Every employee of the company undertakes not to offer, provide, or promise bribes in any form — whether in cash, services, gifts, or personal invitations — to any interested party in order to gain an undue advantage. Providing such benefits through an intermediary is equally prohibited.The employee also undertakes not to solicit or accept a bribe, gift, service, or invitation — whether from an external partner or on behalf of an external partner — if such conduct would result in obtaining an undue advantage (e.g. concluding a contract in violation of the law). This prohibition also applies to offers or acceptance made through a third party.Every employee undertakes not to accept or provide cash, gifts, or invitations in connection with a tender process — before, during, or as part of any other negotiation.A so-called facilitation payment (payment for expedited processing) constitutes a form of corruption, regardless of whether it is provided directly by the company or indirectly through an intermediary.If an employee, external partner, or other interested party finds themselves in any of the above situations, they are obliged to immediately notify the person responsible for overseeing compliance with anti-corruption regulations and rules — in person, by phone, or by email at: oznamenia@gratex.com.
Giving or receiving gifts and invitations may be a common expression of courtesy and contribute to building good business relationships. However, such conduct may also be perceived as an act of active or passive corruption. Therefore, all gifts and invitations must be appropriate, reasonable, transparent, consistent with the company’s values, and free of any ulterior motives. The fundamental principle in this regard is transparency.
No employee may accept or provide monetary gifts.
An employee is required to decline any gift or invitation from a supplier or partner, unless it is clearly of symbolic value not exceeding €50. Exceptions may include:
Lunches, dinners, or beverages appropriate to the time and duration of meetings or seminars,
Invitations to seminars or professional events that are justified for work-related reasons.
In these cases, the employee is obliged to consult their supervisor and decline any reimbursement of accommodation or travel costs. In case of doubt or special circumstances, the employee shall contact the person responsible for overseeing compliance with anti-corruption regulations and rules.
If an employee receives a gift of higher value which could not be declined without breaching the rules of courtesy, they are obliged to inform their supervisor. Such a gift must be shared with colleagues or handed over to the ABMS manager, who will arrange for it to be donated to a charitable cause.
The employee is obliged to ensure that all gifts and invitations provided on behalf of the company are appropriate, reasonable, and consistent with the company’s values. In case of doubt, they are obliged to consult the person responsible for overseeing compliance with anti-corruption regulations and rules.
In the context of business relationships, the employee is obliged to verify that business partners are familiar with the company’s anti-corruption policy on gifts and invitations. They are also obliged to familiarise themselves with the anti-corruption rules of their partners.
Every employee is obliged to report all gifts received.
A conflict of interest arises when an employee’s personal interest may be in conflict with the interests of the company. Such situations may call into question the independence, objectivity, and impartiality of decision-making.
Every employee is obliged to identify any potential conflicts of interest to which they may be exposed, report them immediately to the person responsible for overseeing compliance with anti-corruption regulations and rules, and refrain from participating in the relevant decision-making until an appropriate resolution is reached.
The employee undertakes not to acquire any shareholding, in any form, in companies controlled by competitors, suppliers, or customers without the prior written consent of the company’s CEO.Without the prior written consent of the company’s CEO, no employee may engage in any work activity outside the company.
In specific cases, it may be appropriate in the course of business to use the services of intermediaries — whether paid or unpaid — in order to simplify or expedite negotiations, procedures, or transactions with public or private sector organisations.
In such cases, the employee is obliged to:
Verify in advance the reputation and standing of the intermediary,
Conclude a written agreement that clearly sets out the amount of the remuneration or commission and the method of payment,
Verify the reality and legitimacy of the services provided.
The company strictly prohibits any gifts, contributions, or subsidies of a political nature, as well as gifts provided to political parties or political movements.
If the company intends to provide a gift or grant of a charitable, social, or educational nature, it is obliged to verify the legal and ethical basis of such provision in accordance with applicable legislation, internal rules, and the specifics of the country in which the gift is being provided.
Respect for fundamental human rights is an integral part of the company’s corporate culture. The company undertakes to create and maintain a fair, safe, and non-discriminatory working environment for all employees.
We do not tolerate forced labour, child labour, or any form of worker exploitation. Every employee has the right to fair remuneration, reasonable working hours, and dignified treatment. We expect the same principles from our business partners.
Our company promotes diversity and creates an inclusive environment in which everyone is welcome regardless of age, gender, ethnic origin, nationality, religion, disability, or sexual orientation.
We believe that diverse teams generate more innovative solutions and contribute to the long-term success of the company. Our priority is equal opportunities, fair treatment, and the rejection of any form of discrimination or prejudice.
We process the personal data of employees, clients, and business partners with the utmost care and in compliance with applicable legislation.
We ensure transparency in the collection and use of personal data and implement appropriate technical and organisational measures to protect it from misuse. Every data subject has the right to be informed about the processing of their personal data and to exercise their statutory rights.
Cybersecurity is essential for the protection of information systems, data, and customer trust. The company implements preventive measures to protect against cyber threats and regularly trains employees in the field of information and cybersecurity.
Every employee is responsible for the secure use of IT tools, compliance with internal security rules, and reporting suspicious activities.
The company expects its suppliers and business partners to uphold the same ethical principles as the company itself.
We work exclusively with partners who respect human rights, lawful working conditions, environmental standards, and the principles of transparency and fair business conduct. We regularly review the ethical compliance of our supply chain and, where violations are identified, take appropriate measures.
SanctionsAny breach of this Code of Ethics by an employee of Gratex International, a.s. may, depending on its severity or frequency, constitute grounds for the imposition of a disciplinary sanction, up to and including termination of employment by the employer.
This Code of Ethics is binding on all employees as well as on business partners with whom Gratex International, a.s. cooperates.
In Bratislava, on 07.01.2026
Chairman of the Board and CEO
