Universuss Code of Conduct

Universuss, wanting to promote a sustainable business, has developed guidelines to ensure a responsible and ethical business environment. The Code of Ethics defines the requirements for Universuss, its employees and business partners to ensure compliance with ethical, social and environmental responsibility. The Code of Ethics applies and is binding on all companies in the Universuss Group, their employees and business partners. The Code of Ethics is applicable to all Universuss business partners and is considered an integral part of the agreements concluded with business partners.

Business Principles
Compliance with laws and regulations

Universuss operates in accordance with applicable laws and regulations. Universuss employees know and properly follow the requirements of the laws and regulations, as well as internal rules and guidelines applicable to their field. Every employee shall immediately report any violations of the laws and regulations or internal rules and guidelines they notice during work. Universuss business partners shall act in compliance with applicable laws and regulations, as well as this Code of Ethics.

Prohibition of corruption and unfair competition

Universuss follows the principle of fairness in each and every business transaction. Any form of extortion, bribery and/or corruption, including giving or receiving of bribes, tangible assets, property or other benefits
from employees, business partners, state and local authorities or any other person, shall be prohibited.
If Universuss employees find themselves involved in a bribery attempt, or attempts of improper influence by external third parties are suspected, the employee shall immediately notify their direct supervisor and the Universuss management thereof Universuss shall not accept corruption and dishonest business practices. Universuss shall not accept or offer any property or other benefits that could affect a person's ability to make objective and fair business decisions. Universuss shall not cooperate with the companies who violate laws and regulations or try to influence Universuss employees or other persons through bribery.

Universuss shall observe fair and ethical competition in compliance with the laws and regulations and expects the same from its business partners. Any agreements or arrangements with buyers and suppliers that limit competition are prohibited.


Universuss business partners shall take the utmost care to ensure the security and protection of confidential and trade secret information received from Universuss, and not disclose or otherwise pass it onto third parties.

Prevention of conflicts of interest

Universuss shall avoid situations where private or individual financial interests conflict with the interests of Universuss or its business partners.

The powers conferred by Universuss may not be used for purposes other than the performance of the Universuss tasks and the defence of its interests.

Data protection

Universuss shall process personal data only to the extent permitted by the applicable laws, in compliance with the principles of lawfulness and good faith.

Universuss and its business partner shall ensure that personal data is processed with appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction or damage, through appropriate technical or organizational measures.

Human rights and labour rights
Human rights

Universuss shall respect, and business partners who provide services or sell goods to Universuss shall also respect internationally proclaimed human rights and guarantee that they are not involved and will never be involved in violations of human rights.

Child labour

Universuss and its business partners providing services or selling goods to Universuss shall under no circumstances employ children under the minimum age provided for in laws and regulations. Minimum age is the age when the person has completed compulsory general education, or no younger than 15 years (or 14 years where the laws and regulations of the country permits). Children who have reached the minimum legal age for employment shall not be employed in any hazardous work conditions or perform work that can harm the child's personal growth, morality or development.

Forced labour

Universuss and its business partners providing services or selling goods to Universuss shall not use forced labour. Forced labour means any work or service which a person is compelled to carry out due to any threat of punishment and to which the person has not voluntarily consented.

Prohibition of discrimination

Universuss and its business partners providing services or selling goods to Universuss shall treat their employees with respect and provide fair and equal opportunities for development. All forms of direct or indirect discrimination shall be prohibited, in particular on the grounds of race, colour of skin, sex, age, disability, religion or political belief, national or social origin, or sexual orientation. Direct discrimination exists where, in a comparable situation, a person is, has been or may be treated less favourably than another person in relation to any of the above or other circumstances.

Indirect discrimination exists where a seemingly neutral rule, criterion or practice causes or is likely to have adverse effects on individuals in relation to any of the above or other circumstances, unless such rule,
criterion or practice is objectively justified by a legitimate aim for which the means chosen are proportionate. Harassment of a person and instruction to discriminate against him or her shall also be considered to be discrimination.

Work environment

Universuss and its business partners providing services or selling goods to Universuss have the right to a safe and healthy workplace environment. Universuss and its business partners providing services or selling goods to Universuss shall take responsibility for implementing labour protection requirements in their company. Violations of labour safety standards specified in the effective laws and regulations shall not be
permitted at workplaces. Universuss and its business partners providing services or selling goods to Universuss shall ensure that all employees receive information and training in labour protection in order to be able to perform their work duties in accordance with occupational principles of labour protection.

Environmental protection

Universuss and its business partners providing services or selling goods to Universuss shall support precautionary measures to environmental issues and undertake initiatives to promote greater environmental responsibility.

Minimum requirement – Universuss and its business partners shall comply with all environmental protection requirements specified in the laws and regulations, environmental permits or other applicable regulations.

Universuss shall support the development and dissemination of environmentally friendly technologies and call on business partners to implement and maintain a system of best practices within the company to manage environmental issues and their impacts and achieve systematic mitigation of environmental impacts.

Application of the Code of Ethics

Universuss employees shall organise their work and act in accordance with the principles provided for in this Code of Ethics, the internal guidelines and procedures of the company, as well as conventional norms of conduct and morality. Universuss business partners shall follow the principles provided for in this Code of Ethics, as well as conventional norms of conduct and morality, and ensure that their subcontractors also follow these norms.

Universuss may verify and monitor compliance with this Code of Ethics. It is the responsibility of the business partner to allow duly accredited auditors or audit firms representing Universuss to conduct audits of their companies to verify the compliance with the Code of Ethics.

An Universuss employee and Universuss business partner shall immediately notify Universuss of any violations of this Code of Ethics. Universuss shall not allow an employee to be penalized or otherwise adversely affected, directly or indirectly, as a result of reporting such violations.

Any violation of the Code of Ethics shall be properly investigated, and any significant violation of the Code of Ethics may result in termination of the employee's employment relationship with Universuss, as well as termination of the business relationship with the business partner.

Non-Discrimination and Anti-Harassment Policy

Pursuant to the Convention for the Protection of Human Rights and Fundamental Freedoms1, realisation of human rights and fundamental freedoms shall be secured without any discrimination on any ground such as sex, race, colour, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status.

Also, the UN Sustainable Development Goals2 pursue social, economic and political inclusion of all people regardless of their age, sex, disability, race, ethnicity, origin, religious beliefs, economic or other status by 2030. The goals strive to ensure equal opportunity and reduce inequalities of outcome, including eliminating discriminatory laws, policies, and practices and promoting appropriate laws, policies, and action in this regard.

Being aware of the importance of human rights, the Universuss group has drawn up its Non-Discrimination and Anti-Harassment Policy (hereinafter the "Policy"), which the Universuss group follows itself and asks its suppliers and business partners to follow, thus ensuring the application of the principles of this Policy across the whole supply chain.

Anti-Corruption and Conflict of Interest Prevention Policy

Pursuant to the Civil Law Convention on Corruption1, corruption represents a major threat to the rule of law, democracy and human rights, fairness and social justice, hinders economic development and
endangers the proper and fair functioning of market economies. The United Nations Global Compact2 stipulates that businesses should work against corruption in all its forms.

Environmental Policy

The UN Global Compact1 stipulates that businesses must take care of the environment and promote environmental responsibility, as well as they must promote the development and use of environmentally friendly technologies. At the same time, the UN Sustainable

Development Goals2 require to:
- protect and restore terrestrial ecosystems, promote their sustainable use, manage forests sustainably, prevent land degradation, promote its restoration, and halt biodiversity loss;
- ensure sustainable consumption and production patterns;
- take measures to combat climate change and reduce its impact