CONSTRO, UAB is a reliable and socially responsible Company. The Company links its success to the trust of its stakeholders. To achieve its objectives, the Company has gathered a team of highly qualified professionals, who are constantly improving their skills, and whose ethical behaviour towards colleagues, customers and partners is at the core of their day-to-day activities.
1. The Code of Ethics describes the standards which employees of the Company adhere to. The standards of conduct are based on ethical and legal behaviour. Our Code of Ethics is the commitment of the Company as well as the document summarising values and business principles promoted by our Company. It is the expression of professionalism that the Company’s employees foster in their work and expect the same from the Company’s partners. The commitment to follow the Code of Conduct and the rules contained therein is one of the key conditions for the cooperation and labour relations.
2. The aim of our Code of Conduct is to reveal and consolidate the values, business principles and behavioural standards of the Company, and to set out the Company’s guiding principles in respect of its relations with the customers, business partners, public institutions, competitors, shareholders, and employees.
3. Each employee, who becomes aware of any non-compliance with (violation of) the Company’s rules, commitments, or obligations, as well as of any circumstances indicating that there is a real threat to the interests of the Company, its employees, customers, business partners or the Company’s shareholders, must immediately report this to the head of the Company.
4. We value and respect each of our customers, colleagues, and business partners, and we are committed to treating them with respect and integrity, so that they have no doubts over the reliability of cooperation. We pursue the principles of fair business. We act in a transparent, reliable, and fair manner. We always separate public and private interests.
5. We avoid conflicts of interests, i.e. situations, where the employees have to choose between the interests of the Company, its customers, partners or personal interests. In the event of a conflict of interest, the employee must immediately inform his/her line manager or the head of the Company. The pursuit of personal financial interests in the performance of one’s duties shall not be tolerated by the Company in any form or under any circumstances.
6. Environmental protection. As a responsible business, the Company undertakes to actively reduce its environmental impact. Every day, we strive to ensure that all our employees are adequately informed and trained on the issues related to the environmental requirements. The Company and each of our employees must make all possible efforts to reduce the amount of waste and any other impact on the environment. In our activities, we endeavour to save natural resources, raw materials, and energy, to choose our products properly and to purchase and use them in a responsible manner, to responsibly manage waste and reduce the amount thereof, to support and contribute to the national initiatives on environmental protection.
7. Regulatory compliance. Each employee must be thoroughly familiar and comply with the legislation regulating the performance of his/her job functions. The managers must provide their subordinates with all necessary explanations and advice in the field of application of relevant legislation in the performance of their job functions. The Company is strictly committed to non-discriminatory and fair labour standards, to protecting the environment and to ensuring the safety and health of its employees. The Company expects its employees to comply with all laws designed to protect health, safety, and the environment, to obtain all necessary permits and perform their work strictly in compliance with relevant legal requirements.
9. Employee relations and personal commitments. The Company’s relations with its employees are based on mutual respect, non-discrimination and compliance with obligations and legal requirements. In order to achieve the Company’s objectives, the Company must ensure work discipline, maximum attention to customers and an exemplary service culture. Employee relations within the Company are based on unconditional honesty, respect for each other, adherence to customer service standards and principles of work ethics. Each employee shall observe the work ethics of the Company, i.e. to co-operate with co-workers, customers, partners and others in a fair manner; to behave with dignity, respect and integrity; to maintain a productive and constructive working atmosphere; to perform his/her work in a proper and professional manner; and to respect the work of co-workers. The Company has a strict zero tolerance policy for employee misconduct, such as defamation, making unsubstantiated negative claims, disrespect for an individual and the Company.
10. Loyalty of employees. The loyalty of employees towards the Company is expressed through the understanding of the Company’s objectives, obligations to the shareholders and the proper implementation thereof; fair execution of the lawful instructions of the managers, proper performance of duties; clear limits of acceptable and encouraged conduct of employees when dealing with customers, partners, public institutions and shareholders of the Company; protection of the interests of the Company’s customers, employees, business partners, society and shareholders; reporting all the noticed cases of corruption or other criminal activities.
11. Discrimination. The Company does not tolerate any direct or indirect form of discrimination, including discrimination on the grounds of sex, race, nationality, language, ethnic origin, social status, religion, beliefs or opinions, age, sexual orientation, disability, ethnicity, or religion. In addition, the Company does not tolerate any form of harassment, psychological violence, bullying or the use of position held. Decisions relating to recruitment, training, competence development, remuneration and benefits, promotion, leave and conduct at work shall be made on the basis of objective criteria and factors, and without any discrimination. The Company shall, to the extent possible (taking into account the specific nature of the services provided) and the financial resources available, take steps to enable persons with disabilities to apply for vacant positions within the Company, as well as to work, pursue a career, or take part in the trainings.
12. Conflict of interest. Business transactions must be conducted in the best interests of the Company. Neither a natural person nor a legal person having any relationship with an employee of the Company may gain benefits from the Company in a dishonest manner, using his/her connections with the employee or his/her position held. The situations where there may be a conflict between the employee’s responsibilities towards the Company and his/her personal interests must be avoided. The employees must avoid any circumstances which might cause damage to the reputation of the Company or other material and immaterial interests of the Company. All conflict situations related to labour relations within the Company shall be resolved immediately and in accordance with the requirements of relevant legislation. The Company shall not prohibit its employees from engaging in activities which do not and cannot adversely affect the interests of the Company and the proper performance of the employee’s job functions. However, the employee must inform the Company of such activities prior to the commencement thereof in order to avoid any conflict of interest.
13. Relations with customers, partners, representatives of public institutions. Our relations with customers, partners and representatives of other institutions are based on respect, integrity, professionalism, mutual trust, justice, priority of customer interests, compliance with obligations, information sharing and the priority of negotiations against legal actions. The employees of the Company must make every possible effort to prevent any manifestations of corruption.
14. Relations with competitors. Our relations with competitors are based on the principles of integrity and mutual respect. In case of any disagreement or conflict when entering into competitive actions, negotiation and compromise should always be a priority. Fair competition is a fundamental principle of the Company’s business. Information on the activities of competitors is collected only through lawful and publicly available means of collecting information.
15. Information and communication with the public. The Company shall disclose all the information on its activities strictly in accordance with the requirements of legislation of the Republic of Lithuania. The employees of the Company must refrain from disclosing any information to the mass media representatives, except in such cases, where the appropriate written instruction is obtained from the head of the Company. Information on behalf of the Company both to the mass media and any third parties that are not the customers or partners of the Company shall be provided only by the authorised person or the head of the Company. Confidential information relating to the Company’s activities and its partners shall be kept strictly confidential by each of the Company’s employees.
16. Bribery, facilitation payments, business lunches and gifts. The Company shall never aim to gain business advantage by unlawful means. It shall be strictly prohibited to offer or give bribes to the third parties in the activities of the Company. None of the employees may make any payments, give bribes, and offer unfair financial benefits to the customers or
other persons engaged in public functions, thus endeavouring to maintain commercial relations in providing services or obtaining other benefits. The employees of the Company must not grant any hidden privileges to the customers, business partners, representatives of state, municipal, or public institutions. The payments made in a form of expensive gifts and all other forms of illegal payments, services, or other remuneration by the employees to the customers, representatives of state, municipal or public institutions, or other third persons, which are in business relations with the Company, for the taken or non-taken decisions in favour of the Company shall be strictly prohibited. The employee of the Company who suspects that any third party (customer, colleague, etc.) is trying to involve or use him/her in a conclusion of an unlawful transaction, must report that to the head of the Company. Business lunches and business gifts to the employees should comply with the general policy for business expenditure and the rules and requirements of the government institution or of a legal person concerned. Third parties must not be used to bypass the aforementioned policies.
17. Benefit provocation and benefit acceptance. The term “benefit” includes the following: expensive gifts, loans, tax benefit, reward, position, employment, transaction, services, support, etc. The Company shall prohibit the managers or employees to provoke any benefit from the customers, suppliers or any other person related to the business of the Company. The managers and employees must refuse to accept a benefit offered on account of their positions, if the acceptance of the benefit might affect their objectivity or force them to act against the interests of the Company, or if that might result in a claim regarding partiality.
18. Benefit offering. Any payments, agreed favourable conditions or other advantages provided by the managers or employees in the performance of the Company’s activities, shall comply with the prevailing policy of the Company on practice in dealing with such issues. Such payments shall only be possible upon prior written approval of the Director.
19. Entertainment. Although entertainment is an acceptable form of business and public conduct, managers or employees should refuse invitations to catering institutions or entertainments that are made too often in order to avoid discomfort or loss of objectivity in the performance of the Company’s activities. Where it is impolite to decline an invitation, the manager or employee may accept it under the agreement that he/she would be allowed to respond the same way.
20. Protection of interests of the Company, its shareholders, customers, business partners and employees. The Company does everything within its power to protect and defend the rights and legitimate interests of its shareholders, customers, business partners and employees. The employees of the Company should take all reasonable actions within their power in order to prevent any unlawful actions of any employee, customer, business partner or any third party, which would cause damage to the State and the public in general as well as to the Company or any of its customers, employees, or business partners in particular. The employees of the Company must refrain from any act that would violate good morals or laws. The Company shall maintain the full confidentiality of persons, who reported the non-compliance to the norms of this Code of Ethics and shall ensure the protection of such persons in accordance with the provisions of the laws.
21. Use of Information Technologies. The Company shall, at its discretion, provide employees with work equipment (computer, mobile phone, internet access, e-mail, other information technology and telecommunications equipment), depending on the employee’s position and duties. The work equipment provided belongs to the Company and is intended for the performance of job functions. The employees who use the e-mail, Internet access and other information technology and telecommunications equipment provided by the Company are strictly prohibited from publishing the Company’s confidential information (including, but not limited to, copyright objects, internal documents of the Company) on the Internet, if it is not related to the performance of job functions. It is forbidden to use work e-mail and Internet access to carry out the activities prohibited by the laws of the Republic of Lithuania, to disseminate information of a defamatory, offensive or threatening nature or contrary to the principles of public ethics and morality, to disseminate computer viruses, or to violate the legitimate interests of individuals; to download or distribute graphic, audio and video materials, games and software that are not directly related to work, send data that are infected with viruses, contain various other software codes, files that may disrupt the functioning and security of the Company’s computing or telecommunication devices and software; to modify, repair information technology and telecommunications hardware and software by oneself; to transfer information technology and telecommunications hardware and software belonging to the Company to third parties, provided that such transfer is not related to the performance of the Company’s business functions or is otherwise in any way prejudicial to the interests of the Company; install, store, use, copy or distribute any unauthorised, illegal, copyright infringing or personal software/computer software; use the equipment for unauthorised access to data or systems, for checking the security of systems, for scanning, for monitoring computer network traffic data; perform other acts that are not related to the performance of his/her duties or that are contrary to the legislation.
22. Control. The employees who fail to comply with the provisions of this Code of Ethics may be subject to disciplinary measures. This Code of Ethics shall be introduced to each employee by signature. The management shall regularly monitor whether the Code of Ethics is complied with, and, if necessary, implement specific monitoring programmes. The violations of the Code of Ethics shall be brought to the attention of the line manager of the employee in question, or a responsible person appointed by the Company.
23. Implementation. We also strive for the provisions of our ethical conduct to be implemented by our suppliers and partners.
