BUSINESS PARTNER CONDUCT & ETHICS POLICY
Business Partner Conduct & Ethics Policy
Introduction
The GREENIGEN Ltd. is committed to the highest standards of compliant and ethical conduct in its business dealings. All business partners which include customers, suppliers and third parties that provide services to GREENIGEN Ltd. must behave in a manner that does not damage GREENIGEN Ltd.’s reputation. This Business Partner Conduct and Ethics Policy (“Policy”) describes how GREENIGEN Ltd. expects its business partners to behave and, as such, represents the standards that GREENIGEN Ltd.’s business partners must observe.
The Policy applies to all companies doing business with GREENIGEN Ltd., referred to in this document as “business partners.”
This Policy is designed to assist GREENIGEN Ltd.’s business partners, acting through their employees, officers and directors, in conducting their daily activities ethically and legally as an integral part of doing business with GREENIGEN Ltd.
This Policy is not intended to cover every situation that might arise, nor will it take account of every legal requirement, but is intended to help business partners make the right decisions and ask the right questions.
It is the responsibility of all business partners to know, understand, and comply with this Policy, subject to applicable law.
A failure to comply with this Policy may result in GREENIGEN Ltd. terminating its business relationship with a business partner, among other consequences. If an actual or potential violation of any law, regulation, or provision of this Policy is identified, or to request assistance with compliance and business ethics matters relating to GREENIGEN Ltd., contact us at www.greenigen.hu or by e-mail info@greenigen.hu
Workplace and environment
Equal employment opportunity: Business partners are expected to foster a work environment in which all individuals are treated with respect and dignity.
Fair Wages: Business partners are expected to provide wages and benefits in compliance with local laws.
Harassment-free workplace: GREENIGEN Ltd. expects its business partners to commit to providing a workplace that is free of harassment, bullying and other unlawful conduct.
Substance abuse: GREENIGEN Ltd. is committed to maintaining a safe and healthy work environment free of substance abuse and expects its business partners to adhere to the same high standards.
Workplace violence: Business partners are expected to provide a workplace that is free of violent and abusive behaviour, in compliance with applicable law.
Environment: Business partners must comply with all applicable environmental laws and prevent or mitigate any adverse environmental impact in all its business activities.
Human Rights: GREENIGEN Ltd. is committed to supporting and respecting the principles set out in internationally proclaimed human rights. Business partners shall ensure that the employment of workers adheres to all applicable laws and regulations, and not tolerate child and forced or compulsory labour at any point in their supply chain.
Health and safety: Business partners shall commit to providing their employees with healthy and safe workplaces in compliance with applicable laws.
Whistleblowers: Business partners must create programs to ensure the protection of their worker whistleblower confidentiality, where allowed by law, and to prohibit retaliation against workers who participate in such programs in good faith.
Working with others
Antitrust and competition: All business partners are expected to carry on business in accordance with all applicable antitrust and competition laws.
Confidentiality: All business partners must protect confidential information of GREENIGEN Ltd. in all respects. Business partner personnel must be careful not to disclose confidential GREENIGEN Ltd. personal or business information through any casual conversations or discussions in a public place.
Competitive intelligence: Where a business partner is providing competitive intelligence to GREENIGEN Ltd., it is permissible to lawfully gather and use information gained about the activities of GREENIGEN Ltd. competitors. However, it is GREENIGEN Ltd.’s expectation that such information must only be obtained by a business partner through lawful and ethical practices.
Fair dealing: Each business partner shall deal fairly with GREENIGEN Ltd. and its customers, suppliers and commercial partners.
Conflicts of interest: Business partners shall disclose to GREENIGEN Ltd. any relationship that appears to create a conflict of interest in their business relationship with GREENIGEN Ltd. This includes family relationships, closer personal relationships, excessive gifts or favors or frequent lower-value gifts or favours.
External communications: Without GREENIGEN Ltd.’s prior written consent, business partners are not authorized to provide any response to any inquiries about GREENIGEN Ltd., its brands or its businesses including, but not limited to, media interviews, commentary to analysts, writing newspaper or magazine articles, expressing viewpoints related to competitor initiatives, forward-looking information, company strategy, proposed legislation or government regulations, or speculation about GREENIGEN Ltd.’s financial condition, as well as any other external sources seeking information about GREENIGEN Ltd..
Corruption and bribery: The laws of virtually all countries in which business partners operate, as well as extra-territorial laws, such as the United States (US) Foreign Corrupt Practices Act and the United Kingdom (UK) Bribery Act, prohibit bribes to governments and other officials (such as political candidates, political parties and their officials, employees of government-owned business, United Nations officials and individuals, etc.). Business partners shall ensure that all GREENIGEN Ltd. invoices raised are for legitimate business purposes only. Under no circumstance is it acceptable for business partners to seek, offer, give, solicit or receive any form of bribe or kickback.
Marketing, advertising and promotions: Business partners shall carry out any marketing, advertising or promotional activities in a fair, truthful and ethical manner.
Anti-Tax Evasion and Anti-Facilitation of Tax: Business partners should comply with all relevant tax legislation in countries and territories where they operate in accordance with relevant tax authority rules. Business Partners must create programs to detect and prevent tax evasion and facilitation of tax evasion.
Privacy
Privacy and personal information: In the course of its dealings with GREENIGEN Ltd., business partners may come into possession of personal data relating to GREENIGEN Ltd. employees, customers, vendors or service providers. GREENIGEN Ltd. personal data must be restricted and protected from discovery by unauthorized parties through appropriate security measures, which may include encryption or similar encoding processes for personal data captured in electronic form and must not be disclosed without GREENIGEN Ltd.’s prior written consent. Business partners are not permitted to store GREENIGEN Ltd. personal data on laptops, mobile drives or the hard drive of their computers, or leave GREENIGEN Ltd. personal data available in and around their workstations, but instead should access it only through a secure site, or otherwise keep such information in a locked drawer, office or storage area and only for so long as is necessary for the purposes in which the data was originally obtained.
In the event such personal data is inadvertently disclosed, the business partner must immediately notify GREENIGEN Ltd.
As an example, business partner personnel who have access to personal data about GREENIGEN Ltd. employees, such as compensation information, must treat it appropriately and confidentially.
Protecting assets
Business partner personnel may, in the course of performing their duties, come into possession of “material non-public information” about GREENIGEN Ltd. or other companies with whom GREENIGEN Ltd. does business. Buying or selling securities based on such information is referred to as “insider trading” and can result in substantial fines and imprisonment.
Money laundering or illicit financing: Business partners shall implement appropriate internal procedures to actively guard against possible money laundering or illicit financing activity.
Trade sanctions: Business partners must observe and comply with the laws and regulations governing activities in the various regions and countries where GREENIGEN Ltd. conducts business. Those laws include trade sanction regulations implemented by the US, EU, and United Nations.
Intellectual property of GREENIGEN Ltd.: GREENIGEN Ltd. is committed to protecting its brands and other intellectual property. This means that all business partners shall safeguard the intellectual property of GREENIGEN Ltd., such as trademarks, service marks, patents, copyrights, and trade secrets. All such information, products and inventions, whether or not they are subject to a copyright, patent, trade secret or other rights, are the sole property of GREENIGEN Ltd.
Intellectual property of others: Business partners shall not reproduce, distribute or alter copyrighted materials without permission of the copyright owner or its authorized agents. Software used in connection with GREENIGEN Ltd. business must be properly licensed and used only in accordance with that license. Using unlicensed software could constitute copyright infringement. The unauthorized reproduction, distribution or use of copyrighted materials, including software, can result in severe civil and criminal penalties and is strictly prohibited.
Use of information assets: GREENIGEN Ltd. information assets are to be used by a business partner solely in accordance with the terms of the business relationship with GREENIGEN Ltd.
Business partners may not use, whether inadvertently or intentionally, GREENIGEN Ltd. information, technology or communication systems to:
- Allow others to gain unauthorized access to GREENIGEN Ltd.’s information technology or communication systems through the use of a password or other security codes.
- Access files, data, or systems to which express authorization from the owner, whether GREENIGEN Ltd. or another company, has not been obtained.
- Remove, install or modify any GREENIGEN Ltd.-installed software or programs without authorization.
- Send copyrighted documents not authorized for reproduction.
- Attempt to circumvent or subvert system or network security measures.
- View network traffic for any reason (unless required by the business partner’s relationship with GREENIGEN Ltd.).
- Send or promote the distribution of unsolicited and unnecessary “junk mail” (e.g., chain letters, advertisements or other communications that represent a waste of time or computer resources for GREENIGEN Ltd. or others).
- Access the Internet for inappropriate use such as pornography or personal entertainment.
- Send harassing, threatening or obscene messages.
- Engage in any non-GREENIGEN Ltd.-related business activity.
- Engage in illegal activity or any other activity contrary to GREENIGEN Ltd. policy.
Company business information and records
Confidential and proprietary information: All GREENIGEN Ltd. confidential and proprietary information, products and inventions, whether or not they are subject to a copyright, patent, trade secret or other rights, are the sole property of GREENIGEN Ltd. The business partner shall ensure that its personnel shall not disclose GREENIGEN Ltd. confidential information to any third party, including business colleagues, friends or family members, except for reasons strictly related to the performance of their authorized duties for GREENIGEN Ltd., and should share such information only with other business partner employees who have a “need to know” or as permitted by applicable law.
Confidential information includes, but is not limited to:
- Proposed or advance product plans.
- Projected earnings, important management or organizational changes, information about mergers or acquisitions and any other information related to the foregoing.
- Product or service design and development or training.
- Computer software and systems developed by, or for, unique to, GREENIGEN Ltd.’s business.
- Client lists (including phone numbers, addresses and email addresses) or client contact information.
- Personal, financial or compensation information pertaining to any employee of GREENIGEN Ltd.
- Advertising or marketing plans, cost structures, pricing plans and strategies.
Business partners and their personnel are responsible and accountable for safeguarding GREENIGEN Ltd. documents and information to which they have direct or indirect access as a result of the business partner’s relationship with GREENIGEN Ltd. This duty includes the responsibility to protect sensitive or confidential GREENIGEN Ltd. documents from unwanted disclosure.