UNDER ITEM 220.127.116.11 IATF 16949:2016
This section applies to all employees at TBP (full-time employees, workers who perform their work through employment agencies, workers through public works, highschool and university students on practical work training or other work, through the social welfare centre and anyone who performs work at TBP on any other basis).
1) TBP anti-bribery policy
Within the scope of its operations, TBP is on top of international trends and follows good practices by implementing a anti-bribery policy, while adhering to the legislation and provisions of the new international standard IATF 16949:2016. Our policy is to run our entire operations in a fair and ethical way. We furthermore have a zero tolerance stance regarding bribery and corruption. We are committed to act professionally, justly and fairly in all our business transactions and relationships, wherever we operate, and implement and exercise an effective system to prevent bribery.
All persons who perform work at TBP are prohibited, both directly or indirectly for themselves or for someone else, from requesting or accepting any bonus, gift or other reward or promise or offer of such reward for performing an act within their professional duties or powers that they should not perform, or refraining to perform an act that they should or could perform, or otherwise abuse their position. Furthermore, any violation of the due diligence of persons in charge is prohibited, as are the actions of persons who initiate violations or persons who could benefit from a violation due to directly or indirectly promised, offered, given, requested, received or expected rewards for themselves or others.
Any participation in such conduct is also prohibited.
The above is, in principle, concretized in the prohibition of the direct or indirect giving, offering or acceptance of: bribes; gifts and entertainment; and political or charitable contributions or unauthorized benefits under the guise of any other business (donations, sponsorships, etc.) for which any kind of unauthorized material or non-material reward or advantage is expected.
Exceptionally, the receiving and the giving of i.e. occasional business gifts between business partners is permitted if they do not exceed a value of €25 and are not paid out in cash and do not constitute any benefits that exceed €100 in value; at the same time, no action, benefit or commitment is expected in return, nor does it affect any business decisions.
It should also be noted that the practice of giving business gifts is different in each country and region, and it must be assessed whether a gift, entertainment, or any other benefit is reasonable and justified in all circumstances. It is always necessary to assess whether a gift is given for a specific purpose. If it is not appropriate to refuse the offer of a gift that exceeds the aforementioned value, it can be accepted on the condition that you then report it to a superior and donate it to charity or display it on company premises.
2) Employee code of conduct
Employee conduct is a reflection of the image, success and reputation of the company in public, therefore the basic rules of business etiquette should be followed. The aforementioned is undoubtedly considered by TBP to be the intangible value of the company and represents people’s evaluation of the company’s appropriate conduct, their experiences with it and the message sent by the company. The company’s employees strengthen the company’s reputation with their work and conduct when performing tasks, and acting in accordance with guidelines for maintaining the positive reputation of the company is the task and responsibility of each and every employee. Both the company’s management and employees strive to find a balance between the conduct and behaviour of the employees on the one hand and the expectations of buyers, employees, owners and the environment on the other hand, as only in this way can the reputation of the company be maintained and improve.
Since the work environment directly impacts the reputation of the company in the business and social environment, we ourselves are primarily responsible for creating a work environment where no worker is exposed to sexual or other harassment or mobbing by the employer or colleagues; in this context, in relation to work and interaction other people, each individual is obliged to conduct themselves at the very least according to basic etiquette and the unwritten rules of interpersonal relations. We do not tolerate conflict between employees, but at the same time we are also aware that minor conflicts and conflicts between colleagues in the workplace can always be present and form part of the mutual relations in the group of employees, but in accordance with the internal rules of the company it is necessary to respond appropriately to the conflict with the intention of resolving it. When communicating with others we respect the values of TBP and the value so the employees, we communicate openly and sympathetically, and are able to listen and respectfully respond to both positive and negative information.
Therefore the basic rules of conduct in the workplace are understood to be: arriving at work on time; every arrival and departure from the workplace is recorded in the prescribed way; in lateness or absence is notified to a superior as well as the reason for the lateness or absence; work property and the work environment is used and maintained correctly; no swear words, offensive words or raised voices are used and do not communicate in a way that would hurt or offend others; do not speak inappropriately about colleagues in and outside of the workplace; do not bring alcohol and other psychoactive substances into the workplace or consume them there; do not speak about matters outside of the workplace that you are not authorised for, etc. The violations and sanctions for these are set out in more detail in the internal regulations of the company. We also strive to make sure that employees greet each other pleasantly; only use familiar forms of address if they agree to this; when entering the office of a colleague, first knock on the door; if a colleague is on the telephone when you enter their office, leave the room and only enter when the colleague indicates that you may enter; behave in a polite and respectful manner to each other, etc.
Regarding conduct in relation to the “outside”, therefore towards customers, suppliers and other third parties, respect the principles of professional communication. Therefore always have a respectful attitude towards customers and respect their various means of communicating; treat every return or complaint as an opportunity for self-improvement; be prepared for meetings and actively participate in them; be well-prepared for public appearances; behave respectfully at gatherings and do not make inappropriate comments; do not spread falsehoods or hate on social networks; respect the rights of individuals. In relation to the public and the media, provide them with clear, accurate and timely information about activities, support the media in their role of objective reporting and the right to information, so carefully build responsible, planned and proactive relationships that contribute to the satisfaction of information needs of the interested public; in relation to them, respect the agreed internal rules of communication. In the cooperation between employees and representatives of public institutions, judicial authorities, public order and peace authorities, officials and supervisory bodies with inspection powers at any other public administration body, we require full compliance with the relevant legal provisions and the maximum possible availability and participation of employees in relation to these representatives.
The procedures for internal and external sectoral communication and the authorisations to provide information are detailed in Item 5.5.3. of the adopted Quality Manual.
This code of conduct does not provide the answer to every question. It is also necessary to be familiar with the content of internal regulations and the law, and observe them at work. We must be aware that the violation or suspension of the code rules can be considered a violation of internal regulations or the law and result in the disciplinary liability and liability for damages or even criminal liability of the individual.
3) Ethics escalation policy (“whistle-blowing policy”)
At TBP, anyone who, at work, perceives a violation of the law or internal rules of the company, contractual and/or other obligations arising from their employment relationship or suspects that a violation could have been committed, can submit a complaint to a representative of the employer or an authorised person. In principle, the complaint can be submitted to the HR and legal department, to a superior or to company management. If the complaint was not submitted or forwarded to the HR and legal department for their reference, the recipient shall address it to the HR and legal department, which then conducts further proceedings; except in the case where the submitted complaint refers to the employees of the HR and legal department itself – in this case, it is dealt with by the managing director of the company.
After assessing the circumstances of the violation or at the request of the applicant, the HR and legal department assess whether it is reasonable to ensure the anonymity of the applicant in the case in question, in order for them to not be exposed to negative and unwanted consequences of the submitted complaint. Complaints that are given anonymously are also dealt with insofar as the complaint does not show an obvious unfoundedness. If the perceived reported violation is found to be justified, in accordance with the law and internal regulations, after the assessment of all relevant facts, appropriate action shall be taken against the offender – either by initiating a disciplinary procedure, issuing a warning before regular termination of the employment contract for misconduct, initiating an extraordinary or regular termination procedure, demanding liability for damages, or selecting a lighter informal measure. If the perceived violation shows signs of being a criminal offence or other elements that require the forwarding of the complaint to public institutions, judicial authorities, public law authorities, officials and supervisory authorities with inspection powers, the matter in question shall be immediately forwarded to the relevant authorities and to whom full cooperation shall be given.
If the submitted complaint proves to be unfounded, the company ensures that the applicant shall not be sanctioned or suffer any other negative consequences if they submitted the complaint in good faith or they misperceived a certain violation in practice.