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Code of Conduct

SIA „Data Security Solutions“

POLICY

CODE OF BUSSINESS CONDUCT

 

 ON HUMAN & LABOR RIGHTS,

HEALTH & SAFETY AND

ANTI-CORRUPTION REQUIREMENTS

Approved on 07th of January, 2019

by Member of Board of the Company

Andris Soroka

INTRODUCTION

SIA “Data Security Solutions”, a company registered in accordance with the laws of Republic of Latvia with unified registration No. 40103302905 (hereinafter – DSS) is a company which offers world leading software and hardware solutions together with full range of services related to these solutions (IT consultancy, IT Security audit, selection and evaluation of the solution which fully fits requirements of the Customer, implementation and technical support of the solution based on ISO/IEC 2700 standards). Team of DSS has many years of experience working with selected top security vendors in Latvia, Lithuania and Estonia.

Our vision is to become a trustful partner to private and public organizations in Latvia, Lithuania and Estonia. Further, the main mission of DSS is to strengthen the Baltic States as defended and safe place for business.

This Policy “Code of Business Conduct” is based on legal acts of Republic of Latvian and applicable international laws or agreements, as well as unified legal principles and defines requirements on human and labor rights, health and safety, as well as anti-corruption.

DSS and its employees must follow this policy “Code of Business Conduct” and apply the requirements of this Code as a minimum, even if they stipulate a higher standard than required by national laws or regulations.

DSS shall on an on-going basis keep updated on changes to and updates of this policy “Code of Business Conduct”.

DSS will post changes to or updates at: https://www.dss.lv/

HUMAN RIGHTS

All employees, temporary or permanent; contracted by DSS shall be treated with respect, dignity, fairness and be entitled to fundamental human rights. DSS shall make sure that all employees working directly or indirectly for them know and understand these rights.

The freedom of expression and the privacy of employees, customers and other stakeholders shall be especially respected.

Diversity shall be promoted. Discrimination is prohibited regardless of grounds and specifically on ethnicity, gender, sexual orientation, marital, social or parental status, religion, political grounds, nationality, disability, age or union affiliation.

Child labor and illegal, abusive or forced labor have no place in DSS operations.

No person shall be employed who is below the minimum legal age for employment. Persons who are younger than 18 years may be employed only in specific cases and accordance with the applicable national legal acts.

LABOR RIGHTS

All employees, temporary or permanent; contracted by DSS shall have a written contract in a language understandable to them. The contract shall contain: working hours, overtime compensation, notice period, salary and frequency of payment.

A normal working week shall not exceed 48 hours and overtime shall be voluntary and not exceed 12 hours per week, unless otherwise regulated in collective bargaining agreements. Employees shall be entitled to at least one day off in every seven-day period.

The salary shall be fair and must meet basic needs. Overtime pay rates shall be premium to regular wages according to requirements of national legislation.

The employees are informed about, and fully understand, their employment conditions and rights in their own language. Employees shall be encouraged to use grievance mechanisms, i.e. to be able to voice concerns without fear of punishment or retaliation.

Working descriptions, including documented hazard work, are established, updated and communicated to all employees. All employees shall have access to basic amenities such as drinking water, toilets and adequate rest facilities that are clean, safe and fit for purpose.

Any form of involuntary labor is strictly forbidden. Nor shall employees be required to lodge deposits or original identity papers or equivalent. Employees shall be allowed to move freely and have the possibility to leave the premises outside of working hours.

Nobody shall be subject to physical punishment, unlawful detentions, physical, sexual, psychological or verbal harassment or abuse. Deduction from wages as a disciplinary measure may be permitted if such cases are strictly defined by the national applicable laws.

All employees shall be free to form and to join, or not to join, trade unions or similar employee representative organizations and to bargain collectively.

HEALTH & SAFETY

DSS’s working environment shall have fair working conditions and be safe and healthy, including both physical and psychosocial health. Appropriate health and safety information and training shall be provided to employees including, but not limited to: fire safety, emergency preparedness and first aid.

Adequate steps to correct and prevent physical accidents and injuries shall be taken to limit hazards of working environment. DSS shall provide appropriate IT equipment without any charge to the employee. Physical incidents and accidents shall be documented and reported to DSS’s board of management.

Every employee is responsible for making safety and health a priority and should:

(1) Promptly report unsafe or hazardous conditions to DSS’a management of the board;

(2) Comply with all DSS’s policies, laws, regulations and standards relating to conditions of employment, including those concerning hours, wages and other working conditions;

(3) Comply with applicable workplace safety and industrial hygiene policies, laws, regulations and standards.

ANTI-CORRUPTION REQUIREMENTS

All forms of corruption, including but not limited to extortion, bribery, facilitation payments, nepotism, fraud and money laundering, are strictly forbidden.

No one shall offer, ask for, give or accept, directly or indirectly, a personal payment, gift or benefit in exchange for favorable treatment intended to influence a business transaction or to obtain a personal or business advantage. This provision includes both families and employees of DSS.

DSS employees are prohibited to receive or give any kinds of gifts during procurement processes and in relations with officials.

Employees of DSS can only accept and give gifts on behalf of DSS, if the gifts demonstrate a clear business objective and are appropriate for the nature of the business relationship.

Business activities include modest forms of hospitality, such as lunches or dinners and occasional gifts of minimal value, which do not influence business decisions. Although it is difficult to define “customary” or “modest,” the best approach is to exercise good judgment. If employee of DSS shall be offered anything that is more than nominal in value, the employee must consult with the supervisor or member of the management board. DSS employees should avoid activities that are excessive or become a regular occurrence. For example, if the action will cause a disinterested third party to think the gift or service affected the employee’s judgment, then it is excessive and should be refused.

Fair competition and open markets shall be respected and business decisions shall not be motivated or affected by personal relationships or interests.