Code of business conduct

Our values

Our view

We consider the basis of every successful business to be dedication to excellence in performance intertwined with the quality of the product positioned on the market. Only well-rounded customer care can improve and ensure the joint growth of all business participants and bring added value to all aspects of the trade. It is necessary to cultivate relationships of mutual respect between business partners, externally, and employees, within the company.

We offer a wide portfolio of high-quality and diverse applicable products, delivered through the highest standards of executed logistics. Our business model includes top quality services providing added value to your company through our dedicated professionalism in providing a comprehensive service, thereby proving ourselves worthy partners that you can undoubtedly rely on as you strive to achieve international brand status for your company – from Only through motivated employees can we ensure that our business partners enjoy the fruits of joint cooperation.

Our mission

The mission of our company is to ensure the stability and growth of our company by creating strong ties with our suppliers on the one hand and our end users, to whom we will continue to offer operationally a wide portfolio of top quality products delivered through flawless logistics, while ensuring market competitiveness to all involved parties by implementing our know-how and experience in the oil and gas market to financially enable the commercial conditions necessary for the growth of our partners in each individual trade over short and long-term periods.

Our responsibilities

What is expected from all of us

Regardless of the job they do, we expect all our employees to:

• work in accordance with the law and our core values;
• respect the principles of our Code, rules and procedures, as well as the laws and regulations of the country in which they work;
• always use sound judgment and avoid any inappropriate behaviour as well as situations that could lead to illegal or unethical actions;
• think in such a way that every business relationship they enter into reflects our core values;
• if they notice or suspect certain illegal or unethical actions, they immediately contact their superior or any of the persons listed as reporting channels in this Code;
• be aware that any violation of our Code, rules and procedures may lead to disciplinary measures, including termination of employment, in accordance with applicable laws.

We expect our managers to:

• respect the principles of the Code and promote our core values at all levels of business;
• create an environment that encourages legal and ethical behaviour and allows employees to ask questions and express their concerns about potential violations;
• encourage the timely acquisition of the necessary training of employees related to the content and application of the Code and other applicable procedures and rules, and appropriately monitor the actions of their employees;
• immediately notify the Compliance Officer or other designated responsible person of any reports of illegal or unethical actions or any actions or practices that violate our policies, procedures, the Code or the law;
• ensure that the employees they lead know that they will be protected from retaliation if they have sought advice in good faith or reported questionable behaviour and/or potential injury.

Report of improper behaviour

Any employee who finds himself in a situation where he suspects illegal or unethical actions or any actions or procedures that violate our rules, procedures, the Code or the law, must immediately report any suspected violation.

In principle, as a first step, we encourage addressing your superior.

If this is not possible for any reason, it is necessary to contact any of the following channels for application:

• info@mpi.hr

• MARCO POLO INTERNATIONAL D.O.O.

RADNIČKA CESTA 21,, 10000 ZAGREB

n/r Compliance Officer

with the indication: “DO NOT OPEN”

Anonymity and confidentiality

Any inquiry or violation report can be submitted anonymously.

However, we point out that in some cases it may be difficult or even impossible for us to thoroughly investigate anonymous reports.

We take reasonable precautions to protect the identity of the reporting party and information about the individual investigation. We will handle all inquiries discreetly and will make every effort to preserve, to the extent permitted by applicable law, the confidentiality of information about anyone seeking advice or reporting questionable conduct and/or possible injury. Participants in a legality and compliance investigation in any capacity (for example, a witness) are expected to keep the details of the investigation confidential in accordance with the obligations in the Confidentiality Agreement for all employees and business partners.

Protection against revenge

Retaliation against any employee who reports a suspicion or violation in good faith is prohibited. Any retaliation is a violation of this Code.

Seeking advice, expressing concerns, reporting suspicions or violations cannot and will not be the basis for any adverse actions, which may include threats, harassment or discrimination, denial of benefits, dismissal, demotion or the like.

If an employee believes that he or she has been subjected to any of these practices for any of the reasons listed above or for reporting in good faith, he or she may contact any of the reporting channels listed above, and we will take appropriate action against any retaliatory practices.

False reports of suspicions or violations are considered a violation of the Code and are grounds for initiation of disciplinary or other procedures in accordance with relevant regulations.

Code in practice

When in doubt about how to act in a certain situation, we expect employees to use sound judgment by asking themselves the following questions:

• is mine or someone else’s behaviour legal and ethical?
• is it in line with our core values?
• Does it comply with this Code, our rules and procedures?
• will it reflect well on me and society?

If the answer to any of the questions is “no”, you should contact our application channels for advice.

Compliance monitoring officer

We have appointed a Compliance Monitoring Officer, who acts as an independent and objective body, oversees the corporate compliance program, is responsible for the continuous assessment of business compliance risks and the coordination of business processes.

The role of the Compliance Officer ensures that the Management and employees of the company respect the rules and procedures of the corporate compliance program, comply with the rules and regulations of the regulatory bodies, and that the behaviour in the organization meets the company’s standards of behaviour.

The Compliance Officer performs the following tasks:

– creates a corporate compliance program and related activities to prevent illegal, unethical or behaviour contrary to the company’s institutional values;
– provides support to the Management in creating an organizational culture;
– regularly conducts examinations of the set values, standards of conduct, mission and goals of the organization and monitors the organization’s compliance with them;
– proposes and establishes an effective system of internal controls and takes care of raising awareness, training and consulting on strengthening business integrity;
– proposes and establishes an effective system for reporting violations and protecting whistleblowers;
– identifies potential areas of vulnerability and compliance risk and develops and implements corrective action plans and provides general guidelines for resolving problematic issues;
– manages anonymous and/or confidential channels for reporting violations (improper behaviour and violations of applicable regulations, internal rules and ethical principles, etc.) with appropriate reporting of reports from authorized resolution bodies;
– is responsible for reporting to the company’s Management on business compliance;
– proposes corrective measures after observed and processed irregularities, deficiencies in procedures, policies, processes or organizational culture in its entirety;

The Compliance Officer reports directly to the CEO.

Our fundamental ethical principles

Human rights

In society, we respect the fundamental human rights defined in the United Nations’ Universal Declaration of Human Rights and internationally recognized principles and guidelines, including the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, which deals with freedom of association and collective bargaining, forced labour, child labour and by prohibiting discrimination.

In all countries where we operate, we respect all legal regulations and standards in the field of human rights.

Discrimination and harassment

In society, we promote a working environment in which any discrimination against employees, as well as any form of harassment and abuse in the workplace, is prohibited. We treat all employees equally, regardless of nationality, race or ethnic origin, national or social affiliation, gender, skin colour, state of health, disability, religion or beliefs, age, sexual orientation, family status, union membership, property status or other personal circumstance.

Employees who engage in harassment or discrimination are subject to disciplinary measures that may lead to termination of employment (in accordance with applicable law). Direct superiors are obliged to ensure that there is no harassment and discrimination in their business units/departments.

Child or forced labor

As a company, we do not employ children and we do not accept any form of child labour, as well as forced labour or debt slavery.

Safe and healthy working environment

In the company, we provide our employees with a healthy and safe working environment in accordance with the relevant regulations on work and safety at work, we continuously comply with the legal regulations related to the creation and maintenance of a safe and healthy working environment, and regularly adopt measures to reduce and eliminate possible risks for health and accidents.

As a company, we enable and oblige our employees to receive regular education and training in the field of safety and health protection at work, fire protection and property protection, and we encourage them to inform the responsible persons about potential dangers or deficiencies in the working environment and all insecurities in the workplace.

All employees must comply with the rules on occupational safety and health in accordance with the relevant legal regulations and internal acts on safety, occupational safety and fire protection.

Abuse of alcohol and drugs

The society strictly prohibits the consumption and/or use of alcohol, prohibited substances, drugs and/or other hallucinogenic substances in the workplace. A workplace is any place where an employee performs work for the company, regardless of time or location.

According to internal rules and procedures, employees may be subjected to testing for alcohol, drugs and other substances of addiction, including unannounced random testing.

Our business integrity

Measures against bribery and corruption

As a company, we respect anti-corruption laws in all countries where we do business.

No employee or any other person acting on behalf of the company may offer, promise or make a payment or give any other object of a certain value or demand or accept such an object for the purpose of influencing public and state officials or employees or other persons or obtaining an unfair business advantage . It is also prohibited to offer, authorize or pay or give any benefit with the intention of inappropriately influencing public and state employees or state employees, in order to gain an unfair business advantage.

Our employees and third parties acting on our behalf are not allowed to offer, ask for or accept bribes or other illegal payments in order to conclude or retain business, they are not allowed to participate in money laundering and are obliged to comply with the general principles of combating money laundering, corruption and bribery defined relevant conventions on combating corruption and money laundering.

Gifts

Employees or any other person acting on behalf of the company must not give or accept any gifts, tokens of appreciation or offers of entertainment that could influence business transactions or decision-making by employees, business partners or clients. Gift-giving and entertainment practices may differ in different cultures or countries, but all gifts and entertainment, received or given, must comply with the law, must not violate the policies and rules of the giver and recipient, and must be in accordance with local practices, customs and laws.

Payments that accelerate procedures

Payments that speed up procedures include the provision of unofficial benefits with the aim of facilitating and speeding up activities or procedures to which the person making the payment is authorized by law.

In the company, we do not promise any benefit, we do not make payments and we do not give gifts to speed up the decisions of government bodies, officials, business partners or any third party.

Conflict of interest

A conflict of interest occurs when, when performing their work, employees or other persons acting in the name of the company put their personal, social, financial, entrepreneurial or political interests or the interests of family members or other related persons before the interests of the company.

A conflict of interest exists when an individual’s personal interests affect or could affect the employee’s ability to objectively make decisions and perform their work for the company.

In accordance with the provisions of applicable laws and our internal procedures and regulations, our employees must avoid situations of real and potential conflicts of interest, including situations that may appear to be a conflict of interest in relation to their position, work and themselves.

We expect our employees to refrain from all activities that are in conflict with the interests of the company and to make decisions in an impartial and objective manner.

Any possible conflict of interest must be reported to the immediate superior employee, and if this is impossible for any reason, the Compliance Officer must be consulted through the reporting channel.

Our responsible business

Property of the company

Employees, business partners and third parties are obliged to use the company’s assets carefully, purposefully and rationally and in accordance with internal regulations and instructions.

The assets of the company are used for the needs of the company, and only exceptionally and to the agreed extent for personal needs.

Use of information technologies

The use of the company’s information technologies and resources and access to their content is permitted for the purpose of performing work for the company or for other approved purposes arising from it.

We expect our employees to use common sense and judgment in all situations, behave morally, professionally and in accordance with the law, and strictly respect authorization protocols when accessing the company’s information technologies and their content.

Unacceptable use of company resources includes processing, sending, obtaining, accessing, displaying, saving, printing and any other distribution of false, abusive, threatening, illegal, racist, sexist, obscene, intimidating, defamatory and other professionally inappropriate messages, materials and data.

Intellectual property

Intellectual property that employees create within their employment relationship or the right to use it, is transferred to the company to the extent determined by law and/or in accordance with the employment contract or other contract.

We also require employees to respect other people’s intellectual property. Unauthorized use, theft or misappropriation of third party confidential information or intellectual property is strictly prohibited.

Data protection

Employees have access to various data owned by the company, and sometimes also owned by third parties. This can be financial data, business plans, marketing plans, sales data, technical data, data on employees and customers and other types of data.

We carefully protect all confidential information, prevent inappropriate or unauthorized access or disclosure of this information, which may harm the company, our business partners and third parties.

Unauthorized access, use or disclosure of confidential information may also constitute a violation of confidentiality agreements, applicable laws, including data protection regulations.

Company employees must comply with all rules and procedures for data security and protection, and access, use or disclosure of data is permitted only to employees who are duly authorized to do so.

In our daily business, we expect our employees to be guided by the following principles:

• in case of doubt as to whether it is sensitive and confidential data, to act as if it is data of the highest degree of confidentiality and to consult with the owner of the data;
• when sending sensitive or confidential data by electronic mail, to ensure that the message is marked with the appropriate level of confidentiality and that the attachment is adequately protected against unauthorized access;
• do not disclose confidential or proprietary information to third parties, including business partners, customers and suppliers, without appropriate authorization and/or any required confidentiality agreement;
• do not discuss confidential information in places where it can be overheard and secure all confidential information when working in an open environment;
• confidential or protected data are used and disposed of in accordance with procedures and rules;
• they do not directly or indirectly access data that is not of a public nature or duplicate, copy or use it outside the scope of their duties and tasks; When they leave the company, all authorizations to access or use non-public data cease to be valid, and all data in possession must be returned or destroyed.

The company’s employees, business partners and third parties acting on our behalf are responsible for the protection of personal data, and may process such data only within the limits permitted by applicable laws.

Our suppliers and business partners

The company effectively manages risks arising from business relations with customers, suppliers and other business partners. The Code determines the minimum standards that we require from our suppliers, their subcontractors and other business partners, and which they must respect and adhere to when doing business with the company. The Company requires suppliers, its subcontractors and other business partners to act in accordance with the Code or equivalent standards, which may represent higher standards than those prescribed by applicable law.

We expect suppliers and business partners to:

• respect human rights and create a working environment in which the dignity and privacy of individuals are respected;
• act in accordance with the law and our core values and refuse all types of illegal business;
• have established internal controls, risk and conflict of interest management systems, and to notify us immediately of a conflict of interest that could directly or indirectly affect the company;
• ensure that its employees and subcontractors are informed about the Code and that they comply with it;
• respect the laws on the fight against corruption and market competition and manage the risks of all frauds and abuses.

The supplier and business partners are obliged to report any suspected violation of regulations, laws and the Code through any of our available channels.

Suppliers and business partners who are proven to try to improperly or illegally influence the decisions of the company will be excluded from any future transaction with the company.