Overview

In our team each employee makes a significant contribution for improving the quality of our products and services to our clients. In our business relationships we apply the ethical standards of positive attitude, propriety, security, treating others with respect, honor and dignity.

The company stands for its position of creating and keeping trust, building up and maintaining a stable image to its future partners and current clients through sustainable, continuous and consistent improvement of the integrated management system. The internationally recognized standards ISO 9001:2015, ISO 14001:2015, OHSAS 18001:2007, ISO 27001:2013 guarantee for the Company's reputation and customer satisfaction seeking a high-quality product on the European Union market. We are proud to be part of this team and understand the role of each member who is essential to our successful business with his personal contribution.

We strive to promote the Company's strategic values in our day-to-day activities and relationships with our colleagues, clients, suppliers and stakeholders.

Оur code of ethics represents us and our goals, through the achievement of which we will guarantee the success of our business. Business whose main features are quality, transparency and integrity.

Each and every employee of ITA must get acquainted with it and re-read it whenever they shall hesitate how to act in their day-to-day activities.

 

  • General scope. Persons to whom the Code applies.

The Code of Conduct and Anti-Corruption Policy (briefly "Code") defines the fundamental rules for employees, including board members (all together hereinafter referred to as "employees") of "ITA Group Bulgaria" and all its subsidiaries. 

It is also expected that third parties (consultants, suppliers, subcontractors, etc.) acting on behalf of the Company will comply with the principles set out in this Code.

  • Company Regulations.

This Code is supplemented by the rules of Company Labor Code of the Company.

As far as the Rules of Company Labor Code are set as minimum standards of conduct, the Company can perceive additional measures.

  • Compliance Obligations.

All employees are responsible for knowing and complying with this to apply and comply the Code and Company Labor Code as well as other internal rules relevant to their specific tasks and activities.

Employees must participate in the induction and additional training programs for development.

  • Reporting for violations and misconduct.     

The Company urges employees to express concern about the practices and actions they deem that actually or potentially violate the law, the Code, Regulations of Company Labor Code or other internal rules.

Signals can be submitted in person or anonymously, verbal or in writing, shall be kept in strict confidence in accordance with state laws and regulations of the Company.

ATTENTION: The Code of Conduct affects our everyday work. For every new job we are engaged in, we should ask ourselves not only whether it is legal and permitted by the current legislation, but also whether it complies with the Code and the Company's Rules of Procedure. The breaches of the Code threaten the Company's activity and reputation. So do not hesitate to alert and report any wrongdoing to which you have witnessed.

  •     Infringements.

Violations of the Code and/ or other company regulations by employees may lead to disciplinary action in accordance with current local or European Union regulations. Such violations can also lead to implead or criminal prosecution.

  •    Integrity In Business            

 The Company operates in accordance with the legislation of the Republic of Bulgaria, professional ethics and its internal rules and regulations. It follows that the pursuit of company objectives can not be contrary to the principles of honesty and integrity. Every employee is responsible for how he performs his duties. If errors, omissions or defects are noted, he/ she is obliged to remove them if they are in his/ her credentials or to immediately notify his / her supervisor, line manager to take appropriate actions;

It is explicitly the observance of the labor legislation, the norms for health and safety at work, observance of the laws regulating the activity of the company, as well as the internal rules;

In relation to all internal and external business relationships, any discrimination based on age, racial and ethnic origin, nationality, political beliefs, religion, gender, sexual orientation, state of health are avoided;

Employees must behave fairly and honestly, respecting the internal rules, the provisions of this Code and their commitment to sustainable development. Managers are expected to lead by personal example and encourage a culture of ethical and legal compliance.

  •    Corporate Social Responsibility.

 The Company strives to contribute to quality economic and social development based on respect for fundamental human and labor rights as well as protection of the environment in a healthy working environment.

Through corporate social responsibility we make our voluntary contribution to Bulgarian society. This approach is embedded in the way we work to provide long-term and sustainable solutions. We strive to create, initiate and support programs that are in tune with our business. Science, education, innovation, road safety are the topics around which our activities in the sphere of corporate social responsibility in Bulgaria are concentrated. We undertake long-term activities for the benefit of the widest possible range of people. We believe that in this way we can be most effective and beneficial.

For this reason, employees are socially engaged:

  • to take out the best of their colleagues by encouraging personal development and recognize the individual contribution of each of us for the success of the organization;
  • to put the competence and resources of the company at the service of those who are most vulnerable in order to promote the social inclusion of the poor and disadvantaged;
  • to contribute to environmental protection by encouraging the reduction of direct and indirect environmental impacts of their activities.

 

  •      Work Environment, diversification and people integration.

The company provides a motivating work environment without any discrimination or harassment of any working place. With regards to the people, diversification and inclusion are encouraged by the conviction that the collaboration of people from different cultures with different skills, experience and worldview is crucial for attracting talent to ensure business development.

Employees should treat each other with respect by avoiding any action that can injure a person's personal dignity.

Managing staff should create a welcoming atmosphere and climate of mutual support where there is a genuine desire for honesty, respect, cooperation, cultural diversity and a sense of belonging.

Decisions affecting employees, including hiring, appointment, training, assessment and staff development are based primarily on individual merit and performance and can not be influenced by racial and ethnic lines, religious/ belief and sexual orientation, marital status and political views. Messages to employees must be clear and honest. Managing staff encourages the development of the individual skills and abilities of employees by providing them with suitable professional training as part of a wider framework for staff development.

The Management respects its employees' freedom of association and collective bargaining. It categorically rejects any form of illegal labor and exploitation, as well as any form of forced labor and exploitation of child labor. It stands against all kinds of violence, harassment and ill-treatment in the workplace.

IMPORTANT! Warning signals and advice in case of harassment in the working place

        We must reject any disrespectful behavior, bearing in mind that the feeling of harassment is determined by the way in which others perceive our actions, regardless of our actual intentions. Therefore, for example, emails and messages with sexually implied meaning, obscene gestures and physical contact, as well as insulting and degrading statements about one's personal characteristics are prohibited and will be treated as a form of harassment, whether presented as playful remarks or jokes. If you have the feeling that you are the victim of some kind of violence, harassment or abuse at work, do the following:

  • Explain in writing what happened (date, time, place, situation, witnesses) and keep evidence of any unacceptable behavior (eg. materials, correspondence and etc.);
  • Give the offender a clear sign to understand that such behavior is unacceptable and must to
  • The Management stands against any form of harassment, and strictly sanctioning such bad behavior;
  • If this employee continues to behave indecently, do not hesitate to report the situation, as this is also a violation of this Code;
  • Remember that you can always contact the management for assistance

 

  •    Health and the environment.

 The company guarantees fair working conditions by providing a healthy and safe work environment.

Employees are required to avoid any action that may endanger the health and safety of others.

Employees support the efforts of the Company to protect the environment and reduce environmental impacts not exercised by their work activities.

  • Protection of assets and business data.

 It is necessary to protect the tangible and intangible Company assets as well as those of clients and suppliers made available to him/her in the performance of his/hers official duties and/or in unforeseen circumstances.

The tangible assets of the Company, including real estates, equipment and inventories, must be protected from damage and unauthorized use and must be used for business purposes only, unless otherwise permitted.

Any information relating to the Company's activities is considered as confidential, including any information obtained in the performance of tasks on its behalf. Employees must treat such information as strictly confidential and may disclose it only on the basis that it is provided only if it is explicitly required or specifically authorized. This policy applies to all documents containing confidential information.

Intellectual property of the Company (ie ideas, products, methodologies, strategies, etc.) should also be protected through patents, trademarks and copyrights whenever possible.

The obligation to protect the intellectual property of the Company continues to be valid even after leaving the company and under the Additional Agreement to the labor contracts.

All business data should be recorded accurately and comprehensively. Official documentation must be available and accessible at the request of the competent authorities and authorized personnel.

All documents and data, including files and e-mails must be retained as long as required by applicable law. In the case of pending lawsuits and foreseeable court procedures, they should be kept for a longer period of time when necessary.

Strictly prohibited any unauthorized repairs and falsifications of information and documents.

IMPORTANT! The disclosure of confidential information, which is required only when it is expressly required, means that access to such information must be permitted only for specific and legitimate purposes. For this reason, whenever someone asks us to provide confidential information, we must carefully examine the purpose of this request, even if it is made by another department of the same company.

Any information relating to the Company's business must be kept throughout its period of use. We should be careful when throwing away documents that contain confidential information because they are subject to the same rules for proper handling of information.

  • Conflict of Interest

 Employees must act in defense of the interests of the Company.

A conflict of interest occurs when an employee engages in personal activities and relationships that may interfere with his ability to work for the interests of the Company. In principle, any conflicts of interest must be avoided, and when this can not happen, conflict of interest must be resolved in a way that protects the Company from damage.

  • Аnti-corruption regulations and practises.

Тhe company condemns and opposes all attempts of bribery and corruption.

Employees must do their work honestly.

No forms of corruption, including bribery and extortion, are tolerated. Therefore, employees must refrain from offering and accepting unregulated payments, gifts, treats or other benefits.

It is forbidden to make promises as well as giving and receiving gifts in the form of cash or equivalent means of payment, as well as all kinds of payment instruments.

The scope of Company's operations require interactions with government officials, public authorities and institutions and trade unions. In such circumstances, employees should refrain from directly or indirectly offering and accepting anything other than those related to customary duties, and in accordance with the law and customary local customs.

  • Customer Relationships.

 Customer satisfaction is a key factor in  strategic plan of the company that allows it to strengthen and improve its leadership positions.

When communicating with clients, employees should behave honestly, frankly, sincerely and professionally, by refraining from misleading and deceptive practices.

Employees must always take into account the interests of customers by offering them the solutions most appropriate to their needs. Conflicts of interest should be avoided, and if this is impossible, they are resolved in a way that protects the interests of the client.

When offering products and services, employees must provide true, accurate and factual information.

 

  • Fair competition.

The Company recognizes the fundamental role of competition in the expanding range of business opportunities and business results. Competition should be based on offering superior quality products and services as well as on fair trade practices.

It is forbidden employees to discredit competitors or their products and services as well as to manipulate, conceal or presented in an unsuitable manner in order to gain illegal benefits. In addition, practices and actions aimed limiting the free and fair competition are prohibited.

 In contacts with competitors, employees must take into account the law on protection of competition and to avoid any illegal activities in order to prevent the company and competitors from unfair treatment.

IMPORTANT! The following practices should be considered infringements of the rules of free competition:

- any agreements with competitors aimed at fixing tariffs and premiums or limiting the types and number of products and services being offered;

- exchanging information with competitors regarding future strategies for products and tariffs;

- choice of suppliers.

  • Anti-Money Laundering, Countering Terrorism Financing and International Sanctions.

The company supports the international fight against money laundering and financing of terrorism and is against any action that could mean support of such crimes.

Employees must have and maintain adequate information about clients and sources of funds used in transactions, in accordance with the Company's current legislation and policy. Whenever employees suspect that a counterparty is trying to use the products or services of the Company for illegal purposes such money laundering or terrorist financing, must immediately inform the relevant manager of the situation. These employees must have complete and updated information on relevant restrictive measures established by local government and international organizations against certain countries, people, assets or services.  

  • Training.

       In order to ensure that the Company Code is properly understood and implemented effectively, induction and annual training programs are held to comply with regulatory requirements.