CODE OF BUSINESS CONDUCT

ECOPSY complies with all applicable laws and regulations, acts ethically at all times and in all matters, conducts its business operations with an emphasis on Corporate Social Responsibility, ECOPSY has the same expectations of our Partners.

This Partner Code of Conduct (“Code”) establishes related requirements for all of our Partners.

ECOPSY expects all of its employees to comply with the law and act ethically at all times and in all matters. We have the same expectations of our Partners. Our Code of Business Conduct sets the basic standards for employee conduct. This Partner Code of Business Conduct establishes related requirements for our Partners (both Partners and Buyers).

This Code contains general requirements applicable to and expected from all ECOPSY Partners. Particular Partner contracts may contain more specific provisions addressing some of the same issues. Nothing in this Code is meant to supersede any more specific provision in a particular contract, and to the extent there is any inconsistency between this Code and any other provision of a particular contract, the other provision will prevail. As a ECOPSY Partner you are expected to demonstrate clearly that you comply with all applicable national and international laws and regulations. This applies especially to the following requirements, but is not limited to:

1. FAIR BUSINESS CONDUCT

Partners shall have an unwavering commitment to compliant, fair, ethical and responsible business conduct.

1.1. Anti-corruption

Partners are required to comply with anti-bribery and anti-corruption laws and regulations applicable to their activities. In connection with any transaction as a ECOPSY Partner or any other transaction that otherwise involves ECOPSY, the Partner shall not transfer anything of value, directly or indirectly, to any third party or any third party employee in order to obtain improper benefits and/or advantages. These prohibitions include kickbacks and facilitation payments. In addition, Partners shall not offer any ECOPSY Members benefits, including gifts and entertainment, that may cause suspicion regarding fairness.

*A facilitation payment is the provision of money or good to a government official to perform, or speed up the performance of, a duty the official already has to you. For example, paying a customs official to clear goods for import, where he is technically required to clear them anyway, would be a facilitation payment.

1.2. Conflicts of Interest

All ECOPSY employees should act in the best interest of the company. Accordingly, employees should have no relationship (financial or otherwise) with any Partner that might conflict or appear to conflict with the employee’s obligation to act in the best interest of ECOPSY (e.g. Partners should not employ or otherwise make payments to any ECOPSY employee during the course of business between the Partner and ECOPSY). Friendships outside the course of business are acceptable, but Partners should ensure that any personal relationship is not used to influence any ECOPSY employee’s business judgment. If an employee of a ECOPSY Partner is a family relation (spouse, parent, child etc.) to a ECOPSY employee or if a Partner has any other personal relationship with a ECOPSY employee that might represent a conflict of interest, the Partner should disclose this fact to ECOPSY or ensure that the ECOPSY employee does so (this is the Partners responsibility).

1.3. Fair competition. Anti Trust.

Partners shall comply with all applicable antitrust and competition laws and regulations and never engage in illegal anticompetitive activities. In particular, Partners shall not engage in any conduct which might be viewed as restricting competition between ECOPSY and any competitors of ECOPSY.

As a ECOPSY Partner you do not share or exchange competitive information (e.g., price, cost) or undertake collusive conduct with any third party, Partner or bidder to ECOPSY.

1.4. International trade controls

Partners shall never be owned or controlled by the governments of sanctioned countries/territories and act on behalf of those governments.

1.5. Prohibition of involvement with criminal organizations and individuals

Partners shall never engage in any criminal activities and have any relationships with criminal organizations or individuals.

1.6. Business and Financial Records

Partners are expected to keep accurate records of all matters related to the business with ECOPSY. This includes proper recording of all expenses and payments. If ECOPSY is being charged for a Partner employee’s time, accurate and complete time records must be kept. Partners should not delay submission of invoices or otherwise enable the shifting of expenses to a different accounting period.

ECOPSY expects Partners to keep true, accurate and complete business records of all matters related to business with ECOPSY including all expenses and  payments, in a form that can be made available to ECOPSY upon request.

1.7. Gifts, Meals and Entertainment

ECOPSY employees are prohibited from accepting anything more than modest gifts, meals and entertainment from Partners. Ordinary business meals and small tokens of appreciation (e.g. confectionary at holiday time etc.) are acceptable, but Partners should avoid offering ECOPSY employees any travel gifts, extensive entertainment or any other expensive gifts. Also, cash or cash equivalents, such as gift cards, are not acceptable to ECOPSY.

2. PROTECTING INFORMATIONAND PROPERTY

Partners shall have an unwavering commitment to compliant, fair, ethical and responsible business conduct.

2.1. Privacy data

Partners shall comply with privacy laws and regulations that are in effect in the countries and regions where they operate. In particular, Partners shall acquire and use all personal information with prior consent and ensure that personal information is not illegally acquired, used, transferred, disclosed, or leaked.

2.2. Intellectual property

Partners shall not use ECOPSY and other’s intellectual property unless authorized by the legitimate owner of the intellectual property. Intellectual property includes, including, but not limited to, patents, designs, copyrights, trade secrets, know-how and trademarks.

2.3. ECOPSY’s assets

When Partners are provided ECOPSY’s assets, Partners shall use them only for legitimate business purposes. Moreover, Partners shall protect confidential information related to ECOPSY and shall not share it with anyone at any time unless authorized to do so by ECOPSY.

3. IMPROPER PAYMENTS.

ECOPSY expects compliance with laws dealing with any form of bribery from all of its Partners. In connection with any transaction as a ECOPSY Partner or any transaction that otherwise involves ECOPSY, the Partner must not transfer anything of value, directly or indirectly to any third party or any third party employee in order to obtain improper benefits and/or advantages.

4. LABOR STANDARDS.

Hiring practices should be in compliance with the International Labour Organization (ILO) and the Conventions of the United Nations (UN), especially concerning standards on forced labour (ILO C29, ILO C105), the minimum age (ILO C138) and child labour (ILO C182).

  • Partners shall not use forced, bounded (including debt bondage) or indentured labor or prison labor, slavery or trafficking of persons.
  • Partners shall not employ a child at any stage of manufacturing or in the provision of services. The term “child” refers to any person under the age of 15, under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Partners shall also not employ persons under the age of 18 for work that by its nature or the circumstances in which it is carried out is likely to harm the health, safety, or morals of such persons.

Partners should provide fair and equal treatment and foster a culture of respect, tolerance and diversity (ILO C100, ILO C111). Moreover, they should provide safe, healthy and fair working conditions, fair working hours (ILO C1, C14) and wages and not tolerate any form of discrimination among their employees. Furthermore, Partners’ employees shall have the right to join workers’ organizations without consequences and to elect their representatives, to organize their administration and activities and to formulate their programs and goals (ILO C87, ILO C98).

  • Partners shall not require their employees to work beyond the maximum legal working hours, and shall pay them at least legal minimum wage in compliance with local laws.
  • Partners shall uphold the freedom of association and the recognition of the right the collective bargaining. All employees have the right to freely form and join groups for the promotion and protection of their employment interests to the extent permitted by law.

5. ENVIRONMENTAL SUSTAINABILITY.

All Partners’ business conduct should be performed in a way that avoids negative effects regarding the environment and complies with applicable laws and regulations.

6. HUMAN RIGHTS

Partners shall respect the human rights of employees.

6.1. Non-discrimination

Partners shall not discriminate against any employees based on grounds including race, color, religion, national or ethnic origin, ancestry, age, disability, gender, pregnancy or maternity, marital status, sexual orientation, gender identity or expression, political or personal belief, or union membership.

6.2. Anti-harassment

Partners shall provide a work environment that is free from harassment and bullying of any kind and any other offensive or disrespectful conduct

7. HEALTH AND SAFETY

Partners shall provide a healthy and safe workplace for their employees. This should meet international, national, and industrial standards.

8. COMPLIANCE CLAUSE

8.1. Compliance obligations

  • The Partner will comply with all applicable laws and regulations and the ECOPSY Partner Code of Conduct in connection with its business with ECOPSY.
  • The Partner has read and understands the ECOPSY Partner Code of Conduct, and will review its operations to ensure compliance with the ECOPSY Partner Code of Conduct.
  • Partners will acknowledge that the standards in the ECOPSY Partner Code of Conduct are being met upon the commencement and renewal of a contractual relationship with ECOPSY  Entity.
  • Partners shall maintain compliance with the ECOPSY Partner Code of Conduct throughout the relationship with ECOPSY  Entity and demonstrate that they comply with this Partner Code of Conduct upon ECOPSY ’s request.
  • The Partner will provide all information which ECOPSY  may reasonably request in order to evaluate whether a breach of its obligations under this Compliance Clause has occurred and the implications for its business. The Partner will cooperate with audits or inspections by ECOPSY  personnel and/or its designated third party when they are conducted at Partner’s facilities.

8.2. Acknowledgement:

The Partner acknowledges that it is neither acting nor will act directly or indirectly on behalf of ECOPSY  other than as specified herein.

8.3. Duty to notify:

The Partner agrees to notify ECOPSY  immediately (i) if the Partner discovers that it, or any of its shareholders, partners, legal or beneficial owners, directors, officers, managers, employees or agents, have violated its obligations under this Compliance Clause, and/or (ii) upon becoming aware that it, whether directly or through intermediaries, is the subject of any request for information, investigation, litigation, penalty, or claim from any government enforcement entity, or any third party, for violation of any applicable laws or regulations.

8.4. Indemnification:

The Partner will wholly indemnify ECOPSY  against any and all losses, costs (including reasonable legal costs), claims, damages, liabilities, fines and expenses suffered or incurred by ECOPSY  or its Affiliates as a result of any breach of this Compliance Clause.

8.5. Immediate termination:

Partner acknowledges that a breach of the provisions in this Compliance Clause will constitute a material breach of this agreement or business relationship, as the case may be, and ECOPSY shall be entitled to immediately terminate this agreement or business relationship, as the case may be, without limitation  of any other rights it may have. On termination for a breach of this Compliance Clause, Partner will not be entitled to claim compensation due to premature or unjust termination.

9. DISCLOSING POTENTIAL MISCONDUCT (“WHISTLEBLOWING”).

Partners who believe that an employee of ECOPSY, or anyone acting on behalf of ECOPSY, has engaged in illegal or otherwise improper conduct, should report the matter to the info@ecopsy.ru).

A Partner’s relationship with ECOPSY will not be affected by an honest report of potential misconduct.

The Partner hereby confirms that on the date the present Additional agreement is signed there is no to be provided to ECOPSY in accordance with the conditions of the Additional agreement that was concealed by the Partner.

ECOPSY hereby confirms its compliance with all above stated rules and obligations.

10. PERSONAL DATA

Hereby, ECOPSY guarantees compliance with the General Data Protection Regulation (GDPR) requirements for the receipt, processing and storage of personal data and expects the same degree of compliance from its partners.