AM-BITS Group Code of Conduct

This Code of Conduct provides a concise overview of the AM-BITS Group’s fundamental values, which guide the conduct of our business units: AM-BITS LLC, AM-BITS Development, AM-BITS Consulting, AM-BITS Software, and AM-BITS International.

Should you encounter a situation where you are uncertain about the appropriate course of action, this Code of Conduct will assist you in making the most suitable decision.

The integrity of our actions

Integrity and fairness underpin our business policies and conduct. For each employee, this means that when in doubt, they will always adhere to this principle:

The AM-BITS Group expects employees, including management, to act with integrity and honesty at all times, both inside and outside the company.

Compliance with the law

It is our policy to comply with all local laws and regulations in all places where we operate, as well as with all internal regulations and instructions. The commercial success of the AM-BITS Group is contingent upon fair competition. We therefore refrain from any form of unfair competition, including anticompetitive agreements with clients, suppliers and competitors, as well as any violation of antitrust laws. It is important to note that the law is often broadly interpreted, and therefore when communicating with competitors, including in industry associations, we should take special care not to inadvertently exchange information that contravenes antitrust rules.

No discrimination

We are an equal opportunities employer and do not tolerate any form of discrimination on the basis of ethnic origin, nationality, gender, cultural characteristics, race, age, disability, religious beliefs or sexual orientation. The AM-BITS Group of Companies has a zero-tolerance policy towards any form of sexual harassment or persecution.

At present, 40% of AM-BITS Group employees are women, and the company is actively seeking to employ people with disabilities who are willing to work.

Responsible treatment of company property

We treat AM-BITS Group property with the same care and respect as if it were our own. However, we do not use it for our own purposes or make it available to third parties. In exceptional circumstances, prior management consent may be sought. Likewise, internal company information, including all production and trade secrets, may be used, stored and copied solely for the proper conduct of business.

Avoiding conflicts of interest

Conflicts of interest pose a significant risk to the company and often result in employees being placed in a position where their personal interests may influence their decision-making or create the impression that their actions are not aligned with the company’s interests. It is our policy to avoid conflicts of interest wherever possible. In line with the AM-BITS Group’s policy, employees are not permitted to work part-time for competitors, clients or suppliers, nor to participate financially in their business (except in the case of a listed company or with the relevant management approval).

It is the general rule that any family, personal or financial relationships that could impair objective decision-making in a particular situation should be disclosed to management so that it can determine how to deal with the situation. During office hours, each employee is expected to utilise their full working potential for the benefit of the company. This entails refraining from undertaking any external tasks for other employers and avoiding engaging in any personal activities.

Rejection of corruption

At AM-BITS Group, we have a zero-tolerance policy towards any form of corruption.

Even relatively minor local instances of corruption can have a significant negative impact on the reputation of AM-BITS Group worldwide. This can result in the immediate cessation of cooperation with major international clients. It is therefore the duty of all employees and managers of AM-BITS Group to take immediate and decisive action in the event of any manifestation of corruption and to cease cooperation with corrupt partners.

Another related principle is that we must not request private services or goods from a colleague, particularly if they are a subordinate, that we cannot obtain through other means.

In order to comply with the zero-tolerance policy on corruption, AM-BITS Group has a separate detailed anti-corruption programme in place.

Information security

All employees of AM-BITS Group are required to comply with security measures and instructions.

In the use of company devices, we always act responsibly to prevent loss or damage to data and IT systems. This encompasses general security measures, such as limiting the data stored on portable devices to only that which is necessary for work purposes and deleting old data that is no longer required.

We ensure compliance with all applicable data protection laws and regulations. This applies to both the personal data of employees and the handling of data belonging to third parties, such as customers or suppliers.

Our commitment to information security is outlined in the Information Security Policy and is supported by ISO 27001 certification.

Sustainability of our growth

Our growth is sustainable, both in terms of our business, our people and our offices.

Treating our business partners

At our company, we believe that sustainable growth is only possible when we understand how to attract new clients and create long-term relationships with existing clients to achieve mutual success. To achieve this, it is essential that we maintain a long-term focus on meeting our clients’ needs at all stages of the AM-BITS Group, from initial contact through to long-term satisfaction. All employees in departments without direct customer contact must also recognise their role in the supply chain and demonstrate commitment to serving our customers. Consequently, the principles of quality customer service apply not only to external clients, but also to internal clients within the AM-BITS Group and to work between departments.

We listen to our customers and provide them with clear, concise, and accurate answers. We respond promptly to queries and facilitate proactive problem-solving. We are reliable partners for our clients and committed to meeting our obligations. In the event of difficulties, we endeavour to identify a constructive solution that is mutually beneficial to the client and the AM-BITS Group.

We also endeavour to cultivate long-term partnerships with reliable suppliers. We place great emphasis on the constructive and professional fulfilment of agreements and the joint constructive search for new solutions. Communication with suppliers and customers should be clear, responsible and prompt in order to process open issues effectively.

Please be advised that partner statuses are updated on the official website on a regular basis. The latest information can be found at https://am-bits.com/uk/partners/.

Cooperation within the AM-BITS Group

We believe that clear levels of hierarchy, free and direct contact between employees and management, and the long-term retention of valuable employees are essential for achieving long-term success and responding effectively to changing market demands.

We conduct our business in a constructive, respectful and trusting manner. This means that we respond promptly to colleagues’ requests and communicate regularly and confidentially with each other to analyse and resolve potential issues.

As employees of the AM-BITS Group, we act and make decisions in line with the desired outcome and in accordance with our full scope of responsibility. We recognise that our colleagues and management depend on us to complete tasks correctly, reliably and on time.

A culture of innovation and responsible behaviour also encompasses a responsible approach to failure, should a method that has been meticulously devised and properly implemented prove unsuccessful.

In all countries and regions (not only those where alcohol consumption is prohibited), we have a policy of not consuming alcohol or similar substances during working hours.

It is also advisable to avoid excesses during business lunches and similar events.

Behaviour in the workplace

In our day-to-day interactions, we conduct ourselves in a courteous and professional manner towards our business partners, colleagues and employees. We are aware that our appearance and behaviour, both in words and deeds, create an impression of us and AM-BITS Group. We therefore always endeavour to act professionally and to adhere to the values set out in this code.

Labour standards

At AM-BITS Group, we are committed to minimising risks to people and the environment, as well as using resources efficiently. Safety is our primary concern. This ensures that all our products comply with the required Ukrainian and international safety standards. Furthermore, all our facilities comply with safety and environmental standards to prevent hazards to our employees.

The AM-BITS Group of Companies is opposed to the use of child labour in any form, whether by our own employees or by our business partners. In line with these principles, AM-BITS Group endorses the core standards set out by the International Labour Organization (ILO).

 

Violations of the Code

In the event an employee is observed violating the requirements of this Code of Conduct, please first bring it to the attention of their colleagues in a friendly manner. In the event of repeated violations or violations by a supervisor, please contact your supervisor, AM-BITS Group management or the Internal Control Officer (Olga Stroka, HR Manager). In the event that this is not possible due to personal circumstances, please refer to the ombudsman procedure.

It is the policy of the AM-BITS Group to eliminate violations and inappropriate business practices. It is therefore important to report any violations of the Code openly and directly, and for measures to be taken to resolve them.