Code of Ethic

ETHICAL CODE CZECH AEROSOL, a.s.

The aim of establishing a Code of Conduct is to provide clear rules and guidelines to be followed by the company, employees and business partners in all activities.
In order to preserve and enhance the reputation and goodwill of Czech Aerosol a. s., we focus on honest and fair conduct in the following areas:

I. Business relations
In business relations, the company is represented by a specific employee who deals directly with the customer and establishes long-term business relationships with them. All signing, decision-making or approval authority and trading limits must be observed.
Employee chooses practices that meet the highest ethical standards when dealing with business partners. Act in accordance with the rules and procedures set out in this Code, comply with applicable and effective legislation, the provisions of the Civil Code and the principles of fair business conduct. An employee may only enter into, decide or approve commitments on behalf of the Company for which he/she has been granted approval powers.
In particular, the employee shall observe the following rules and procedures in his/her dealings with business partners:
a) acts in a way that does not take advantage of the company's market position;
b) provides its services competently, honestly, professionally and takes into account the legitimate interests of the customer to the greatest extent possible;
c) provides truthful information in an understandable form, discloses all terms and conditions of the contractual relationship, and draws attention to provisions of a punitive nature;
d) does not conceal any facts that may be of material importance to the business partner;
e) makes sure that the business partner understands and agrees with the information provided;
f) does not offer benefits that it cannot guarantee;
g) treats the business partner with courtesy and friendliness and does not put pressure on him/her;
h) upon request, provide business partners with the currently valid and effective terms and conditions, price list or other contractual terms.
The employee also defends the interests of the company by his/her actions and requires the same standards of integrity from business partners.

II. Conflict of interests
The Company shall not restrict employees from engaging in other gainful employment, provided, however, that the following points are met:
- the activity in question does not adversely affect the performance of job duties and tasks;
- must not be identical to the employer's subject of activity or could by its nature constitute a potential conflict of interest.
The Company expects its employees to be able to clearly distinguish the boundary between their professional and private lives and to act at all times in a manner that preserves their independence and avoids conflicts of interest.

III. Donations/bribes/corruption
The Company supports all necessary measures to prevent corruption. It ensures that its business partners comply with the relevant duties of care of a good trader. Employee compliance with anti-corruption rules is communicated to them as part of workplace safety training or internal auditor training, as appropriate. The Company creates conditions under which corruption is prevented or at least limited.
The Employee shall only provide/accept hospitality and gifts on a limited basis as a generally accepted part of building good business relationships, provided that such gift is in compliance with applicable laws and that it does not obligate the recipient in any way to the donor or give the appearance of such.
Employees do not accept any financial gifts from business partners (or companies seeking to become a business partner), even in the form of vouchers. Such offers must be refused in a friendly but firm manner.

IV. Human Rights
The Company shall ensure and create such conditions that employees can properly perform their work during working hours. Employees must use their working time efficiently and only perform activities that benefit the employer. The success of the company is largely dependent on good cooperation and communication between employees. The company expects its employees to be friendly and open, respectful and to build team spirit. Leaders in particular must act with integrity, be open and share necessary information that could be important to others, always respecting other rules such as confidentiality. They handle difficult and uncomfortable situations with courage. The company places great emphasis on creating a good working environment where employees feel comfortable and proud of where they work.
a) Anti-Discrimination Ordinance: it is prohibited to discriminate in any way or treat employees or job applicants unfairly. Any employment decision regarding our employees (wages, compensation, career advancement, access to education) or job applicants is based on past work performance, qualifications, performance, without regard to race, color, age, sex, sexual orientation, gender identity, ethnic or national origin, disability, marital status, pregnancy, religion, political affiliation, union membership, etc. The basic criteria for employee development are performance and potential. All employees can express themselves openly and their views are taken into account.
b) Anti-Harassment Policy: the Company strives to create a work environment that is free from harassment or offensive or disrespectful behavior. The Company places great emphasis on courteous behavior. Conduct in the workplace must not make others uncomfortable or endanger their health and safety.
All employees are prohibited:
– exert undue pressure or influence;
- to make offensive remarks;
- act in a way that undermines the integrity or dignity of other colleagues;
- to gang up on other colleagues;
- Bully, harass or sexually harass colleagues;
- to abuse his position in relation to his colleagues.
c) Intolerance of violence: the company does not tolerate any form of violence in the workplace and does not support the use of corporal punishment. Any activity that may cause individuals to feel threatened or unsafe is unacceptable. The same includes verbal attacks, threats, or other acts of hostility, bullying, aggression, etc.
d) Volunteer Work: The Company shall not employ or otherwise use the labor of minors in circumstances in which the tasks performed by such labor could reasonably be expected to cause physical or emotional impairment to the development of the minor.
The use of forced or slave labour or work with unfavourable conditions for the employee is prohibited. Employees shall not be required to pay any fees as part of their employment.
e) Employee development: managers are interested in the further growth of their subordinates. The company offers professional development opportunities to employees and strives to meet their needs and requirements, taking into account the nature of the work, technical and operational conditions, so that employees can deliver quality work performance. The initiative of individuals in the direction of their further development is encouraged and they are offered the opportunity to acquire all the knowledge they need to perform their work. In addition, the company encourages initiatives that enhance employee motivation, such as working from home, online language learning, webinars, etc.
f) Dress Standards: the Company does not require formal work attire in the normal course of business. However, an employee must dress cleanly and appropriately for his or her position. For meetings with third parties or when the situation calls for it, more formal attire is desirable. Short pants, slippers (rubber flip-flops) or T-shirts with flashy lettering are considered inappropriate attire.

V. Health and safety
The company continuously creates and ensures conditions for safe and health-safe work, takes measures to prevent potential threats to the lives and health of employees and co-workers. Employees and co-workers observe the adopted occupational health and safety measures in order not to endanger themselves and their surroundings. They alert supervisors to potential health hazards, use prescribed protective equipment and clothing, maintain cleanliness, respect applicable OSH legislation and comply with internal guidelines and procedures.
Employees have the right to raise their concerns:
- if they are asked to perform a task they consider dangerous;
- if they would be doing work that they believe they are not properly trained to do and may cause harm to themselves or others;

VI. Environment
Environmental protection and conservation of natural resources are very important to the company and all employees. The company complies with all legislative requirements and actively prevents environmental pollution. The Company and its employees behave responsibly towards the environment (in particular, they do not waste energy or consumables and take care to minimise the environmental burden resulting from their activities).

VII. Tax treatment
The company prides itself on professional compliance with all tax laws. Employees must not give advice that could lead to a breach of tax legislation. It is forbidden to create mechanisms that would contradict normal practices and lead to tax fraud.

VIII. Company assets
Employees shall use the Company's resources economically and shall not intentionally conceal, alter, falsify or exchange information for their own benefit. Employees shall use the items entrusted to them efficiently and only for Company purposes. Company property shall not be deliberately damaged.

IX. Information
The Company requires employees (even after termination of employment) to maintain the confidentiality of information and trade secrets provided by a third party, even after the termination of the relationship.
Employees who come into contact with the personal data of employees, suppliers, customers, etc., and employees who use IT systems must pay special attention to the protection of personal data and comply with Regulation No. 2016/679 of the European Parliament and of the Council (GDPR), including Czech legislation and internal regulations of the company that affect this. Employees must not enter incorrect or distorted data into IT systems and must not conceal any data relevant for decision-making. Employees must not allow unauthorised persons access to the Company's premises or information systems.
Employees who handle or have access to personal data shall observe the principle of necessity. Any information about customers or business partners obtained in the course of business is subject to the obligation of confidentiality. Employees will not request data that is not directly related to a specific process or legal regulation (e.g. the obligation to collect and process personal data for employers is imposed by law). Personal data must remain confidential and be protected against unauthorized use, disclosure, alteration or destruction.

X. Conclusion
Employees of the company, as well as persons outside the company, can express their opinions, questions or comments through the anonymous mailbox located on the 1st floor - in the corridor near the canteen. They can also use the e-mail address: etickykodex@czechaerosol.cz or mail to Velvěty 33, 415 01 Rtyně nad Bílinou.
Management addresses all allegations of violations of this Code and ensures that appropriate corrective action is taken at regular management meetings. If the inquiry, comment or complaint is signed, management will respond to the employee within 30 days.
The company's management clearly and strictly rejects non-compliance with or attempts to circumvent the rules of the Code of Ethics. In the event that a violation is confirmed, the offending person is treated as follows, depending on the degree of the violation and misconduct:
- reproach;
- a call to remedy the undesirable situation and to implement corrective measures;
- compensation for damages;
- with a fine;
- termination of cooperation;
- report to the Police of the Czech Republic or other authorities.
Violations of the Code of Conduct are always communicated with the person concerned, his/her immediate supervisor and the Human Resources Director. A record of the discussion of the breach of the Code of Ethics is made. A report of complaints of non-compliance with the Code of Ethics is included in the QMS management review.
It is important for the management to maintain a working environment where everyone has the opportunity to express their opinion openly. The company also has a frank and fair dialogue with employee representatives.