TR| EN
Business Ethics
Our Business Ethics and Code of Conduct

Our guiding principles

Integrity, transparency and responsibility characterize the way we conduct business. Operating with a strong sense of integrity is critical to maintaining trust and credibility with our customers, partners, employees and other stakeholders. Such trust and credibility requires transparency in how we conduct business and confidentiality when we conduct business to protect business assets and the privacy of individuals.

Creating an environment of transparency in the conduct of business is a high priority for all of us. Our Code of Business Ethics is our promise to operate with candor and truthfulness in our dealings and communications to the marketplace. Everyone, from the members of the Board of Directors and the Executive Leadership Team to each individual working for ALKOR, will be held accountable for meeting these standards.

 

The Code of Business Ethics reflects our company’s commitment to conducting business responsibly including:

Being responsible corporate citizens

Respecting human rights throughout our business operations

Ensuring Worker health and Work safety

Encouraging sustainable development

Supporting the UN Global Compact principles as set forth in the Code of Conduct

 

The Code also contains rules for all individuals performing work for ALKOR, under the staff management of ALKOR or in ALKOR premises, whether as an employee of ALKOR or a subcontractor, or as a private contractor, including:

 

Ensuring compliance at all times with applicable laws, rules and regulations

Promoting full, fair, accurate, timely and understandable disclosure in financial reports

Appropriately dealing with conflicts of interest

Protecting and properly using company assets

Protecting non-public information

Our responsibility for compliance

Everyone working for ALKOR is required to review the Code, to support and work in line with the company’s commitments stated herein, and to follow the rules in the Code addressed to us as well as all applicable laws. In addition, we must follow ALKOR’s Group policies, directives and instructions as well as local directives and instructions; failure to do so may result in disciplinary action including termination of employment and/or civil and criminal liability. We place additional responsibilities on our leaders. Through their actions, they shall demonstrate the importance of compliance. Leading by example is critical, as is being available for those who have questions or wish to report possible violations of this Code.Leaders must ensure that this Code is respected and is enforced in their organizations. Leaders may not turn a blind eye toward unethical conduct.

 

Reporting compliance concerns

Individuals working for ALKOR– Individuals working under the staff management of ALKOR or in ALKOR premises are encouraged to report any conduct that they believe, in good faith, to be a violation of laws or the Code of Business Ethics to their manager or in accordance with locally established procedure. If the manager is involved in the situation or cannot or has not adequately addressed the concerns, employees are advised to report to a manager of higher rank or in accordance with locally established procedure.

Suppliers, customers and others - Suppliers, customers and other partners involved with ALKOR may report suspected violations of laws or the Code of Business Ethics to the local operations manager or in accordance with locally established procedure. Leaders are expected to seriously address a reported issue and to work to ensure a satisfactory resolution in alignment with these ethics, values, and procedures, and with any local statutory or regulatory obligations. ALKOR will not accept any discrimination or retaliation against the individual reporting the violation for having, in good faith, reported alleged violations.

Our obligation as responsible corporate citizens

We believe that communication is a basic human need that contributes to economic prosperity and social equity and provides solutions to many sustainable development challenges. It is important to behave in a socially and ethically responsible way, and we strive to be responsible citizens in the communities where we conduct business. It is important that the ALKOR brand is always associated with respect for human rights, fair and safe working conditions, and ethically and environmentally sound business practice.

Respecting human rights throughout our business operations

ALKOR respects all internationally proclaimed human rights, including the International Bill of Human Rights and the International Labor Organization´s Declaration on Fundamental Principles and Rights at Work, which address freedom of association and collective bargaining, forced labor, child labor, and non-discrimination. We are committed to implementing the UN Guiding Principles for Business and Human Rights throughout our business operations. Privacy and security are important elements in products and services delivered by ALKOR, and we align our product and business processes to ensure that human rights aspects of privacy and freedom of expression are respected throughout the operations of our products and services.

 

Health and safety

ALKOR is committed to maintaining a strong occupational health and safety culture, by promoting awareness, prevention and care.

In our daily operations, we work together with our customers, suppliers and other stakeholders to ensure a safe and healthy working environment.

Our commitment is demonstrated through a system of documented management controls and by taking any necessary actions. By applying these controls, we act as a responsible employer by seeking to protect the life and health of everyone working for ALKOR and protecting the commercial interest and brand of ALKOR and our customers.

Commitment to sustainable development

ALKOR is committed to the sustainable development of society, which is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. We define sustainability as long-term social equity, economic prosperity, and improved environmental performance. ALKOR shall strive to develop, produce and offer products, services, and solutions with excellent sustainability performance. We shall continuously work to reduce the negative impacts of our operations and to maximize positive impacts of our technology in order to enable the sustainable development of society.

 

 

 

Code of Conduct

For the purpose of respecting human rights and promoting fair employment conditions, safe working conditions, responsible management of environmental issues, and high ethical standards, our Code of Conduct is based on the UN Global Compact principles and shall be applied throughout the company´s operations, including the production, supply and support of ALKOR products and services worldwide.

The Code of Conduct provides that:

All persons should be free to peacefully and lawfully form and join, or not join, workers’ associations of their own choosing, and should have the right to bargain collectively.

ALKOR does not accept the use of child labor.

No individuals should be discriminated against because of race, color, gender, sexual orientation, marital status, pregnancy, parental status, religion, political opinion, nationality, ethnic background, social origin, social status, indigenous status, disability, age, or union membership, or any other characteristic protected by local law, as applicable.

All individuals should know the basic terms and conditions of their employment, and individuals with the same experience, performance and qualifications shall receive equal pay for equal work with respect to those performing the same jobs under similar working conditions.

The health of the workers and the safety of the workplace shall always be a priority concern. This applies to all aspects of working conditions.

It is the responsibility of each ALKOR employee to respect and promote the Code of Conduct, and it is the responsibility of each ALKOR unit and company, as well as of each manager, to ensure that ALKOR employees are treated in accordance with the Code of Conduct.

Suppliers and their subcontractors shall be required to comply with the Code of Conduct and to verify compliance.

 

Rules for everyone performing work for ALKOR, whether as an employee of ALKOR or a subcontractor, or as a private contractor

 

Compliance with laws, rules and regulations

ALKOR shall comply with all laws and regulations that apply to its business. As you conduct ALKOR’s business, you may encounter a variety of legal issues. Violations of any applicable law or regulation have serious consequences, both for ALKOR and for the individuals concerned. Therefore, it is your responsibility to be familiar with and comply with relevant laws and regulation including those listed below.

International business dealings – Specific laws and regulations apply to us when participating in international business. Everyone involved in international business transactions must be familiar with, and adhere to, all applicable domestic and foreign laws and regulations, for example export and import regulations, anti-boycott provisions, trade embargos, and sanctions in force.

Fair competition – ALKOR is dedicated to promoting fair competition. Fair competition is the basis for business development and innovation. Everyone working for ALKOR shall compete in the open market as vigorously and constructively as possible, while consistently complying with antitrust laws in each of the countries in which ALKOR operates. Antitrust law matters must be handled in concert with Group Function Legal Affairs, which is responsible for the management and co-ordination of such matters internally, and in relation to court or authorities.

Accounting and financial reporting ALKOR is required to follow strict accounting principles and standards, to report financial information accurately and completely, and to have appropriate internal controls and processes to ensure that accounting and financial reporting complies with applicable laws, regulations, and listing requirements. You must support the company’s efforts in this area. Privacy- ALKOR is committed to protecting the privacy of personal information, such as information relating to employees, partners, external workforce, customers, and end-users. ALKOR is required to follow laws relating to the protection of personal information. When you are involved in accessing or processing personal information, you must familiarize yourself and comply with applicable legal and contractual requirements.

Communication and financial information

It is important that ALKOR employees have a good understanding of their units’ operational and financial performance to increase involvement in improving operations. Everyone involved in financial reporting shall always provide full, fair, accurate, timely, and understandable disclosures in reports and documents that ALKOR files with or submits to government agencies or authorities or makes in other public communications.

 

Dealing with conflicts of interest

We make business decisions based on the best interests of the Group rather than personal considerations or relationships. A conflict of interest arises when anything interferes with or influences the exercise of our independent judgment in the best interest of ALKOR. We must avoid situations in which our personal interest may conflict with, or even appear to conflict with, the interests of the Group.

The following are examples of situations to be particularly aware of:

Business opportunities – You may not take business opportunities for yourself that are identified in your duties for ALKOR if this could be contrary to the interests of ALKOR. Nor may you otherwise use ALKOR property or information or your position at ALKOR for personal gain.

Other Employment – You may not take any employment outside ALKOR, with or without compensation, that harms or may harm job performance at ALKOR or creates or may create a conflict of interest. ALKOR employees may not engage in outside business interests that divert time and attention away from ALKOR responsibilities or require work during ALKOR time. ALKOR employees shall avoid any potential conflict of interest by not accepting employment from any ICT organization or any supplier, contractor, agent, customer, or competitor of ALKOR.

Board memberships and other outside affiliations – ALKOR employees may not serve on a board of directors or similar body of a for-profit enterprise or government agency if it creates a conflict of interest. All such service must be approved, in advance, by your manager. Serving on boards of not-for-profit or community organizations does not require prior approval unless there is a potential conflict of interest with ALKOR.

Political activities – ALKOR will not make contributions or payment or otherwise give any endorsement, directly or indirectly, to political parties or committees or to individual politicians3 You may not make any political contribution on behalf of ALKOR or through the use of corporate funds or resources.

Gifts, benefits, reimbursements and entertainment – You may not offer or accept gifts, benefits, reimbursements or entertainment to or from a third party that would constitute a violation of laws or that could affect, or appear to affect, your professional judgment in the performance of work or duties for ALKOR or a third party.

Bribes, kickbacks, etc. – No one may, directly or indirectly, demand or accept, offer or give any kind of bribe, kickback or any other unlawful or unethical benefit to employees, or other representatives or associates, of ALKOR or any third party. Any such offer or proposed arrangement must be reported immediately to Group Function Legal Affairs.

Disclosure of conflicts of interest – ALKOR requires that you disclose situations or transactions that reasonably would be expected to give rise to a conflict of interest. If you suspect that you are involved in a transaction or any other arrangement that presents a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it to your manager or to Group Function Legal Affairs. Your manager and Group Function Legal Affairs will work with you to determine whether there is a conflict of interest and, if so, how best to address it. Although transactions or arrangements presenting conflicts of interest are not automatically prohibited, certain transactions or arrangements may be undesirable, and for certain persons, such as members of senior management, such transactions or arrangements may require the approval by Board of Directors

 

Protection and proper use of company assets

ALKOR has a wide variety of assets, including physical assets, proprietary information and intellectual property. You are responsible for protecting ALKOR property entrusted to you and for helping to protect ALKOR’s assets in general. To do this you must be aware of and understand ALKOR’s security directives. You must be alert and report any loss, or risk of loss, of ALKOR properties to your manager  as soon as they come to your attention.

Below, you will find certain instructions for internal and external handling of information, communication systems and intellectual property.

Intellectual property – Intellectual property includes a variety of properties, such as computer programs, technical documentation and inventions. Certain intellectual property is, or can be made, subject to special protection through copyright, patent right, trademark right, etc.

Intellectual property is an asset of utmost value to ALKOR and must be treated with appropriate care. You must follow and, in case of doubt, seek instructions on how you shall act to protect this valuable asset.

Intellectual property created by ALKOR employees under the employment is transferred and assigned to ALKOR by law and/or the employment contract or other agreement, with the exceptions stated ininternational conventions, applicable laws and the agreement with ALKOR.

Use of ALKOR IT resources – ALKOR IT resources, including communication systems and connections to the Internet, shall be used for conducting ALKOR business or for other incidental purposes, authorized by your management or applicable Group steering documents. You may be authorized by managemen  to access ALKOR’s IT resources with devices and storage media not provided by ALKOR.

To the extent allowed under applicable law, access to ALKOR’s IT environment from any device or storage media (whether provided by ALKOR or not) may be checked for installed software, USB storage, firewalls, administrator information, additional network connections, encryption, anti-virus or malicious software and components, etc. For the purpose of protecting ALKOR business and detecting unacceptable use of ALKOR’s IT resources, you may be asked to provide access to any devices and storage media used to access ALKOR’s IT resources or store ALKOR information. Such a request can only be made by an authorized security function and in accordance with applicable processes.

Unacceptable use of ALKOR’s IT resources includes: processing, sending, retrieving, accessing, displaying, storing, printing or otherwise disseminating material and information that is fraudulent, harassing, threatening, illegal, racially or sexually oriented, obscene, intimidating, defamatory or otherwise inconsistent with a professional environment.

When you leave ALKORyou must return all ALKOR assets, including documentation and any media containing ALKOR proprietary information. You remain bound by the restrictions for use and disclosure of ALKOR proprietary information after you leave ALKOR.

 

 

Protecting information

Protecting ALKOR’s confidential and proprietary information and that of our customers, partners and suppliers

Persons working for ALKOR have access to information owned by ALKOR and sometimes also to information owned by third parties. Such information may be financial information, business plans, technical information, information about employees and customers, and other types of information. Non-authorized access, use and disclosure may damage ALKOR or the third party and, therefore, you are not allowed to access, use or disclose the information unless you have been properly authorized to do so. Non-authorized access, use and disclosure may also be a violation of laws, including privacy regulations. Whenever you are in doubt of your authorization, you must seek instructions from your manager or ALKOR Security.

Here are some rules that will help protect non-public information of ALKOR and its customers, partners and suppliers:

Do not disclose to others information not made public by ALKOR except to, persons working for ALKOR who, in their work, need access to the information and who have justified reason to have the information, anyone else authorized by ALKOR as the receiver of such information or persons to whom you, according to your work duties, shall give such information.Do not directly or indirectly access, duplicate, reproduce or make use of non-public information other than in the course of your duties and work for ALKOR. When leaving ALKOR, any authorization to access or to use non-public information expires, and any information in your possession must be returned or disposed of.

 

Upon learning of any wrongful use or treatment of non-public information, promptly notify your manager and cooperate in full with ALKOR to protect such information.Do not store non-public information on private computers, storage media or other devices not authorized by ALKOR. Third party cloud services, or other online hosting services, should only be used to store non-public information if approved for that purpose by ALKOR.Accesses and authorizations provided to persons working for ALKOR may only be used in the manner in which they were intended. Passwords and pin codes and similar information must never be shared or provided for use to unauthorized persons.