Communication from the General Director

The fundamental strategy of Sament Group’s development is based on active and consistent actions towards the expansion of our presence on the international markets. Our objective for significant export development is based on the understanding that namely while operating without geographic constraints we may face real challenges that could promote our growth. We believe that this is the right path on which to develop and to improve the products and services which we offer, in order to satisfy the various needs and demands of our clients.

Such development results in new challenges and responsibilities for each of us to overcome and fulfil. Results and higher common goals are irrevocably related to individual qualities and results, based on trustworthiness and mutual assistance.

The Code of Ethics defines the ethical principles that I expect each of us to follow, irrespective of his or her position or responsibilities. These principles are not new, many of them are well-known to some of you. These principles and values are summarized in the Code of Ethics in a synthesized pattern, so that when someone has any doubts as to how  he or she should act in a given situation, he or she will find answers to the relevant questions in the most convenient manner.

In order to be successful and achieve our objectives, over and above the overriding qualities of professionalism and effectiveness, we need these invisible threads that connect and unite us – namely, the principles and values which hold us together– the Code of Ethics.

I would like to ask each of you to carefully review the presented document. Should you not understand something, do not hesitate to ask for clarity. Each of you are required to conform to the principles and values as set out in the Code of Ethics.

Conformity with the laws and provisions

Since we are an ethical company, our personal responsibility is to know and respect not only the Bulgarian laws and provisions related to the essence of our work, but also those of the particular countries in which we operate on behalf of the company. Violation of these laws and provisions could result in civil or criminal legal action. Hence any actions and practices that infringe the laws and provisions of the particular country perceived as  being illegal are strictly forbidden.

Trustworthiness

In our day-to-day business, each of us should follow our Code of Ethics the main objective of which is to ensure the trustworthiness of our employees’ actions and behaviour. In cases where the company business is not regulated by law, we should act in an honest and ethical manner. Every employee is personally responsible for implementing that principle at all time. Objectives that are achievable only in dishonest manners, and those that compromise the ethical principles of the company are not to be undertaken, under any circumstances..

Sharing and mutual assistance

When we face a situation in which we do not know the right and ethical way to proceed, we should seek advice and support from our direct supervisor, or from one of the managers.

If you reasonably believe that the actions of your colleague, or business partner violate the ethical principles of the company, you should share these concerns. We take all our employees’ concerns into account and treat them with due care and attention, ensuring confidentiality and discreteness.

Our clients

Our attitude towards our clients is characterized by honesty and trustworthiness and is a fundamental requirement towards all company employees. We always conform to the terms and conditions of the entered contracts, and provide high quality and safe products, while adhering to all rules and standards as laid down at national and international level.

Our suppliers

Because of the nature of our business, our suppliers play an essential role in ensuring client satisfaction. Hence we maintain ethical relations with each and every one of our suppliers, ensuring fair and equal treatment at all times.

In order to provide our clients with the quality they expect, when choosing a supplier we must take into account, not only the price and quality in their central role as the main criteria, but also delivery flexibility and performance timeliness.

Our competitors

When competing with the competition for being awarded a particular procurement, we must treat our competitors with the honesty, trustworthiness and ethics which we implement when operating with our clients and suppliers. Our collective and individual responsibility is to avoid all kinds of unethical or corrupt practices. Additionally, each and every company employee should conform to the antitrust and anticorruption laws of the country, and the countries in which we operate.

Other business partners

Hiring third parties in order to commit an unethical, or illegal act will be treated as a violation of the company’s Code of Ethics and the anticorruption laws, and it is absolutely forbidden. The selection of business partners are to be guided by strict internal procedures.

Hospitality and gifts

Each decision made by us, our clients, suppliers, or any other partners of ours will be based on certain criteria, such as competitiveness, performance, quality of the products being offered and the services being rendered etc. All kinds of professional kindness, such as gifts and hospitality, should be within the framework of ordinary courtesy and should not impact on the decision-making process in any manner.

The giving or receiving of gifts, as we hold, or believe to be in the sphere of excessive/bribing hospitality, with a view to corruption purposes, will not be tolerated. In these situations we should abide to the principles of reasonable behaviour, common sense and caution. Our obligation is to adhere to the company’s internal procedures, as well as to the laws and provisions of the particular country.

Money laundering

Falsifying the origin of money that results from criminal operations is unacceptable, illegal and unethical. We undertake to work only with reputable partners, that we have checked in advance and report on any alleged illegal business, on behalf of the companies with which we work.

Unofficial payments

The unofficial payments, irrespective of their size, to state officials in order to accelerate the routine administrative processes, or to have permits issued, are forbidden- irrespective of the government policy on the issue.

Conflict of interest

Situations in which employees’ obligations to the company may conflict with their personal relations should be avoided. All kinds of relations, or activities that could impact on the performance of our obligations towards the company should be reported at once.

Sponsorship

Sponsorship, being part of company’s marketing and communication strategy, is allowed in conformity with the enforceable laws and provisions. All sponsorship decisions should be approved in advance and be clearly documented.

Export control

We conform to all enforceable laws regarding the import and export of products, services and information. Our employees should know the company policies and procedures related to processing commodities, technologies and data that could be imported into, or exported outside of the country.

Health and safety

Our employees’ health and safety are essential to us. Hence we strive for ensuring favourable and safe working conditions. Thanks to various programmes, training sessions and internal control, we promote the implementation of occupational health and safety practices and procedures.

Security

We do everything possible so that our employees feel protected wherever they are. Additionally, we inform them of the occupational risks and internal procedures to be conformed to.

Colleague relations

Our responsibility is to treat our colleagues respectfully and to create an environment in which employees feel comfortable and free to express their opinions in a professional and constructive manner. We do not tolerate any form of coercion, discrimination, humiliation, harassment – sexual, physical or psychological – or other offensive behaviour.

Equal opportunities and versatility at the workplace

We are striving for the building of a versatile work team that will reflect the markets and communities in which we operate. The process of personnel recruitment is based without exception, on the experience, qualification and skills of the applicant and the remunerations will be defined mainly on the contribution as made by the particular employee to the company.

Career development

We promote the personal development of our employees. The regular meetings, held tete-a-tete between the employees and managers of our company, allow us to focus on the individual needs and ambitions of the employees and to establish a particular plan for the development of the necessary skills and knowledge of the individual employee.

Data protection

Access to employee personal data is limited to those whose function and responsibilities require the processing of such personal data. The company does not provide third parties with access to personal information, with the exception of our requirement under enforceable laws and provisions.

Asset protection

It is forbidden to use company assets for illegal objectives or for objectives not related to the company business. The adaptation of company assets for personal use is also not allowed.

When working with confidential information, which we were provided with by clients, suppliers or other partners, we should process that information with the same due care and security with which we treat the company information. Disclosure of such to unauthorised persons is absolutely forbidden.

Protection of intellectual property

Intellectual property rights include patents, know-how, trade secrets, trademarks, domain names, industrial design and copyrights. We are obliged not only to protect our intellectual property, but also to respect the intellectual property of third parties and not to violate their rights.

Maintenance of precise documentation

We ensure the precision and accuracy of the information contained in our business documents and require our employees to follow the internal control procedures and maintain all financial records. We are expected to maintain company documents in conformity with the statutory requirements and our own internal procedures. The creation of false, misleading or unregistered records is unlawful and unethical.

Communication and media relations

Material for distribution in the media should be approved in advance by the company managers. Without advance approval by the company, employees are not authorized to represent the company through expressing opinions, or issuing information on behalf of the company to the media.

Environment

We promote environmental protection and ecological effectiveness in each and every activity of ours, and we strive for the reduction of the company’s global ecological footprint in conformity with all enforceable laws and provisions. In addition to the collective responsibility, we give our employees incentives to be individually engaged with environmental protection.

Donations

Donations for public causes or private organizations on behalf of the company should be decided in conformity with the enforceable laws and provisions. Donations on behalf of the company should be approved in advance by the company managers.

Political actions and conflicts

Company contributions in politics are frequently subject to national laws and they vary in the different countries. Company participation in political parties and organizations, or the support for individual politicians is not tolerated at company level. Nevertheless, we respect our employees’ rights to be politically active at an individual level, in their leisure time and with their personal funding in conformity with the enforceable laws. In these situations, we require the separation of our employees’ personal political activities and their responsibilities towards the company, thus avoiding any potential conflict of interest.

Our employees

Our employees should know and conform to the company’s Code of Ethics. They are expected to perform their obligations honestly while following our ethical principles

Our managers

Our managers have additional responsibilities that exceed the conformity with the Code of Ethics. They are expected to be exemplary for the other employees, they should demonstrate conformity with the Code at all times and promote and communicate the ethical standards of the company. The managers should be prepared to resolve any issues related to the Code, and to provide their employees with the assurance and support they need when looking for assistance and cooperation in relation to issues or doubts.

Awareness of the Code of Ethics

The Code of Ethics is being circulated among all employees so that they can access it at any time. It is also be shared via various channels such as: business ethics programme, general training, modules focused on the main ethical principles and on company’s website.

Consequences in the case of violations

Every employee is responsible for his or her behaviour and that of the others, so such behaviour must at all times be in conformity with the principles as laid down in the Code of Ethics. Every violation or nonconformity with the Code could bring about severe and long-lasting consequences for the goodwill, business relations and ultimately the financial condition of the company.