Employees should be aware of the risk of potential conflicts between the Group’s best interests and the interests of themselves or someone close to them. They should never make any decisions that would be harmful to the Group because of such a conflict of interest.
Relationships with public officials are particularly sensitive. Employees should always avoid violations of laws involving public officials and ensure that all dealings between the Group and government officials and agencies are appropriate. The Group’s strict compliance with law policy also applies to agents, consultants and other third parties which may represent the Group.
Specific rules and regulations have also been put into place because shares of the Group are publicly listed on stock markets. The insider information policy prohibits employees from using or disclosing insider information or tips for securities trading purposes.
Anti-trust laws and regulations prohibit any direct or indirect agreements, understanding, or communications with competitors regarding prices, markets, customers, and any other business conditions or policies.
The anti-fraud provision of the Code of Conduct prohibits the deliberate abuse of Group procedures, systems, assets, products and/or services to attain benefits deceitfully or unlawfully.
Our anti-corruption policy means that it is forbidden to directly or indirectly pay, offer or promise any payments of any kind and in any form to any public official. Under the Group’s anti-money laundering policy, the Group pledges to do business only with customers involved in legitimate enterprises using funds from legitimate sources.
Gifts and entertainment represent another area where ethical issues can be difficult to interpret. The Group policy is that employees shall not give gifts to customers or provide them with hospitality other than such hospitality as appropriate in a normal business relationship.