eltek group code of ethics code of...code of ethics eltek group – revision 2 - issued 2017 –...

Code of Ethics ELTEK Group – Revision 2 - Issued 2017 – of 21

ELTEK GROUP CODE OF ETHICS


This Code of Ethics has been developed to define, in a clear and

transparent way, the values inspiring the ELTEK Group and the

rules of conduct to be derived therefrom.

Compliance with these standards is required to all employees of

the Group, as well as to those who, in any other capacity,

collaborate in the business activities.

The Directions of all Group divisions and plants are responsible

for divulgation and implementation of this Code through

widespread distribution, promotion and factual example, daily.

INTRODUCTION


WHAT IS A CODE OF ETHICS?

It is a document that summarizes and explains the reference

values of the ELTEK Group and behaviours to ensure compliance

with the said values.

WHO IS IT FOR?

All ELTEK employees, regardless of their level and their plant.

The Code of Ethics also applies to third parties who, for various

contract reasons (such as project workers, agents, etc.), act in the

name and on behalf of ELTEK.

WHY?

To illustrate clearly the patterns of behaviour to which we must

adhere, and provide information about entities to which we can

turn to report any situations and inappropriate behaviours.

INTRODUCTION


As part of its activities, the ELTEK Group refers to the following

essential values:

Legality:

We adhere unconditionally to the principle of legality.

All ELTEK plants act within the laws, regulations and rules of the

countries where they operate.

Business ethics

We pledge to work with honesty, integrity and fairness, and we

expect the same approach by our counterparts. We do not allow

any actions which, although in the interests of the Group, may

involve a violation of the regulations in force or this Code.

Orientation to the future

To be future-oriented, for us means:

acting in the interests of the Group, to ensure its

profitability and therefore continuity over time;

acting in the interests of civil society, and especially of

future generations, by preserving non-renewable resources and

the environment in which we operate and where our products are

used.

Human rights

We respect, we affirm the universality and we promote the

compliance with internationally recognized human rights.

Child labour

We respect children's rights and we condemn child labour.

Freedom of choice of work

We reject all forms of forced labour; the work is a right and a free

choice.

Non-discrimination

We condemn all forms of discrimination against employees and

third parties, based on gender, race, nationality, disability, sexual

orientation. We respect all political and religious beliefs, provided

that they are based on democratic principles and guided by

tolerance.

THE VALUES OF THE ELTEK GROUP


Freedom of association

We recognize the fundamental right of association and pledge to

work constructively with labour unions. No employee may be

discriminated or favoured because of his/her labour union

membership.

Working conditions

The wages paid to our employees is at least equal to the standards

of the law or to national or local arrangements which apply.

Working hours and holidays are compliant with applicable

regulations.

The employees can always contact their superiors if they judge to

be treated unfairly or to report any abnormal situations.

A worker may not be discriminated or punished for a complaint

or a report presented, in any way.

Training

We invest resources in training our employees, aware of the

return in terms of their professionalism, competence and

personal satisfaction.

Safety and health in the workplace

We do not accept any compromise on the safety of our workers

and the environment in which they operate.

All ELTEK plants work in compliance, at least, with the laws and

regulations in force and adopt every appropriate measure to

ensure the health of the workplace.

Environment

Every day, we are committed to the protection of the

environment with factual actions that include an eco-conscious

design, the limitation of emissions and waste, and the choice of

manufacturing processes that allow limiting the consumption of

resources, especially non-renewable ones.

All ELTEK plants work in compliance, at least, with the laws and

regulations in force.


Our reference values are translated into standards of conduct

that engage the employees individually and the Group

companies, as a whole.

These rules can be resumed as follows:

Compliance with the regulations in force

The ELTEK Group complies with the laws and regulations in force

in the countries in which it operates. Laws and regulations are to

be intended broadly, including in this context all tax,

environmental, workers' health- and safety-related provisions,

provisions on protection of intellectual property, competition,

etc.

What does this actually mean?

From the operator of the line up to the CEO, everyone who, in

various ways, represents and acts on behalf of ELTEK is required

to comply with this requirement.

When acting on behalf of the Group and, we hope, even in your

private life, you must not be engaged in any act that violates the

regulations, even if you feel that this may be an advantage for

ELTEK.

If you have any doubts about the legality of your actions, contact

your local Legal Department before acting.

RULES OF CONDUCT LE

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Conflicts of Interest

Conflicts of interest arise when the interests and personal

activities influence decisions that should be taken in the interest

of the Group.

To determine a conflict situation is sufficient that others perceive

an influence, it is not necessary that this is effectively exercised.

Any possible conflicts of interest, even potential, must be

reported to superiors or to the Board and implies that the subject

abstains from actions that could damage the company or grant

him/her an unfair advantage.


When acting on behalf of ELTEK, always be professional and

impartial, especially in relations with suppliers and collaborators.

If you believe you are in a situation of conflict of interest, report

it to your supervisor and refrain from activity.

Even if you feel to be impartial, remember that the mere

perception of a conflict can seriously harm the company's

reputation. In this case, refrain from taking any decisions that

could be perceived as unduly favourable to you or to a party close

to you.

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Money laundry

ELTEK employees and collaborators must not engage or be

involved in any activity that may imply money laundering. The

provisions on money laundering, also internationally, must be

scrupulously complied with.

Before establishing a business relationship with third parties,

ELTEK shall review the current information to verify the legitimacy

and integrity of such business relationship.

All financial transactions, including intercompany transactions,

are conducted in order to ensure full traceability of financial flows

and compliance with all legal requirements.


Money laundering means accepting or using money for lawful

activities, originated from criminal actions.

You must not entertain any relationship with those involved, or

suspected of involvement, in illegal activities.

Before starting a business relationship, you must verify any

information available on your counterparty and you must not

establish any relationships with customers, suppliers or thirds,

the activity and origin of property of which is not clear.

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Bribery

The ELTEK Group is committed to ensure that all relationships

with employees and third parties, be they collaborators,

customers, suppliers, public administration, are characterized by

maximum transparency and fairness.

No form of bribery, active or passive, or of collusion aimed at

obtaining or granting favours in your own interest or in the

interest of ELTEK, is admitted.

It is not permitted to offer money or any other benefits to

influence the counterparty.

It is not permitted to receive money or any other benefits from

any supplier, or potential supplier.

An exception is the utility of low value bestowed or received by

guests as a courtesy, as required by company procedures.


Refrain from offering gifts, favours or money in exchange for a

business advantage.

Refrain from accepting gifts, favours or money in exchange for a

favourable treatment by the counterparty.

Refrain from any action that could be interpreted as a form of

improper payment.

Report to the Legal Department each suspicious episode.

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Relationships with Customers

Customer satisfaction is the cornerstone of the ELTEK Group

business.

ELTEK is committed to building courteous, professional,

transparent and cooperative relationships, with the aim of

meeting the demands of customers with diligence and with

impeccable quality levels.


Be committed to maintain the exchange with gentle and

professional tones.

Provide accurate, truthful, complete and timely information.

Be proactive, when possible; do not wait for the Customer to ask.

If the Customer asks you to act contrary to this Code, explain to

him/her that is impossible to do so and the reasons why.

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Relationships with suppliers

Selection and management of suppliers of the Group is entrusted

to the Supply Chain Management and its plant divisions.

The selection is based on objective criteria including skills, quality,

price and integrity.

ELTEK strives to create and maintain professional and

constructive relationships with suppliers.

The Group does not use suppliers suspected of illegal activities or

which fail to ensure fair working conditions for their employees.

In particular, it is unacceptable that ELTEK suppliers:

- Use child labour

- Use forced labour

- Carry out operations that endanger the health of employees

- Fail to ensure working conditions (wages, benefits and rest) in

line with local regulations.


Strive to establish and maintain correct, transparent and

collaborative relationships with suppliers.

In the relationship with the supplier, follow the policies of the

Supply Chain.

Operate in accordance with local regulations and require strict

compliance to such regulations by the supplier.

Ask the supplier to adhere to the values of this Code.

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Donations and Sponsorships

ELTEK Group adheres to requests for donations and sponsorships

for social and sports activities, provided that they come from non-

profit associations, duly constituted and authorized.


Every year ELTEK allocates some funds to sponsor social activities.

If you wish, you can submit your sponsorship proposal to the

Group's Financial Department and they will decide on the

authorization and the allocation of available funds.

In the absence of requests or preferences expressed by

employees, the same Finance Department shall define the

destination of the funds.

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Accuracy and confidentiality of information

In providing information on the Group, ELTEK agrees that such

information is accurate, truthful and consistent.

Employees are expressly obliged not to disclose information

about ELTEK or information acquired by company without

permission, and never to use or disclose it for purposes unrelated

to work.

The ELTEK Group also ensures that the information in its

possession are collected, handled and protected as provided by

law.

Any research concerning the tastes, preferences or otherwise the

privacy of employees is prohibited.


Respect the individual right to privacy, protecting carefully, and

according to instructions, personal data that have to be treated

at work.

Do not collect, treat or store any personal information not

relevant.

Do not disclose personal information, unless previously

authorized by your superior and only if this is absolutely necessary

for the work.

If you need to provide information on ELTEK, make sure that this

information is accurate, truthful and consistent. Check also that

authorization to proceed, if necessary, has been obtained.

Do not disclose any information to the press, to competitors or

suppliers, or to external organizations, unless expressly

authorized by your superior or by the central management.

Do not disclose any confidential information, unless specifically

authorized by your superior or by the central management.

Always remember that you may not use or disclose information

acquired by the company for purposes unrelated to work.

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Protection of Intellectual and Industrial Property

The ELTEK Group acts in full compliance with intellectual property

rights held by third parties.

Employees and collaborators must refrain from deliberate

violation of these rights.

Equal attention has to be paid to the protection of the company's

know-how. Employees and collaborators must follow carefully

the instructions and refrain from disclosure or misuse of patented

corporate assets.


Submit timely design innovations to the analysis of the

"Intellectual Property" department. In this way, you protect the

most important asset of the company, its know-how.

Contact "Intellectual Property" department whenever you are

afraid of being in the position of violating others' intellectual

property or you need any clarification.

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Personnel selection

Personnel is selected according to the principles of equality and

non-discrimination.

Candidates are evaluated according to how closely their

characteristics and skills correspond to business needs.

Candidates can't be asked for personal information or

information not relevant to the assessment needs.

The recruitment officers must avoid any favouritism or conflict of

interest. Any pre-existing personal or working relationship with

the candidates must be declared, so that the recruitment officer

is excluded from the selection process.

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Establishment and management of the employment

relationship

ELTEK employees are hired with regular employment

agreements.

No form of irregular employment is allowed.

New employees receive a detailed description of the job to be

done and related responsibilities, the detail of their remuneration

and the necessary training on aspects of safety and environment.

Later in the relationship, the company is committed to providing

equal opportunity in career advancement and to managing

promotions and prizes exclusively on the basis of merit and

matching of skills of the employee with the specifications

required by the business role.

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Harassment in the workplace

Working in a serene environment, in which interpersonal

relationships are characterized by fairness, mutual respect for

freedom and human dignity, is a fundamental right of all female

and male workers.

ELTEK is committed to remove all obstacles to the

implementation of these rights, in order to ensure a work

environment in which women and men respect the inviolability of

the person.

Harassment may include:

creating an intimidating or hostile work environment or isolating

individuals or groups of employees;

unjustified interference in the work performance of others;

any action or unwanted behaviour - physical, verbal, non-verbal -

of a sexual nature or based on sex that offends the freedom,

dignity and inviolability of the person to whom it is addressed.

The witness of harassing or discriminatory actions must assume

an attitude of solidarity with the victim, notify the ELTEK HR

Department and testify, if necessary.

The victim of harassment within an ELTEK Group plant can report

the incident to HR Department and has the right to obtain the

termination of any unwanted behaviour.

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Protection of safety and health at work

ELTEK Group promotes the dissemination of a strong safety

culture among its employees, through knowledge of the risks,

proper behaviour and applicable regulations.

All Group companies operate in full compliance with current

regulations, with particular emphasis on preventive measures.

The same diligence is required of the contractors and, in general,

to any third parties acting at the ELTEK facilities.

Improving safety and working conditions is constantly pursued

through critical analysis and upgrading of business processes.


You are entitled to receive comprehensive training regarding

safety. Training must be appropriate to your function in the

company and the risks to which you may be exposed.

Adopt responsible behaviour, in line with the information

received; any misguided actions can represent a risk to yourselves

and to others.

For any doubt, contact the Safety Manager or workers' safety

representative (for plants in which this figure exists)

If you have a doubt about the risk of an action, stop immediately

and call the Safety Manager before.

If you see any inappropriate behaviour and potentially risk, do not

hesitate to report them to the Safety Manager.

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Our environmental policy

For years, we have been committed to protecting the

environment, by trying to combine economic interests and social

and environmental considerations.

Starting from the minimum requirement of compliance with

government regulations, all plants of the ELTEK Group are

reaching the goal of ISO 14001 environmental certification.

These are the areas in which we commit ourselves concretely:

In the design phase, with the ECO project, we try to

develop products with a minimized environmental

impact throughout their entire life cycle.

In the engineering phase, we favour processes to reduce

consumption, especially of non-renewable resources,

and pollution.

In production, we train our employees so that they are

aware of the impact of their individual behaviour on the

environment.

We give them information and tools for reducing this

impact.

We inform them promptly of the results.

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Comments, suggestions or notices about this document can be

directed to your manager, the HR department or the offices

indicated from time to time in the Code.

All ELTEK employees and collaborators have a right and duty to

report situations that appear in conflict or dubious with

references to the rules of conduct contained herein, i.e. frauds,

dangers, risks that could damage Customers, Colleagues,

Shareholders and the company reputation.

Reports can also be emailed anonymously to

[email protected]

ELTEK will not allow any punitive or intimidating behaviour

towards employees who have submitted a report.

HOW TO COMMUNICATE WITH THE COMPANY

mailto:[email protected]


Compliance with the provisions of the Code of Ethics is an

essential part of the contractual obligations of employees,

pursuant to and for the purposes of the applicable regulations.

Violations of the Code of Ethics may constitute a breach of the

primary obligations of the employment relationship or a

disciplinary offense, with the consequences of the law.

To third parties with whom ELTEK has contractual relations, the

adoption of behaviour that violates this Code may constitute a

breach of agreement, with all legal consequences.

COMPLIANCE WITH THE PROVISIONS OF THE CODE

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