SUPPLIER CODE OF CONDUCT
Effective date: 01.10.2024
„Universum Energy Project Development“ EOOD is a solely owned limited liability company, registered in Bulgaria, UIC 207967704, with registered seat and address of management: 1797 Sofia, Musagenitsa (Mladost-1) residential area, blok 98Б, entrance A, floor 6, ap. 13 (the Company, We, Us).
This Code of Conduct („Code of Conduct”) has been adopted on 01.10.2024 with a resolution by the sole owner of the capital of the Company and applies for the Company and all its subsidiaries and their suppliers.
Тhe Company is committed to ensuring that its supplier chain is robust and compliant with all applicable laws.
We, therefore, require all our service providers to sign up to our Supplier Code of Conduct which defines the basic requirements and responsibilities for all our suppliers.
We reserve the right to amend these terms from time to time as the most recent version will be available on our website.
I. INTRODUCTION
Our Company is committed to its values of being thoughtful, open, adaptable, and trusted company, and seeks to implement these values in its relationships with employees, clients and suppliers and as such we require that all our suppliers (including but not limited to our vendors, agents, subcontractors, consultants, intermediaries and other business partners) also adhere to these values. We are keen to work with suppliers who are “open” and “trusted” and who respect and take our values seriously and therefore observe the highest ethical standards, comply with all applicable laws and meet the requirements established in the present Code of Conduct.
For the avoidance of doubt, this Code of Conduct applies to our suppliers and their subsidiaries, subcontractors, consultants, agents and others, who provide goods or services to the Company. The Company requires all suppliers to ensure that their supply chains comply with and respect all applicable laws observing the highest ethical standards and respectively adhere to the standards set out in the present Code of Conduct.
II.GENERAL PRINCIPLES
The Company is aware that working sustainably, respecting human rights, and operating with the highest standards of ethical conduct and professional integrity improve long-term business performance. We are dedicated to these principles and require our suppliers to share our commitment by complying with the obligations set out in this Code of Conduct. The specific requirements we have set out should be seen as a minimum standard and we encourage all our suppliers to go beyond these standards, particularly where they operate in geographic regions, where local laws and regulations are arbitrarily enforced.
III.SUPPLIER CONDUCT
COMPLIANCE WITH LOCAL LAWS AND REGULATIONS
Suppliers shall comply with all relevant laws, regulations, and standards in the countries in which they operate. Where the applicable laws and the Code of Conduct address the same subject and are not in conflict, the highest standard shall apply. Should any of the Code of Conduct’s requirements conflict with any applicable laws, the highest standards consistent with applicable local laws shall apply.
BRIBERY AND CORRUPTION
The Company does not tolerate any form of corruption or bribery within its supply chain and strictly prohibits corruption, bribery, kickbacks, fraud, theft, extortion and embezzlement of any kind. All suppliers must comply with all applicable anti-bribery laws and keep actual and accurate books and records that correctly reflect their transactions and do not contain false or misleading information. Suppliers shall not give to, offer to give to, request from, or agree to accept money or anything of value from anyone be it directly or indirectly through another party, to gain an improper advantage whether related to the goods and services provided to the Company or not. Suppliers undertake to adhere to the highest anti-bribery and anti-corruption standards and are expected to maintain their own anti-bribery compliance program to identify, prevent and determine any actual or suspected violations.
GIFTS AND HOSPITALITY
Suppliers undertake not to directly or indirectly, offer gifts, hospitality or other benefits to the Company’s employees or representatives with the intent to improperly influence or induce them to perform a certain action or omission. The suppliers undertake to not offer to the Company’s employees or representatives any gifts or hospitality, regardless of their value, during contract negotiation, bidding, tender, public procurement and supply contracts, etc.
MONEY LAUNDERING
Suppliers shall firmly oppose all forms of money laundering and take all reasonable steps to prevent financial transactions from being used by others to launder money. Suppliers shall notify the relevant local government authority if they become aware of any such transactions.
UNFAIR BUSINESS PRACTICES
Suppliers undertake not to violate or agree to participate in any violation of competition laws. Suppliers undertake to maintain fair business, advertising and competition standards and to notify Competition on Protection of Competition in Bulgaria (or relevant local supervisory authority) if they believe that competition law has been breached, or if they have concerns about the existence of a problem in the market sector.
CONFLICTS OF INTEREST
A conflict of interest means any circumstance, potential, actual, or perceived, that might cause a party to prioritize their financial or personal interests or might cause that party to be biased in their business judgments, decisions or actions. Suppliers must avoid any conflict of interest when doing business with the Company and shall further report any conflict of interest that may be relevant to the Company.
In addition, anyone who has information about corruption or a conflict of interest within the meaning of the Bulgarian Anti-Corruption Act for a person holding a public position is advised to report it to the Bulgarian Anti-Corruption Commission.
HUMAN RIGHTS AND MODERN SLAVERY
For us, it is important that we continue to identify and manage potential risks associated with human rights violations in our business and supply chain, adapting to changing times and global issues.
Suppliers shall respect and promote universal human rights as stated in the United Nations’ Universal Declaration of Human Rights. Suppliers shall not aid in any human rights abuses of any kind and will respect the personal dignity, privacy and rights of individuals at all times and shall not tolerate any unacceptable treatment of employees, such as but not limited to mental cruelty, physical abuse, mistreatment of persons with disabilities, slavery and sexual harassment.
Suppliers shall ensure the work relationship between the employee and supplier is freely chosen and free from threats, intimidation, or coercion and shall not use any form of forced labour, debt bondage, or involuntary and compulsory labour. Suppliers shall not require employees to surrender any government-issued identification, passports, or work permits as a condition of employment.
CONFIDENTIALITY AND DATA PROTECTION
The Company respects the confidentiality of the information and is committed to protecting the personal data and business data of its customers, suppliers and employees. The confidentiality and security of the data entrusted to us are one of our priorities.
Suppliers shall handle and disclose personal data and any confidential information that they obtain in the course of their relationships with the Company, as authorised and directed by the Company and as required by applicable laws and regulations. Suppliers shall protect personal data and confidential information against unauthorised and unlawful use, disclosure, access, loss, alteration, damage and destruction.
INTELLECTUAL PROPERTY
The Company is committed to protecting its intellectual property and respecting the valid intellectual property rights of others.
Suppliers shall respect the intellectual property rights of the Company and others. This means, for example, that suppliers shall not use the Company’s intellectual property in a manner that is not authorised by the Company.
NON-DISCRIMINATION
Suppliers shall provide a workplace that is free of harassment and discrimination. Suppliers shall not engage in discrimination based on any ground including class, age, race, colour, ethnicity, indigenous status, national origin, gender, gender identity or expression, sexual orientation, disability, pregnancy, medical condition, religion, social origin or status, political affiliation, trade or union membership, or marital or veteran status in hiring or employment practices, such as promotions, rewards, and access to training.
OPEN AND HONEST ENGAGEMENT
Suppliers shall support open and honest engagement between employees and management without fear of retaliation, reprisal, intimidation, or harassment and recognise, as far as legally possible, the right of free association of employees.
The Company expects suppliers to report in good faith any concerns that may arise in connection with the Company’s business (including the provision of goods or services to the Company) and potential violations of this Code of Conduct, laws, regulations or ethical and professional standards.
We encourage all our suppliers to reach out to us at compliance@universum-energy.com. If you have serious concerns around any suspicion, offence or improper conduct and wish to confidentially report this, please mark your email as confidential. You can include a subject line that indicates the level of confidentiality, such as, for example, „Confidential“, or „Private“.
SANCTIONS AND EXPORT CONTROL
The Company does not conduct activities nor assist any other party in violating applicable economic sanctions or export control laws and regulations.
Suppliers shall comply with applicable economic sanctions and export control laws and regulations and avoid doing anything that would position themselves or the Company in violation of applicable economic sanctions and export controls.
FACILITATION OF TAX EVASION
The Company is committed to preventing the facilitation of tax evasion by associated individuals or businesses anywhere within its operation. The Company conducts all business in an honest and ethical manner. It is not acceptable for any supplier to engage in any form of facilitating tax evasion and suppliers must avoid any activity that might lead to or suggest facilitation of tax evasion.
ENVIRONMENT AND POLLUTION PREVENTION
Suppliers shall act in accordance with applicable standards regarding environmental protection and will adhere to applicable environmental laws to ensure responsible practices. Suppliers shall obtain, and adhere to, all necessary permits and strive for the implementation of an environmental management system. Suppliers will endeavour to minimize, or strive to avoid, hazardous air emissions, energy consumption and CO2 emissions as well as to limit the use of materials and resources when sourcing or producing goods in order to minimize their environmental impact. In countries where legislation is less developed or unenforced, suppliers will strive to minimize environmental pollution. Innovative developments in products and services that offer environmental and social benefits and the use of environmentally friendly technologies should be supported.
ACCIDENT AND EMERGENCY READINESS
Suppliers shall maintain systems to prepare for and respond to global crisis, accidents, health problems, and emergencies. Suppliers shall have robust plans to ensure limited disruption to services provided to the Company.
MONITORING AND SOCIAL, ENVIRONMENTAL, COMPLIANCE AUDITS
The Company shall have the right to audit Supplier’s records and facilities related to the compliance with this Code of Conduct. Such audits may be conducted by the Company and/or its authorized representative at reasonable times during normal business hours upon providing 5 days’ written notice to the Supplier. The purpose of such audits is to ensure compliance with the terms of this Code of Conduct and to verify the accuracy of the Supplier’s performance.
Тhe Company and/or its authorized representative shall have the right to perform audits including on-site inspections and/ or launching due diligence questionnaires. At the Company’s request, the Supplier shall inform the Company of the measures implemented to ensure ongoing compliance with the principles set in this Code of Conduct.
If the Supplier believes or has reasons to assume that there is a failure to comply with the principles set in this Code of Conduct, it shall immediately notify the Company and provide the Company with information about the measures taken to ensure compliance with this Code of Conduct.
