setting forth general guidance on how to carry out daily activities in accordance with ASBIS mission, vision and values,
as well as in compliance with the applicable legal requirements and ASBIS’s policies, standards and ethical principles.
The Code includes the 10 guiding principles described above which are straightforward points written in an easy to
comprehend language and simple to follow for all employees. These are: “We are honest”, “We are trustworthy”, “We
promote diversity”, “We are team players”, “We use good judgement”, “We are responsible”, “We stick to the law and
our policies, “Never compromise on integrity”, “Just say no” and “Select business partners carefully”. The Code of
Conduct also encompasses ethical guidelines which are to support employees in making the right choices. It promotes
an honest and ethical conduct, a safe working environment and compliance with all governmental directives, laws,
rules and regulations. ASBIS’ Code of Conduct is communicated to employees at the initiation of the employment
contract and regularly through HR. Employees need to regularly confirm adherence. A training program is also available
on the Group’s training module on it4profit.
• HR Management Policy: Another aspect of developing, promoting and evaluating the corporate culture within the
Board of Directors powers is ASBIS’ comprehensive HR Management Policy which is consistently applied at the Group
level at each subsidiary, standardising processes related to Human Resources and building of corporate culture. The
HR Management Policy encompasses six key topics: hiring, team building, motivation, leadership, diversity and anti-
mobbing. On top, it also addresses employer branding actions. The key aspects of this policy are described in S1-2.
ASBIS’ HR Management Policy is communicated to employees at the initiation of the employment contract and
regularly through training.
• Human Rights & Labor Policy which sets forth ASBIS’ global standards regarding The Code of Labour Practices is
also approved by the Board of Directors. This policy of labour practice sets forth minimum standards for working time
and working conditions and provides for observance of all the core standards of the International Labour Organisation
including other applicable Conventions. The policy provides a pledge by the Company to observe these standards and
to require its contractors, subcontractors and suppliers to observe these standards (i.e. it applies to the upstream of
ASBIS’ value chain). It also establishes ASBIS’ general responsibilities concerning human rights, health management,
work safety, career management, employees’ rights etc. The Human Rights & Labour Policy is established by the
Board of Directors and communicated to ASBIS’ upstream partners and the Board of Directors monitors whether there
are any whistleblowing reports regarding treatment of workforce in the value chain as well as monitors publicly available
and sector information regarding its upstream partners. Application of Human Rights & Labor Policy strengthens ASBIS’
corporate culture by underlying the importance of human rights preservation.
• Employment Standards and Global Supplier Standards cover company-owned operations as well as our supplier
partners i.e. relate to the upstream part of ASBIS’ value chain. These policies describe the workplace practices and
ethical behaviour that ASBIS requires for all workers in its value chain such as: (1) prohibiting child and forced labour,
(2) ensuring non-discrimination and equal opportunity, (3) supporting a harassment-free and violence-free workplace,
(4) prohibiting retaliation or any form of physical or mental disciplinary practices, (5) respecting workers’ right to freedom
of association, (6) ensuring compliance with laws governing working hours and wages and (7) promoting environmental
protection, health and safety. The Employment Standards and Global Supplier Standards established by the Board of
Directors and communicated to all ASBIS’ partners. Application of Human Rights & Labor Policy strengthens ASBIS’
corporate culture by underlying the importance of human rights preservation.
• Whistleblowing Policy set up by the Board of Directors allows employees and external stakeholders (i.e. persons
from the whole value chain) to anonymously raise concerns about possible wrongdoing to the Board of Directors.
Concerns must be reported in writing. Employees may submit these through the corporate portal, while employees,
partners, contractors, consultants and members of the public may also report concerns via a dedicated whistleblowing
email address or by submitting a written report to an Executive Director. It is ASBIS intention to treat all reports seriously
and assure appropriate investigation of each reported manner and protect the whistleblowers from retaliation. The
Board of Directors monitors whether there are any whistleblowing reports and is prepared to act should any such report
materialise. All reports are treated confidentially and are transmitted to the Board of Directors, which retains oversight
of whistleblowing matters. Upon receipt, a designated member of the Board promptly initiates a review and investigation
of the allegation, ensuring that the matter is assessed objectively and that individuals concerned are given the
opportunity to respond. Reports of potential violations of laws, regulations, internal policies or ethical standards are
formally documented and reviewed within defined internal timelines (typically within 30 days of submission), with
findings recorded and corrective or disciplinary measures implemented where appropriate. The Group maintains
safeguards to protect the confidentiality of the reporting person and explicitly prohibits retaliation against individuals
who report concerns in good faith; these protections are communicated to employees through the Code of Conduct,
the Whistleblowing Policy, and related compliance policies that encourage early reporting of suspected misconduct.
Application of Whistleblowing Policy strengthens ASBIS’ corporate culture by underlying the importance of human
rights preservation. The Policy is consistent with the EU Directive 2019/1937.
• Business Ethics Policy encompasses conflicts of interest. A conflict can take the form of a business relationship with,
or an interest in, a competitor or customer of ASBIS, or participation in sideline activities that prevent employees from
being able to fulfil their responsibilities at ASBIS. It is important that all ASBIS’ employees recognize and avoid conflicts
of interest, or even the appearance of a conflict of interest, as they conduct their professional activities. Employees