relates to a Europack competitor or a company or organization that can be considered a customer, contractor or supplier, a conflict of interest may occur.
Such arrangements are never allowed. You should not work or provide services for any company or organization you are interested in your position at Europack. If you intend to do additional work outside of Europack that may be perceived or cause a real conflict of interest, you should disclose it to your Department Manager and obtain written approval to continue your plans.
Working with close relatives: If you become aware that a close relative is operating as a competitor, customer, contractor, or supplier, you should discuss the matter with your Department Manager.
As a general rule, a relative should not have any business relationship with you, and wherever possible, with anyone in your business unit or anyone who can report to you. For the purposes of the Code of Business Conduct, a spouse, partner, parent, step parent, child, stepchild, sibling, stepbrother, cousin, nephew, aunt / still, uncle / uncle, grandfather, We think it will include grandchildren or mother-in-law / father-in-law and beech.
Board of Directors
As a professional organization, we are aware that our employees may sometimes be asked or invited to take part in another company’s board of directors, and in some cases, conflict of interest or a legal problem may arise. Before accepting duties as a board member for any organization (including non-profit organizations), you must first obtain written approval from your Country General Manager.
Conflicts of interest may occur if investments are made to competitors, suppliers or customers. Any “material interest” for a competitor, supplier or customer requires the prior written approval of the General Manager of your country.
For the purposes of the Code of Business Conduct, “material interest” means any financial interest that can really affect or be perceived by your decision.
Many real or potential conflicts of interest can be resolved in an acceptable manner for both Europack and the individual. The important thing is to highlight potential conflict so that an appropriate action plan can be understood.
If you are concerned that you (or a colleague) may have a conflict of interest, you should disclose this to your Department Manager. Failure to disclose conflicts of interest can lead to disciplinary action.
Insider Sharing / Insider Trading
Oozing inside information to trade in the United Kingdom, the United States, is a criminal offense in Turkey and many other countries. Confidential Information is material information about a company that is known to the company’s executives and employees, but is not made public. It may also be related to another publicly traded company. It is forbidden to share information inside or to buy or sell shares.
PERSONAL HONESTY Gifts, Treats and Hospitality
We appreciate that offering or receiving and receiving gifts can help create goodwill in business relationships, but these are only suitable under limited circumstances.
Employees must under no circumstances present, give or accept any gift or hospitality that may affect the business decision – regardless of value.
When facing an opportunity to present or receive gifts or entertainment, consider the following points:
• What is your intention when presenting a gift or entertainment, or what is the partner’s intent when presenting you the same thing?
• Is her intention to influence a business decision, such as establishing a business relationship or awarding a tender contract?
• Is the nature of the gift or hospitality modest or can you (as the buyer) make you feel obligated to return something?
• Have you checked whether the gift / hospitality is legal in both the country of the buyer and the offer? Be particularly careful when considering gifts or entertainment for government officials, as some countries do not allow this.
• Have you checked whether the gift, catering or hospitality recipient is allowed to receive this “according to the gift policy”?
• Are you happy to justify giving gifts or hosting or receiving gifts? If it doesn’t sound right, it probably isn’t.
Does it matter what kind of gift I offer or entertain? There are some types of gifts or entertainment that should never be accepted. You must not give, offer, receive or approve anything of this type:
• Gifts or entertainment, including any third party involved in any competitive bidding or bidding process in which you participate or are present;
• Gifts or entertainment that may be illegal under local law, such as presenting a gift that can be seen as a bribe to a government official under local law – please make sure you know your local legal obligations;
• Pay cash (or cash equivalents) or someone else’s personal bills or expenses;
• Any hospitality that may violate this Code of Business Conduct or be considered improper or inappropriate as part of the business relationship or negatively affect Europack’s reputation;
• Do not use regardless of whether you have used the opportunity to use personal or company hospitality, gifts are not ready to notify or receive approval within the company or entertainment.
Gifts, Catering and Hospitality (cont’d)
Please note that these values are Group standards specified in the Group Approval Manual (GAM) and may change from time to time. The local gift and hospitality policy in the country where you work can create tighter thresholds that you must follow. It is your responsibility to find out both the locally valid thresholds in your country and the thresholds set in the Group Approvals Guide (GAM).
We are aware that in some countries and cultures, refusing a gift offered to you may be considered an insult but may otherwise violate the Code of Business Conduct. In such cases, you can accept the gift, in such a case, you must inform your Department Manager immediately. It will tell you whether you can keep your gift or not and return it to the gift-giver.
Under no circumstances should you accept cash gifts (or cash equivalents, money orders, investment securities or cash equivalents such as payment of personal invoices or expenses / expenses).
Visits by Government, Joint Venture, Government or Government Agency Representatives Due to the nature of our business, we sometimes receive visits from government, joint venture or government-owned company representatives to our offices or facilities where we operate worldwide. While it is acceptable to promote, demonstrate and explain the benefits of Europack, it should not be attempted to influence any decision by providing personal benefits.
COMMERCIAL HONESTY Competition and Anti-trust
Compliance with Europack competition law – sometimes referred to as antitrust law – is very serious. Violations of the competition law will not be tolerated.
Competition laws may vary from country to country, and some laws may also apply to businesses outside the country of origin. The consequences of violating the competition law can be serious for both companies and individuals. A company in the EU can be fined up to 10% of its annual turnover for anti-competitive behavior. In some countries such as the USA, Brazil and the UK, people found guilty of certain anti-competitive practices may be sentenced to prison.
When examining whether a company is acting in an anti-competitive manner, one factor that is often taken into account by the authorities is the market share of the company. The use of anti-competitive means to obtain or maintain a monopoly or dominant position is illegal in many jurisdictions. If the business you are operating has a significant market share, you should cooperate with your local legal team.
In some countries, offering different prices to different customers can be considered anti-competitive. If you are involved in determining the prices of goods or services in your business area, you should be familiar with the applicable local laws. For advice, please contact your local legal team.
• Never agree (or even discuss this) with competitors about the price Europack will sell goods or services;
• Do not attempt to dictate / impose the price at which customers sell the goods or services provided by Europack;
• Never automatically adopt the recommended retail prices of suppliers – make and save your own pricing decision;
• Do not discuss, accept or accept how to share customers / contracts with any non-Europack company, or discuss / never agree to artificially share a market, such as sharing different regions to specific companies;
• Never cheat bids or tenders or communicate with competitors in relation to any offer or tender (for example, except an official joint offer or joint venture handled by your local legal team);
• Never agree with another company to artificially restrict goods production or service supply.
DO NOT CONSULT YOUR LOCAL LAW TEAM!
• Bid prices below the total cost to eliminate a competitor from the market;
• Refusal to supply an existing customer (for example, unless the customer refuses to pay the invoices);
• Accepting exclusive contracts of more than 5 years;
• Making agreements at a particular facility to give Europack’a “priority” for future business opportunities.
• Please note that if you do not have a local legal team in the country where you operate, you should consult with the group Legal department.
Europack employees should be especially careful to ensure that they do not run the risk of engaging in any anti-competitive behavior or interaction when considering joining a trade association. You should not join a trade association without the approval of the General Manager, who will direct the matter to the Legal Department for approval. Employees are advised to keep a careful record of meetings with representatives of competitors.
Trade Associations should not be used as a forum to adopt a common approach to a commercial issue such as price reduction. For example; Even passive participation in meetings where discussions, such as understanding market prices, can put you and Europack at serious risk. You should leave the meeting immediately, stating that you are not satisfied with the discussions. You should then report the matter to your legal team immediately.
If you doubt your participation in commercial association / association meetings, you should consult your legal team.
We are all expected to comply with anti-money laundering laws. It is Europack’s policy not to accept payments from our customers (except for our end-customers) for cash, traveler’s checks, third party payments or money orders. We usually expect customers to be paid in bank accounts held on behalf of the invoiced customer.
Payments made by Europack to a supplier or another third party must be made to a bank account on behalf of the contracted third party. Exceptions to this must be approved in writing by your legal team or Finance Director. It is the responsibility of management to ensure that Europack operates in accordance with all local legal requirements, including compliance with any currency reporting requirements.
Bribery and Corruption
Bribery is to give or receive a gift, payment or other benefit to gain a commercial advantage. Bribery doesn’t actually have to be paid – it’s even enough to be asked or offered. Bribery may be a problem regardless of whether it concerns the private sector or government.
Bribery or corruption in any form is unacceptable and we are committed to transparency in all our business relationships. Most countries have laws that prohibit corruption. Violation of any of these laws is a serious crime, which can result in penalties for Europack and prison sentences for individuals.
We are determined to create a work environment where all our employees maintain the highest standards of accuracy and professionalism. This is particularly important in our dealings with government, federal, public and local authority officials in any country.
Regardless of whether you are dealing with someone in the private sector or government, you should always follow these basic rules:
• Never make unofficial or unauthorized payments or offers;
• Never try to persuade anyone to do something illegal or inappropriate;
• Always report suspicions or information about improper payments offered or received;
• Never offer or accept money (or anything of value), gifts or commissions for contracts / tenders or to get jobs.
Transaction Acceleration (Facilitation) Payments
Transaction Acceleration (Facilitation) payments are payments to a public official (or another person) as a way to enable them to perform their duties faster or at all. For example, to ensure the rapid release of goods held at customs. Facilitation payments are prohibited by Europack employees. You should not make such payments, even if it is for regular quantities or “normal” practice in the country where you operate.
New Regions, New Sectors, Representatives and Consultants
As part of our risk assessment procedure, the establishment of a business in a new country or region in which Europack does not currently operate, or entering a new business sector / site in an existing country, must first be approved by the General Manager and Group Finance Director.
Reporting and Accounting
It is essential for Europack to record financial and non-financial information accurately and objectively.
All books, records and accounts must comply with Europack Accounting Policies. The relevant guideline is a single reference source for compliance with International Financial Reporting Standards for all areas of the business and enables all Europack businesses to report under one clearly defined policy set.
Remember the basic rules below!
• All records must be accurate and complete, and must accurately and accurately reflect the status of the business at any time;
• Supporting documents should be collected at any time of the transaction;
• Accounting records and documents must be kept in accordance with local legal and financial requirements (and for an appropriate period), but must be kept for at least six years in any case;
• Annual financial statements and documents related to purchases and other important transactions should be kept permanently;
• To the auditors in full cooperation with all internal or external audits.