CODE OF CONDUCT
1 | Page
CONTENTS
INTRODUCTION 3
HUMAN RIGHTS 5
EQUALITY 6
BUSINESS RELATIONS AND FAIR COMPETITION 7
WORKING CONDITIONS 9
CONFLICT OF INTEREST 11
RESPONSIBILITY FOR THE ENVIRONMENT 13
DATA SECURITY 14
2 | Page
ELEMENT GROUP’S CODE OF CONDUCT
Dear Element Colleague and Partner,
Element Group is a versatile, service-based company and produces spare
and wear parts for crushing, screening and pumping equipment, in addition
to conveyor components, wear-resistant materials and mill linings. Element
Group provides a full range of technical and service support. Element
Group’s values form the foundation for our actions and the values strongly
support our Code of Conduct.
OUR VALUES
Reliability Availability Cooperation Responsibility
Stability Competence Efficiency Leadership
3 | Page
Element Group’s course of action is determined by recording these
business principles, i.e. Element Group’s Code of Conduct. These principles
are the same for every employee of Element Group regardless of
employment status. All employees, without exception, should be familiar
with the Code of Conduct and adhere to the principles and procedures
outlined in it.
We also expect our business partners to operate in accordance with these
principles.
The Company complies with legislation and follows generally accepted
standards of business ethics. The Company does not accept any ways of
doing business that would contradict these rules.
The Code of Conduct should be viewed as a document containing the
minimum set of standards and requirements accepted by the Company
with the aim of promoting fair and ethical business conduct, preventing
abuse and for comfortable daily work with colleagues.
4 | Page
HUMAN RIGHTS
We respect and comply with internationally recognized human rights.
Human rights are applied to all employees, suppliers, agents, consultants
and other business partners. Element Group does not use child labor. All
forms of harassment and ill-treatment are prohibited.
We support our employees’ right to join labor unions and collective
bargaining and encourage open and active dialogue with our employees.
We do not tolerate any conduct by any employee, customer, partner or any
person associated with our business activities that harasses, threatens,
disrupts or interferes with another person’s work performance or creates
an intimidating, offensive, abusive, or hostile work environment.
5 | Page
EQUALITY
We select and appoint employees based on their personal qualifications
and skills for the job. We adhere to the principle of pay and employment
equality regardless of gender, age, ethnic or national origin, religion, political
opinion or social status.
We appreciate diversity in our employees’ background, talent, insight,
education and experience, and believe this contributes to our success and
sustainability by enhancing innovativeness, flexibility and the ability to
communicate with our stakeholders.
6 | Page
BUSINESS RELATIONS
AND FAIR COMPETITION
7 | Page
BUSINESS RELATIONS AND
FAIR COMPETITION
We want to be an honest and reliable partner, which cooperates only with
reliable suppliers and partners. We will make all essential agreements in
written form.
We compete honestly in accordance with existing competition laws in all
its market areas. We do not restrict competition by agreeing with
competitors on prices, allocate customers or market areas. The
information about the competitors is gathered only from publicly available
sources in accordance with the law.
8 | Page
WORKING CONDITIONS
9 | Page
WORKING CONDITIONS
We strive to provide safe and comfortable working conditions for
its employees.
Safety is based on a risk assessment, risk management and reliable
communication. Safety includes looking after our own operations and
ensuring that our partners comply with the law and meet our and our
customers' health and safety requirements. We also adhere to international
labor, quality and human rights agreements.
Our goal is to have a good working environment and respect for the
individual. We monitor changes in legislation and we always act in the
applicable laws, collective agreements and collectively agreed working
regulations accordingly. Everyone in the company is also responsible for
his own health and occupational safety.
10 | Page
CONFLICT OF INTEREST
Conflict of interest arises when an employee has any personal
relationships, financial or other interests that could prevent him from acting
in the interests of the company, without prejudice and effectively
performing his work, and also lead to additional financial losses for the
Company. All employees should avoid actions or relationships that conflict
or may conflict with the
interests of the Company.
We expect that each employee
performs their duties in good
faith and does not allow the
receipt of personal benefits
from the position held. The
company, its employees and
representatives shall not
receive, solicit or give any kind
of bribe and we have no
tolerance towards any forms of
corruption. It is permissible to
give and accept symbolic gifts
in the Company, typical for
normal business practices and
that would comply with the
requirements of local
legislation. It is unacceptable to
use gifts (as well as other types
of hospitality) to any person in
11 | Page
order to obtain commercial benefits and promote business.
Gifts and entertainment should not affect the ability of an employee to
make unbiased and fair business decisions in any way. Gifts in monetary
form, as well as their equivalent (gift cards, vouchers, certificates) are
prohibited. Small gifts may be received, when the gift does not exceed
normal standards of hospitality and if the acceptance of the gift does not
affect the decision-making process. It is also allowed to participate in the
event organized by the partner, if participation does not affect the decision-
making process.
12 | Page
RESPONSIBILITY FOR THE ENVIRONMENT
We strive to actively recognize our customers’ needs and increase
production efficiency and safety, widening the raw material base,
enhancing the quality and sustainability of end-products, and developing
totally new innovations.
We actively seek to reduce the environmental impact of our operations. We
obey laws, regulations and administrative provisions regarding the
protection of the environment. We inform our customers and other
stakeholders about the environmental issues and develop our
environmental management system by doing internal and external
evaluations. We also expect our partner’s commitment to our
environmental requirements.
13 | Page
DATA SECURITY
We are aware of privacy regulations and collect and process personal data
only for relevant business purposes. We make sure that the information in
our possession is protected and its integrity is guaranteed. We process
information carefully as required by legislation and take care of the
protection of privacy when processing personal data.
14 | Page
