CODE OF CONDUCT

1.  INITIAL CONSIDERATIONS

The company’s operations in the domestic and international markets and different business units, geographic regions and cultural environments, require transparent standards and compliance with different laws.

LARKALIS and its subsidiaries values its reputation and credibility, and the ethical principles that guide its operations help it preserve its image as a solid and trustworthy company among its Suppliers, Clients, Shareholders, Members, Collaborators and society in general.

LARKALIS understands that it must share its values and principles and orient its Suppliers about the main guidelines that govern its relationships in order to ensure that it meets the requirements related to good corporate governance, ethics and transparency.

2.   GUIDELINES

All LARKALIS Suppliers and relevant Partners must conduct their business based on the guidelines of this Code.

This Code of Conduct is designed to clearly transmit the values and behaviours expected of each one of the Larkalis’ Partner Suppliers.

2.1 BUSINESS INTEGRITY

When performing their activities, Suppliers must adopt an honest and dignified conduct, strictly comply with all applicable laws, and show respect for human rights, the environment and society’s ethical standards.

During their business actions, Suppliers must comply with all laws and regulations applicable to each Country or region in which they operate, observing the highest standards of honesty and integrity and working to prevent situations that may seem suspicious.

Such responsibility also involves adopting appropriate measures when the Suppliers become aware of irregularities practiced by third parties that may compromise Larkalis reputation or interests.

Suppliers should also take precautionary measures when selecting commercial partners, complying with the guidelines found in this Code as well as all relevant law applicable to their activities, primarily the ones related to anticorruption, such as the Austrian Anti-Corruption Law, Foreign Account Tax Compliance Act (FATCA), European Anti-Corruption Conventions and all similar legal instruments in the countries where LARKALIS operates. Suppliers must also implement a procedure for checking the practices of their commercial partners before deciding whether to establish commercial relations with them, seeking to identify any deviations in conduct related to the principles and values found in this Code. Suppliers are considered responsible for any losses resulting from the practices and acts of their business partners that may affect Larkalis’ Partner.

All matters related to Larkalis’ Partner must be dealt with by its Suppliers under absolute confidentiality and so as to ensure the protection of intellectual property rights.  Access to Larkalis’ Partner information must be limited to those who need to receive such information, and its use must be limited to the specific purpose of the supply or offer of services.

2.2 CORRUPTION

LARKALIS does not tolerate the practice of any acts related to corruption. The company values meritocracy and fair competition in the markets. This same behaviour will be required of its Suppliers.

Suppliers shall not practice any of the harmful acts against public national or foreign administration described in Austria’s Anti-Corruption Act or any anti-corruption law.

Suppliers shall be prohibited from promising, offering or granting, either directly or indirectly, any inappropriate advantage to a public, private or third sector official, or any third party related to the same, to influence any act or decision designed to promote its own interests or that of Larkalis’ Partner.

2.3 RELATIONS WITHIN THE SPHERE OF THE CONTRACT

LARKALIS requires cordiality, trust, respect, dignity and honesty in all relationships between its Members and Suppliers’ members, regardless of any hierarchical position, job title or duty. Such conduct must also be observed in the relationships between Suppliers’ members in the workplace.

2.3.1 Harassment

No worker may be subject to physical punishment, abuse or harassment of any kind. Within the scope of the contract with the Supplier, there will be no tolerance for threats and harassments of any kind, particularly sexual and moral harassment.

2.3.2 Discrimination

LARKALIS Suppliers shall not practice acts of prejudice or discrimination against other people, whether due to race, color, gender, social class, age, physical features, nationality, religion, disability, civil status, sexual orientation, union participation, party affiliation or political conviction.

  • Labor Practices

LARKALIS respects and promotes human rights in its activities, as well as in its commercial and labor relations. The company only accepts the establishment of commercial relationships with Suppliers who respect human rights and comply with applicable labor law, as well as the principles and values listed below.

2.3.3.1 Use of Forced and/or Child Labor, Sexual Exploitation of Children and Adolescents and Human Trafficking

LARKALIS Suppliers shall not tolerate, allow or condone the use of forced and/or child labor, sexual exploitation of children and adolescents or human trafficking as part of any process related to its activities.

LARKALIS shall not enter into or maintain business relationships with Suppliers who use irregular and/or illegal labor of children and adolescents, which subject its employees to degrading conditions or those analogous to slavery, or which accept sexual exploitation of children and adolescents or human trafficking. 

2.3.3.2 Work Conditions

LARKALIS Suppliers must offer their members decent working conditions with respect to workload, health and safety – always in compliance with the labor laws of the location in which they are operating.

LARKALIS Suppliers must remunerate their Members in a fair and dignified way, and based on objective evaluation criteria, offering all the legally required benefits. 

2.3.3.3 Political Activities and Free Association

LARKALIS is a non-partisan company and respects the individual right of its Members and third parties with respect to political and labor union involvement. In this sense, its Suppliers must recognise and respect the freedom of association of their own members.

2.3.3.4 Compliance with Labor Law

LARKALIS requires that its Suppliers strictly comply with the labor law of those sites in which they operate and also comply with any collective bargaining agreements and conventions in force, without this indicating the establishment of any employment relationship with Larkalis’ Partner.

  • SAFETY, HEALTH AND ENVIRONMENT

Appropriate care and diligence regarding health, safety and environment will always be crucial. Suppliers must contribute toward ecologically sustainable development, while continuously seeking to reduce the environmental impact of their raw materials, operations, products and services. Likewise, Suppliers must ensure the complete safety of their members and comply with workplace health, safety and environment rules applicable to their activities, including the safety and sustainability practices indicated by LARKALIS.

  • INTERNAL COMMUNICATION

LARKALIS Suppliers are liable for communicating the existence of this Code and its provisions, disseminating the values contained herein to its own executives, associates, shareholders, members and respective suppliers and/or partners, ensuring that the ethical principles mentioned herein are effectively practiced by the entire company and its value chain.

Suppliers must provide periodic training for their members in order to ensure that they understand and observe the ethical principles and values of this Code.

  • MONITORING AND EVALUATION

LARKALIS monitors the development and performance of its Suppliers to ensure compliance with the contract and the principles established in this Code. The evaluation is designed to help improve management practices and strengthen the partnership.

Accordingly, Suppliers must cooperate with LARKALIS during this evaluation by providing information and facilitating visits to their establishments at pre-established times and dates, whenever so required.

  • VIOLATIONS OF THIS CODE OF CONDUCT

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All of LARKALIS’s Suppliers must comply with the guidelines of this Code of Conduct.

LARKALIS reserves the right to take any measures it deems necessary when a Supplier violates any aspect of this Code of Conduct.

If any Supplier, through its representatives or any of its members, suspects or becomes aware of some violation of any aspect of this Code, by any person, it must communicate said violation to the LARKALIS Member responsible for managing the Supplier’s contract or through the LARKALIS Ethics Hotline.

The Ethics Hotline is the internal communication channel used for the LARKALIS Compliance System. Through this channel, LARKALIS Members, Suppliers or any other person may report events or occurrences in which there is evidence of non-compliance with the applicable laws or with the other aspects included under this Code. 

The Ethics Hotline ensures anonymity when reporting any violation of this Code of Conduct and is available as follows: Online at the Larkalis third-party website – www.larkalis.com – by clicking on the Ethics Hotline +43 1 710 2308-11 and e-mail  compliance@larkalis.com on the main page.

All reports will be analysed and shall be treated with confidentiality and objectivity, ensuring anonymity during communication and a precise assessment.

No form of retaliation shall be tolerated against any Supplier who reports, in good faith, some concern about illegal conduct or conduct that does not comply with the guidelines established in this Code of Conduct.

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