Ethical Code

About integer jobs

It is INTEGER policy to maintain the highest standard of ethics in the conduct of its business and in the relationship with any collaborator with whom it connects or associates – its directors, shareholders, customers, associates or suppliers, as well as with public authorities, public opinion and the press. The integrity and reputation of the company regarding the ethics of its activity represent almost the most important advantages of ours and essential elements for our continuous purpose for conducting a profitable activity. Such integrity and reputation ultimately depend on the actions of our employees, directors, representatives, agents and consultants. Therefore, each employee is individually responsible for complying with the Code of Ethics. Its provisions are mandatory and are expected to be respected by its employees, as a mandatory condition of the employment relationship. INTEGER aims to increase its value in relation to its customers, employees and shareholders by obtaining profitability, by offering competitive products and services in the profile market. INTEGER will achieve this goal by maintaining a high level of professional ethics and by respecting its responsibilities.

    1. OUR MISSION
1.1.It concerns us all

The INTEGER Code of Ethics seeks to promote integrity and transparency in our activity and in relationships with colleagues, directors, shareholders and business partners, including customers, associations and suppliers, as well as with central and local public administration and the media. We develop through the integrity and transparency of our relationships; the reputation of our ethical practices is one of the most valuable assets we have, having a crucial importance in our ability to succeed. The Code of Ethics applies to all employees and members of INTEGER management. One of the mandatory conditions for hiring INTEGER or being a member of the company management is to understand and abide by this Code. We must avoid situations in which we could violate this Code of Ethics or the applicable legal provisions. Persons found guilty of such violations may be subject to additional sanctions, including dismissal and / or removal from company management. In addition, INTEGER reserves the right to take further measures, including by law, against the persons involved and / or who have benefited from the illegal activities and / or have violated the provisions of this Code, in order to recover any damages brought by INTEGER and any amounts or benefits paid or received incorrectly. As far as possible, our company, through its employees, will do the due diligence so that the provisions of the Code of Ethics or its equivalent provisions are made known and accepted by our subcontractors, partners, agents, consultants and contractors (named in hereinafter “Business Partners”), as the case may be. Our business partners must be nominated in a manner efficient and transparent, in accordance with market practices. As far as possible, our staff will perform the necessary diligence so that our business partners acting on behalf of INTEGER always comply with the provisions of the Code of Ethics, the laws and regulations in force to ensure the highest standards are respected. In case of violation of the provisions of the Code of Ethics or the values ​​they promote, INTEGER will take the necessary remedial measures, including by terminating or not extending the contract, as the case may be. The Code of Ethics can be updated or amended to reflect legislative and policy changes, as well as those of good practice. Any such changes or updated versions will be notified to the recipients of this Code as soon as possible.

1.2.BUILDING AND KEEPING OUR INTEGRITY

We built INTEGER based on our quality of work and our reputation. Our actions, individual and collective, can have a direct impact on our reputation. Therefore, we must always abide by the legislation in force and avoid behavior that may adversely affect our reputation and the way we are perceived by customers, the public or third parties. We must all try to maintain and promote an excellent reputation in all businesses, no matter where they are conducted.

1.3. .MUTUAL RESPECT AND INTEGRITY AT WORK

We all have the right to respect for dignity, confidentiality and personal rights. In our daily activity we interact with people of different ethnicities, cultures, religions, political beliefs, ages, disabilities, races, sexual identities and sexes. From the beginning, I recognized the need to form a multicultural workforce. Being consistent with these values, we prohibit discriminatory actions and behavior, harassment and violence.

Discrimination there are places where a person or group of persons are treated differently because of their personal traits, beliefs, beliefs or for any other reason prohibited by law, which include but not limited to: race, color, nationality or ethnicity, place of origin, religion , age, sex, sexual orientation and mental disabilities.

Hărţuirea — whether it is racial, sexual, psychological or any other – it exists if the behavior towards another person is:

      • shocking or offensive;
      • it is presented in one of the following forms:

repeated and hostile or unwanted behavior, verbal comments, actions or gestures; or

a single serious accident with lasting effects on the person

      • affects the dignity or psychological or physical comfort of the person concerned, or
      • results in the creation of a hostile work environment.
Violenţa at the workplace may include:
      • the use of physical force that causes or can cause bodily injury; and / or
      • actions, behavior or statements that can reasonably be perceived as a threat to the safety or security of a person in an INTEGER workplace.
      • Physical assaults, threats of violence and other incidents related to violence that occur in a workplace within INTEGER can be reported to the competent authorities.

1.4. WHAT EXPECTATIONS WE HAVE FROM OUR DIRECTORS OF DEPARTMENTS

In accordance with the provisions of this Code, our department heads have additional responsibilities. Managers are responsible for promoting a culture, respect and integrity, including a positive work environment in which people are treated with dignity and respect.

How we do this:
      • Leading by example. We always rise to the standards of the Code of Ethics;
      • Helping those in our subordination to understand and follow the standards of the Code of Ethics and underlining the importance of participating in the respective training and certification sessions;
      • Supporting people who, in good faith, ask questions or report a suspicious problem, even if by doing so we should get out of the chain of command;
      • We must not take or allow repressive action against any person who, in good faith, reports certain problems;
      • We must take action if we are made aware or suspect that there has been potential abuse in the service and we must never pretend that we do not see what is happening to ignore the abuse.
    1. TRANSPARENCY IN ALL OUR BUSINESS

While our competitiveness is manifest in all our markets, all our business activities must be carried out in accordance with the laws and regulations in force. Illegal behavior is strictly forbidden. If we are not sure about how the laws or regulations should be interpreted, we should consult with the company’s legal consultants.

2.1. ANTI-TRUST LEGISLATION / COMPETITION LAW / COLUSION

At INTEGER, we must all use competitive commercial practices that comply with the antitrust and anti-competitive laws in force. Collusion is defined as a secret agreement between two or more parties to promote fraudulent, illegal or dishonest behavior. For example, we cannot engage in discussions and we cannot conclude agreements with our competitors that would:

      • fix or control prices, terms and conditions;
      • limit competition and relationships with suppliers;
      • limit the export or import of services provided by INTEGER;
      • divide or distribute customers, markets, territories or services between INTEGER and our competitors; or
      • it would result in sending a false offer to a tender.

We must not attempt to obtain information about competitors, illegally, through industrial espionage, corruption, theft or electronic interception systems. At the same time, we do not have to communicate information, which is known to be false, regarding a competitor.

2.2.THE FIGHT AGAINST MYTH AND CORRUPTION 2.2.1.Offers, promises and limits

We distinguish ourselves from competitors both by the quality of the work and the services offered, as well as by our reputation.

We must not offer, promise, grant or authorize, directly or indirectly, the receipt of any kind of value – money, gifts, banquets, hires, contracts or benefits of any kind – to customers, suppliers or third parties (eg Partners (Business) to influence certain official actions or to gain unfairly benefits.

Corruption is generally defined as the abuse of a party mandated to obtain personal profits. We also specify that in the regulation of the applicable law, the corrupt person can be both a public official and an employee of a private legal person, or even an authorized person who provides the services.

We must also ensure that we do not offer, promise or give valuable items to customers, suppliers and third parties (for example, business partners) that may be perceived as bribes. At the same time, we must never offer or accept attention, for the amount already paid (or to be paid) as a reward for making or promoting business agreements. We cannot prevent a third party from engaging in an activity that we cannot participate in ourselves, because this is forbidden.

When negotiating with public authorities, we must pay special attention to the laws and regulations that concern the provision of gifts and the hospitality offered to civil servants. As a rule, these practices are forbidden. As an exception, only gifts that can generally be considered as having a small, symbolic value can be offered or received.

The “civil servant” may be an official, employee or any person who represents or acts:

      • at any government level (state, county, municipal or other)
      • in entities wholly or partially owned by the state or providing public services to the population;
      • in international public organizations;
      • in political parties, party officials and candidates for elections; or
      • a person who holds an administrative, legal, religious or military position.

In addition, we must be reluctant to indirectly provide valuable goods to a third party if we have reason to believe that they may be forwarded to a public official or a private business partner for the purpose of unfairly obtaining benefits.

2.2.2. SPONSORING AND ACTS OF MECHANISM

Sponsorship and patronage acts are allowed provided they are performed in accordance with the law and the purpose of our company.

Sponsorships are an important part of INTEGER’s social responsibilities in communicating with clients and the communities in which they operate. These represent an opportunity to strengthen the INTEGER brand in the selected target groups. However, sponsorships should not be given as a means of seeking or gaining undue benefits.

We must inform and inform our top hierarchical boss whenever we have reason to believe that sponsorships represent the risk of being perceived as incorrect.

2.2.3. Accepting and receiving gifts and other valuable goods

Although we do not encourage this, it is not strictly forbidden to offer or accept occasional gifts whose value is small or purely symbolic or recreational gifts of reasonable value, in accordance with local customs and practices, as well as the provisions of this Code. Any other gifts or valuables should immediately be refused, and if the employee has reasonable grounds to believe that such behavior is inappropriate, let his / her boss know this. It is important that all gifts offered to third parties comply with the provisions mentioned in this Code and are fully and correctly recorded in the INTEGER registers.

Gifts, tables and recreational events should not be offered or accepted if:

      • you may violate a law, regulation or rule or the standards of our organization or our business partners;
      • the other party is currently involved in an active bidding or negotiation process with our company;
      • are part of an agreement to do or receive something in return;
      • can influence the standards of our organization or our business partners;
      • are payments in cash or cash equivalents, such as gift vouchers, coupons, vouchers, loans, shares or stock options, etc;
      • have sexual, offensive, bad taste or otherwise violate our commitment to mutual respect;
      • can be considered as bribe or reward;
      • they may reasonably be construed as a reward for preferential treatment, current or prospective, or create obligations for the other party;
      • they are exaggerated or extravagant;
      • they are common.

2.2.3 . POLITICAL CONTRIBUTIONS

Contributions made to political parties or candidates to elections by the corporation or on behalf or on behalf of INTEGER are prohibited by this Code. If permitted by law, individuals may, at their discretion, make personal donations to the respective political parties. We must not solicit or force other persons to make political donations at program hours or INTEGER locations.

    1. AVOIDING CONFLICTS OF INTEREST

Throughout the relationship with INTEGER, we must ensure that we act in the interest of INTEGER. Relationships, activities and personal interests can escalate into conflicts of interests, current or perceived. We must all be able to identify situations in which we might be in a position of conflict of interest, current or presumptive.

Below are some examples of conflicts of interest, current or presumptive:

      • Accepting a third-party administrator position without disclosing and obtaining the consent of the direct supervisor and the human resources department; & lt; & gt; br • Entering a business relationship or having a significant financial interest in a competitor’s company, a business partner, supplier or customer of INTEGER;
      • Collaborate with a family member or a person with whom you are personally involved. You must immediately report any activity or relationship that may constitute a current or presumptive conflict of interest to the direct supervisor and the human resources department. INTEGER will take the necessary measures to ensure that these issues are promptly resolved.

3.1 Activities that are not related to INTEGER

If you are an employee or a director of INTEGER, you are expected to make every effort to develop INTEGER. We must not work or provide services for a competitor or be involved in activities that compete with the activities carried out by INTEGER.

3.1.1.The labor relations and the functions of administrator held in other companies

Employees and members of management must inform INTEGER of any secondary, existing or possible employment relationship with another company or of any administrative position held in a third party organization. The employees and the members of the management cannot initiate or continue such activities without having a written authorization signed by their direct supervisor and a representative of the human resources department. The members of the board of directors must inform the company annually about administrative functions or other important activities not related to INTEGER.

3.1.2. External gainful activities

Below are examples of conflicts of interest, current or perceived:
      • Holding by a person, or a family member, a significant financial interest in an external company, which has or is trying to do business with us or is a competitor of INTEGER;
      • Participation, directly or indirectly through family members, in foreign affairs or financial activities that enter into competition or may compete with INTEGER;
      • Participation, directly or indirectly through the family members, in an external business that provides services or does business with INTEGER and if there is the possibility of offering preferential treatment by virtue of the position you have in INTEGER;
      • Business management on behalf of INTEGER through a family member or a company in which we or a family member is associated, which can be perceived as important from the point of view of presumptive conflict of interest, if these business interests do not have were disclosed to the INTEGER direct supervisor or human resources department prior to the conclusion of any commitment, and you were given a clear approval stating that there are no objections / impediments.

We must immediately report any external business activity to the company’s direct supervisor and human resources department. INTEGER will take the necessary measures to ensure that these issues are promptly resolved.

3.2.Personal relationships at work

It is permitted to employ persons belonging to the same family or employees who have personal relations with another employee, provided that there are no current or presumably future conflicts of interest. If the family or personal relations cause conflicts of current or presumptive interests, we must immediately inform the direct supervisor and the human resources department. The declaration of personal relations at the Human Resources department will be treated with the utmost discretion and confidentiality. We will work together to find a prompt solution to eliminate situations where current or presumably future conflicts of interest arise. Below are some examples that could be conflicts of interest or presumably future:

      • Hiring or promoting family members or a person with whom you have or want to have a personal relationship;
      • Exerting influence on other employees for the benefit or detriment of a family member or a person with whom you have or wish to have a personal relationship;
      • Direct or indirect reporting to a family member or to a person with whom you have or wish to have a personal relationship.
    1. INFORMATION PROTECTION

4.1. Use of sound accounting methods and record keeping

Keeping accurate and safe records is crucial for our company. These are the basis of our financial reports and other materials disclosed to our public, clients, partners and shareholders. Also, this information is the basis of our strategic decisions and planning.

The basis for obtaining accurate and reliable financial reports is the observance of the internal control system, the correct and punctual reflection of transactions, assets and liabilities in our records. Therefore, all our records must be complete, accurate and secure.

Under these conditions, and without limitation, each of us makes the following commitments regarding the company records and registrations, regardless of the purpose for which the information is used:

      • Commercial documents, expense reports, invoices, receipts, payment statements, employee records and other reports are carefully, honestly and timely prepared;
      • All transactions are performed by persons with an adequate level of authority in accordance with the laws, rules, standards and regulations in force;
      • Transactions, assets, liabilities or other financial information should not be hidden from members of the management, legal and financial department of the company;
      • Every effort is made to resolve all problems and misunderstandings arising in internal and external audit reports;
      • All known inaccuracies, errors or omissions are disclosed to customers and suppliers and are promptly corrected by mutually accepted methods;
      • All signed documents are, to the best of our knowledge, accurate and true;
      • False or erroneous registrations and unregistered bank accounts, for any reason, regardless of whether they refer to sales, purchases or other activities of the company, are strictly prohibited;
      • No secret or non-cash funds or other assets are established or kept for other purposes;
      • Unusual financial arrangements made with a customer, partner or supplier (eg over-invoicing or under-invoicing) are prohibited;
      • Access to sensitive or confidential information is limited to ensure that it is not disclosed, altered, misused or accidentally or intentionally destroyed;
      • The use of funds or other assets of the company for illegal or inadequate purposes is strictly forbidden, and the heads of departments, as well as the persons responsible for accounting and record keeping must be vigilant to ensure the application of this prohibition, but considering the correct use of company assets.

4.2. 4.2 Intellectual property

The copyrights, trademarks, projects, inventions, enhancements, discoveries and any other forms of intellectual property (such as protocols, procedures, technical processes, research methods, etc.) created or modified during the relationship with INTEGER remain the exclusive property of the company . In addition, the intellectual property developed outside the relationship with INTEGER belongs to the company if the development is based on confidential information acquired during the relationship with INTEGER. In these cases, you will be required to sign documents proving INTEGER’s ownership.

4.3. External communications

The opinions or information requested by individuals, groups or external organizations should be directed to the appropriate department of the company to receive a response. To anyone who expresses their views on external interests, which are not related to INTEGER business, they are reminded that these comments are strictly personal and should be careful not to engage or compromise INTEGER. The Human Resources Department is the official contact for any member of the media who wants an interview, opinion, comment or suggestion on any topic that may affect INTEGER business. Any request from a media representative, even if it was classified as a comment or a personal opinion, must be submitted to the human resources department. Any participation as a speaker at a conference or any form of media – television, radio, online, social media, print media or other – must be authorized by the direct supervisor and the notification must be sent to the human resources department .. Participation in media events, if not requested or coordinated directly by the human resources department, must be performed as a private person. We must not cite or refer to INTEGER or disclose confidential information to which we have been exposed.

    1. TO KNOW WHAT TO EXPECT

If you have any doubts about the application or interpretation of laws or regulations, you should consult your supervisor or human resources department. Difficulties can generally be avoided or minimized if this is done from the beginning. INTEGER has taken steps to ensure that everyone understands and adheres to the Code of Ethics. We must not forget that the observance of the laws in force and the Code of Ethics are the necessary conditions for obtaining a job at INTEGER or for being a member in the management of the company.

    1. REPORTING AND INVESTIGATION OF INFRINGEMENTS AND COMPLAINTS

In accordance with local law, we all have a duty and responsibility to report in good faith any violation of this Code, including any violation of the laws, rules, regulations or other corporate policies that apply to us, our business group and / or to the company or any other case of improper conduct or use of pressure to compromise the ethical standards of the company. An infringement of this Code may be reported as follows:

      • to the direct supervisor;
      • at the Human Resources department;

It is up to each of us and each of us must watch to ensure that we live according to INTEGER values ​​and the Code of Ethics. Any problems arising or any reports submitted in accordance with this Code will be treated with the utmost confidentiality and the persons reporting them will be protected from any form of retaliation or retaliation. Depending on how the local law is applied, the breach of reporting obligation may result in disciplinary action, including dismissal. INTEGER assumes that all issues and reports submitted under this Code are made in good faith and are real and fair. In the event of such a report or complaint, INTEGER undertakes to investigate the matter within a reasonable period of time. The investigations carried out in accordance with the Code of Ethics will be carried out with the utmost respect, discretion and with the protection of privacy and confidentiality will be kept within the limits allowed by law and according to the need of the company to investigate the matter completely.