Code of Conduct

For the S&T Group

The reputation of our company and the trust of our customers, investors, employees and the public depend on the concrete conduct of every individual who works for the S&T Group. We all want to do the right thing for ourselves and for S&T. This Code of Conduct is a useful guide that defines the way that S&T Group employees should behave towards the company, colleagues, customers, suppliers and the public.

This Code of Conduct represents a summary of binding guidelines for everybody who is employed by S&T (hereafter “employees”). Although the Code of Conduct is primarily intended as an internal policy document, it also provides our business partners with information about the conduct that they can expect from us, as well as that which we expect from them.

Compliance with the Law


Compliance with and observance of the law is obligatory throughout the S&T Group. Each employee is obliged to adhere to both national and international law, and to act in accordance with it. We also require our employees to abide by the law in their personal conduct, to meet their personal responsibilities and to refrain from any activities that may be detrimental to the reputation of S&T.

Our employees


S&T employees are the company’s most important asset and determine the success of the S&T Group. All employees are treated equally, regardless of their nationality, religion, ethnic origin, gender, age or sexual orientation. S&T relies on motivated and competent employees and therefore invests in their continuing education and expertise.

Behavior towards third parties


S&T strives to conduct its relationships with customers, suppliers and other business partners in a partnership-like manner. The S&T Group treats all business partners in a fair, cordial and respectful manner and bases its competition for customers on the quality and benefits of products and services.

We commit ourselves to fair conduct with our competitors and support free and undistorted competition. In this respect, each employee is obliged to observe and abide by the principles of free competition.

Financial and business records


All employees are obliged to ensure that business and financial records are correct, truthful and complete. This applies not only to bookkeeping, but also other records as well as legal requirements to preserve records.

Treatment of S&T property


S&T employees are obliged to treat S&T property and resources carefully. Unless special approval has been obtained, company machines and equipment must only be used for business purposes.

Handling information, data protection


Shares in S&T System Integration & Technology Distribution AG are officially listed on the Vienna Stock Exchange. The efficiency of the financial market is to a large degree based on the confidence of market participants, particularly with respect to the accessibility of public information and the non-disclosure of confidential information. S&T is therefore obliged to maintain a particularly high level of caution regarding the handling of non-public information, to ensure that all market participants enjoy equal chances and conditions.
S&T Group employees are obliged to handle non-public information confidentially and ensure that it is not accessible to third parties. Third parties include family members, friends and acquaintances. Within S&T, information will only be shared with those employees who require it to fulfill their professional role.

Personal information may only be collected, processed or otherwise used in cases where this is required for scheduled and lawful purposes. The observance of measures to ensure the security of information is considered particularly important. Any use of personal information must be transparent to the person concerned and their right to be informed, to correct and, if necessary, to contradict, ban or erase such information must be protected.
With regard to the handling of insider information, legal requirements and compliance regulations must be adhered to. In addition, the communication guidelines define the flow of information between S&T and its external and internal target groups.

Conflicts of interest


All employees are obliged to conduct themselves in such a way that conflicts of interest that may be detrimental to S&T are avoided. All employees must therefore maintain a clear distinction between the interests of S&T and their own personal interests.

Offering and providing personal benefits


Corruption damages not only the company, but also the reputation of its work force. Corruption is not a minor offence. It is an illegal activity. Corruption can sometimes begin with small favors.

S&T employees are obliged to refrain from all forms of corrupt conduct. This applies in particular to attempts to influence decision makers at business partners or in the public sector through promising or awarding unpermitted advantages or favors. S&T employees are also forbidden from demanding or accepting such advantages while conducting business with third parties.

Gifts between business partners are, within reason, an established part of business practice. Gifts are to be understood as physical items as well as various benefits or advantages such as the promise of a discount, invitations, and offers to give paid presentations etc. It makes no difference whether these perks are offered directly to a business partner or to their family members or acquaintances. The standard scope of such gifts is exceeded when – objectively observed – they may compromise the ability to make an objective decision. All forms of gratuity that may compromise the objective decision-making capability of the recipient or damage the reputation of the company are not allowed. Gifts that fall within standard business practices and are given or received as a sign of courtesy in observance of applicable laws are permitted.
The acceptance of occasional gifts of minor value by S&T employees in accordance with the above conditions is permitted. However, gifts that exceed the rules are to be politely declined with reference to the Code of Conduct.

Donations


S&T provides money and other donations for education, science, art, culture and social causes. The allocation of donations must be transparent. This requires the motivation for donations to be recorded in the form of recipient and purpose of the donation.

Ethical code


In April 2014, S&T Bulgaria successfully passed the social SMETA-Audit (Sedex Members Ethical Trade Audits). SEDEX is the largest collaborative platform for sharing ethical supply chain data. It is an innovative and effective solution for managing the supply chain processes, which helps business organizations to reduce risk, protect their reputation and improve their working practices.

Implementation & help


The implementation of the Code of Conduct is the responsibility of managers in cooperation with their team members. Group HR and Internal Audit are available at all times to help clarify questions.

Reporting violations of the Code of Conduct

Employees are obliged to report violations immediately.

This can be done anonymously by writing to the following e-mail address:
conduct@snt-world.com

The Group HR Director and Head of Internal Audit both receive such reports. While protecting the anonymity of the reporting person, discreet contact will usually be required to aid analysis of the accusation.

Violations of the Code of Conduct can lead to official consequences such as dismissal, and to claims for damages from S&T against the employee concerned.