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

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

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

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

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

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

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