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Code of Ethics and Conduct

Table of Contents

 

1. Introduction ………………………………………………………………………………………………..……..……..……..……..……..………….

3

2. Compliance with current legislation ……………………………………………………….……..……..……..……...…..……..…………

4

3. Presence in the halls – proper conduct and rules …………………………….……..……..……..……...…..……..……………….

4

4. Handling of cadaver specimens …………………………….……..……..……..……..…….…………………………….……..……..……

5

5. Health and Safety …………………………………………………………………………………..……..……..………………………..……..……

7

6. Protective Measures against the new coronavirus SARS-CoV-2 …………………………….……..……..……..……..…….…

7

7. Conflict of Interest …………………………………………………………………………………..……..……..………………………..……..….

8

8. Internal Information & Transactions based on the I.I. ……………………………….……..……..……….……..……..……..…..

9

9. Corporate Opportunities ……………………………………………………………………………..……..……..……..……..……..…………

9

10. Competition and Fair Behavior in Transactions …………………….……..……..……..……..……………………………………..

9

11. Anti-Bribery and Anti-Corruption ………………………………………………………………..…….…………..……..……..…………..

10

12. Prohibition of Grants to Political Parties …………………………………..…………..……..……..………………………..………….

10

13. Integrity and Honesty …………………………………………………………………….……..……..……..…………….…..……..…………

11

14. Anti-Discrimination and Anti-Harassment …………………………………………….……..……..…………..……..……..…………

11

15. Alcohol and Narcotics ……………………………………………………………………………………..……..……..……….……..…………

11

16. Environmental Protection and Reduction of Carbon Emissions …………………………….……..……..……..……..……..

12

17. Employee Personal Data ………………………………………………………………..……..……..……..……..…………………..……….

12

18. Continuous Training in New Technologies and Skills ………………………….……..……..……..…………….……..………….

12

19. Record keeping, Auditing and Notifications ……………………………..……..……..……..……..……………………………..…..

12

20. Confidentiality …………………………………………………………………..……..……..……..……..……………………………..………….

13

21. Security …………………………………………………………………………………………………..……..………..……..……..……..…………

13

22. Proper Use and Protection of Company Assets …..……..……..……..……..……..………………………………………….…….

13

23. Commercial Issues and Compliance …………………………………….……..……..……..……………………….…..……..…………

14

24. Code Waiver ……………………………………………………..……..……..……..……..……..………………………………………….………

14

25. Illegal or Unethical Behavior Reporting ……………………………………….……..…………………....……..……..……..………..

14

26. Directors Additional Obligations ………………………………………………………..……..………….…..……..……..……..………..

14

27. Compliance Procedures ………………………………………………………………………..…………..……..……..……..……..………..

14

  1. Introduction

 

The Anatomy Techniques & Training Center (ATTC), since its foundation, applies business practices based on integrity, reliability, honesty, transparency, fair trading and compliance with all applicable legislations. It is also committed to the implementation of these values and the Corporate Business Principles in all areas in which it operates.

 

The Code of Ethics ("the Code") of the Anatomy Techniques & Training Center (hereinafter referred to as "the ATTC") determines the continuous application of the Corporate Operational Principles by establishing non-negotiable minimum standards of conduct in key areas.

 

The Code applies to all employees and permanent collaborators of the ATTC, representatives of the ATTC, external partners such as suppliers and contractors, defining the ATTC’s standards for their ethical business conduct worldwide.

 

The Code covers a wide range of business practices and processes. The moral business models relate to relationships / transactions with ATTC employees, customers, suppliers, contractors and associates as well as its shareholders, society, governments, and government authorities wherever it operates.

 

Employees and executives of the ATTC may seek guidance when they are in doubt about the proper handling of a given situation and should avoid the slightest indication of inappropriate behavior as it is the employee's fundamental responsibility to do the right thing, a responsibility that cannot be denied.

 

Violations of Code behavior patterns are subject to disciplinary sanctions, the most serious of which may be termination of the contractual relationship with the ATTC. In addition, violations of the Code may also constitute violations of the Act with consequent civil and criminal penalties for employees, executives, and directors and / or the Company. If an employee considers that there is an eventual or potential future violation of the Code, he should follow the procedures set forth in Article 23 of the Code.

 

The Company is actively contributing to the promotion of the concept of Corporate Social Responsibility in the Greek and International Business Community. The ATTC is comprehensively compiling the ten principles of the "United Nations Global Compact" for human rights, labor, the environment, and anti-corruption.

 

By its nature, the Code does not have the ability to cover all situations that may arise in the future. It has been drafted in such a way as to provide a reference framework where any unattainable activity can be integrated and evaluated. From now on, wherever the Code refers to "employees" "staff" and "human resources", it comprises all those who contribute to Corporate Action through their contractual relationship with the ATTC, as employees, as associates, as executives, directors or members of the Board of Directors of the Anatomy Techniques & Training Center.

 

The following text clarifies and provides more detailed information on each of the key issues of the Code.

 

 

 

 

 

  1. Compliance with Current Legislation

 

The Anatomy Techniques & Training Center operates in Greece and complies with the applicable law of the Greek State.

Compliance with legislations "both on paper and in concept", is the basis on which the ATTC’s ethical standards are based. All employees must, in carrying out their business activities, obey and observe the applicable law in Greece. Although employees are not required to be familiar in detail with all applicable laws and legislations, it is important to be aware of this information that will guide them to refer to their supervisors, directors or other company entities for guidance.

Employees of the Company are required to act ethically in every area of their business and must maintain high standards of honesty, reliability, and integrity.

Additionally, they must adhere to statutory internal regulations and statutory standards, which may impose stricter requirements than those laid down by law.

 

  1. Presence in the halls – proper conduct and rules

 

The ATTC has the following meeting rooms, laboratories and lounge areas available for rent

 

2nd floor

Aula Conference Hall

Veranda lounge area

 

1st floor

Conference Rooms 1, 2 and 3

Board room

Simulation Center

 

Ground floor

Vesalius Lab

2 cloakrooms

Lounge area

 

-1 floor

Vitruvian Lab

2 cloakrooms

 

The below rules of conduct apply to all users of the ATTC rented areas (participants, visitors, sponsors, representatives, employees or guests).

 

General rules of conduct

 

 

Mobile phones, photographing and recording devices

These devices are for private use only, by their owners.

The ATTC does not allow their use to take photos, record or film material of the premises and other users, without their consent and does not allow the distribution, sharing or publishing of such material through the internet, social media, public platforms or other form of public domain.

The ATTC is not responsible should such behavior occur and the person that has proceeded to such actions is to bear the responsibility for them.

 

ATTC Visitors Wi-Fi service

Use of the ATTC Wi-Fi service is available to everyone present in the premises.

It is only allowed to use this service for professional, educational or medical reasons.

It is not allowed to use this service for recreational purposes.

 

Food and Beverages

It is not allowed to bring food or beverages to any areas within the ATTC premises, with the exception of the lounge areas.

 

Respect – Ethical Behavior

The ATTC demands from all those present in its premises to show respect and to display ethical behavior for their surroundings and towards other people present.

 

Penalty

Any individual present in the premises is to abide by the above rules of conduct. The ATTC reserves the right to remove the individual that does not abide or respect the above rules of conduct from the premises. In case the individual shows such repetitive behavior, the ATTC reserves the right to proceed to further legal actions.

 

  1. Handling of cadaver specimens

The ATTC organizes courses with hands-on practice on anatomical specimens (cadavers). The ATTC fully complies with current law regarding the handling and treatment of anatomical specimens, in an ethical, healthy, and secure manner. All information pertaining to the personal nature of each anatomical specimen is treated with confidentiality and discretion, before, during and after an event organized at the ATTC premises and this obligation is extended to ATTC employees, visitors of the facility, and to faculty and participants to events organized in its premises. ATTC employees, and any person that enters the ATTC premises is responsible for their own safety and should not proceed in acts that may endanger others and are mandated to respect and follow all health and safety rules, as well as to maintain ethical and respectful behavior towards anatomical specimens, during their stay at the ATTC premises.

The ATTC will handle any footage containing anatomical specimens that is distributed, published, or broadcasted for educational purposes in a proper and sensitive manner.

 

The ATTC does not allow employees or other persons present in its premises to take photos or selfies of anatomical specimens or to record videos that include anatomical specimens and furthermore does not authorize the use of social media for displaying any such image or video.

 

Food and beverages of any kind are strictly forbidden within the practical sessions areas.

 

Specifically, the below rules of conduct apply to all users of the ATTC lab areas (participants, visitors, sponsors, representatives, employees or guests):

 

Rules of conduct

 

 

Ethical behavior towards anatomical specimens

 

 

  1. Health and Safety

 

The ATTC adopts and promotes Health and Safety principles and standards in the work environment and furthermore has released relevant instructions, brochures and related information material to the staff, with the main purpose of always providing a healthy and safe work environment free of dangerous conditions or conditions that can cause physical harm.

 

Moreover, the ATTC takes adequate measures to prevent accidents and has established practices that prevent and address possible health risks and risks to the safety of employees. It also provides all employees with information on health and safety issues within the work environment and outside of it, which are responsible for creating and maintaining a safe and healthy workplace for all, in compliance with applicable laws and regulations, corporate standards and best practices according to the Statute No. 3850/2010.

With this scope, it encourages staff to report detailed descriptions of conditions, as well as any further concerns about possibly unsafe conditions or ventures with risk of injury.

 

In order to maintain a healthy and safe working environment free from hazardous or health-damaging conditions, the ATTC does not tolerate any form of violence or threat of violence within or in connection with the workplace or work environment. Employees who fall victim, witness or are aware of a violent or potentially violent behavior or situation at the ATTC's premises must report it directly to their supervisor.

 

Users within the lab areas

 

Specifically for the lab areas, the ATTC will make available PPE (Personal Protective Equipment) to all personnel entering the area where anatomical specimens will be present. The ATTC staff and personnel is responsible for always entering the lab areas wearing this protective equipment.

 

Definition of PPE herein:

 

  1. Protective Measures against the new coronavirus SARS-CoV-2

 

The ATTC has defined the following rules which constitute protective measures against the new coronavirus SARS-CoV-2. The below rules of hygiene apply to all users of the ATTC areas (participants, visitors, sponsors, representatives, employees or guests).

 

  1. It is required to use a face mask
    • When entering the building it is required to wear a face mask at all times throughout the premises
    • Wash your hands regularly with soap and water or use alcohol-based hand-rub

 

  1. Keep a safe distance from others (>1.5 meters)

 

  1. Avoid handshakes and any physical contact
    • Limit the time you meet or talk with other people

 

  1. Use the mask correctly and safely
    • To place or remove the mask from your face hold it by the laces
    • Apply the mask correctly to your face
    • Cover your mouth, nose and chin
    • Make sure that the mask covers your nose and mouth completely
    • Adjust the metal nose clip and tie tightly
    • Do not touch the outer surface of the mask
    • Do not lower the mask

 

  1. Wash your hands regularly with soap and water or use alcohol-based hand rub
    • When entering the building
    • When coughing
    • After throwing away a used tissue or a mask
    • After coming into contact with common areas or objects
    • After removing your gloves
    • Before any contact with your face

 

  1. Avoid unnecessary use of gloves
    • Using gloves does not replace the need for hand hygiene
    • Do not touch your face, mask, clothes, hair, mobile phone or personal items with your gloves
    • Do not touch surfaces or objects within the premises with used gloves

 

  1. If you experience coughing, sneezing, runny nose
    • Cover your cough with your elbow or a tissue
    • Wash your hands
    • Make sure that you wear your mask correctly
    • Keep a safe distance from others (1.5 meters)

 

  1. Conflict of Interest

 

"Conflict of interest" exists when the personal interest of an employee interferes or opposes in any way or appears to interfere with or opposes the ATTC's interests.

 

Such a conflict may arise when an employee of the Company takes action or has interests that make it difficult both to make an objective judgment and to effectively perform his or her duties, or when an ATTC employee, a relative or a close associate inappropriately collects personal benefits due to his/her position in the ATTC.

 

Loans or credits given by the ATTC to an employee, a relative or close associate or guarantees of such loans or credits may lead to a conflict of interest and in some cases are prohibited by law.

 

An employee in the ATTC may not simultaneously offer his / her services to a competitor, customer or supplier and must avoid any direct or indirect employment relationship and / or transaction with the ATTC's customers, suppliers or competitors other than the required and reasonable actions to fulfill the duties he/she has undertaken for the benefit of the ATTC.

 

Any act that may cause a conflict of the employee's personal interests with the interests of the ATTC is prohibited by corporate policy unless previously approved by the ATTC's Board of Directors. The Company requires its employees to disclose any situation that could reasonably lead to the creation of such a conflict of interest. Cases of conflict of interest may not always be clear. However, any employee who takes notice of such a case, or the possibility that such a case may occur, must notify his/her supervisor or director or other responsible employee of staff management staff and consult the Code, Article 19 in particular, which defines the procedure to be followed in order to resolve the situation fairly and in a transparent manner.

 

  1. Internal Information & Transactions based on the I.I.

All non-public (not available to the public) information relating to the ATTC, its customers, or its affiliates and suppliers is called "internal information" and is protected by confidentiality as an ATTC asset.

 

Employees and members of the ATTC's personnel who, in the course of their duties, have access to confidential information or have become aware of confidential information about the ATTC or other legal entity due to their relationship with the ATTC, may not use, exploit or disclose these in order to make investment decisions, decisions to buy or sell shares in the ATTC or any other action and purpose other than Corporate action. Using internal information for personal gain or disclosing it to a third person or party in order to proceed to an investment decision is immoral and illegal.

 

Similarly, disclosure of internal information to a friendly person or next of kin or associate or affiliated person is strictly prohibited unless the person in question is authorized to receive knowledge of such confidential information, e.g. having a signed in in effect contract of confidentiality with the ATTC.

 

  1. Corporate Opportunities

Employees are prohibited from using the ATTC's property, knowledge information or the position they are holding within the ATTC for their own benefit and are also forbidden to take advantage of opportunities presented to them in the course of their duties while making use of the ATTC's property, or the information they acquire or the position they hold within the company, without the consent and approval of the ATTC's Board of Directors.

 

They must also in no way compete against the ATTC either directly or indirectly and have a duty to always promote the ATTC's interest when the opportunity to do so arises.

 

  1. Competition and Fair Behavior in Transactions

The ATTC strives to achieve its goals through high performance standards, developing and delivering top quality products at competitive prices compared to its competitors, always using legitimate means, always acting honestly and avoiding any unethical or illegal business practice.

 

It is forbidden to steal proprietary information or distribute business confidential information obtained without the consent of the owner, or to cause such notifications, both by active employees of the ATTC, as well as by former employees of the ATTC.

 

Every employee must respect the rights and deal fairly with other employees within the ATTC as well as with its customers, suppliers, contractors, and competitors.

 

Employees of the ATTC are not permitted to unfairly profit by anyone, either by manipulating or concealing or exploiting privileged information or distorting facts, or through other illegal business practices.

 

An ATTC employee is not permitted to engage in price negotiations, fraud in sales offers, agreements on share sales and distribution of purchases or clients, and generally in any illegal activity or unethical practice that prevents healthy competition.

 

  1. Anti-Bribery and Anti-Corruption

The ATTC condemns all kinds of corrupt business conduct and any form of bribery.

 

No person acting on behalf of the ATTC may offer or provide (directly or indirectly) any form of unfair advantage or other advantage to a person or legal entity in the private or public sector with a view to securing or maintaining or to expand business activity. By extension, it must not accept any such advantage in exchange for any privileged treatment associated with it.

 

Additionally, any employee, executive, or member of the ATTC's Management must refrain from any activity or conduct that could give rise to the appearance or suspicion of such a transaction or attempt to do so.

 

Promise, offer or provision of a gift to a public officer of the Greek or Foreign State, payment or other benefit in contravention of the rules of this Code is not only contrary to ATTC policy but may be a serious civil and / or criminal offense.

 

Employees of the ATTC must be aware that a promise, offer or inappropriate benefit to influence the decision of the recipient even if it is not a public official not only incurs disciplinary sanctions but may lead to criminal or civil proceedings against both the ATTC and its employees. Inappropriate benefits include gifts, payments, favorable behavior or treatment or other kind of benefit to the recipient, including employment contracts or consultation services with persons or associates of a close family environment or friend environment.

 

  1. Prohibition of Grants to Political Parties

ATTC employees must be aware that laws as a rule prohibit corporate contributions to political organizations, parties, committees, or candidates. The ATTC has embraced a policy of prohibiting such grants.

 

The ATTC prohibits contributions to political parties or candidates, whether made directly by the ATTC or any of its business units or its subsidiaries, or through trade associations in which the ATTC participates.

 

This prohibition applies to: (a) any financial contributions or contributions of other ATTC assets for political purposes; (b) encouraging employees to make any such contribution at an individual level; or (c) rewarding an employer for such actions.

 

Only on a personal level are employees free to act in this area at will, and to make such grants and contributions.

 

  1. Integrity and Honesty

When performing their duties, employees in the ATTC must always act with the utmost honesty and integrity.

 

Every employee, executive or member of the management must always act with integrity and honesty, respect the rights of customers, suppliers, associates, and competitors.

The ATTC's directors and those involved in the management of the ATTC, employees and staff are required to inform the ATTC of any legal proceedings that have been brought against them, especially if they concern matters related to Corporate Procedures. Furthermore, employees of the ATTC must immediately notify the ATTC if they are accused of committing a criminal offense and provide the ATTC with any additional information requested on the matter.

 

  1. Anti-Discrimination and Anti-Harassment

The ATTC prohibits and does not tolerate discrimination in the recruitment process or the determination of pay or access to training or the development or promotion or termination of an employment relationship or retirement based on sex, color, age, place of origin, number of years working for the company, social class, political beliefs, nationality, citizenship, religion, sexual orientation or disability.

 

The ATTC provides equal opportunities in all forms of employment in accordance with current legislation and prohibits child labor by adopting the principles of the Greek Statute No. 1837/1989 and the Statute No. 2101/1992.

 

Additionally, the ATTC does not participate in and does not use or tolerate the phenomena of forced labor, corporal punishment, mental or physical coercion and verbal abuse of employees, and condemns them, always respecting human dignity, confidentiality and personal rights of each employee and is committed to maintaining a non-discriminatory workplace as well as condemns all kinds of moral harassment.

 

As a result, the ATTC does not tolerate any kind of unlawful discrimination, verbal or physical or moral harassment based on gender, color, age, place of origin, number of years working for the company, social class, political beliefs, citizenship, religion, sexual orientation or mental disability, nationality, membership in a union, political cooperative, physical or mental disability, state of health or marital status.

 

Employees who feel that their workplace does not comply with the above principles are encouraged to report their concerns to the Administration.

 

  1. Alcohol and Narcotics

The ATTC is committed to maintaining a healthy working environment free from illegal substances. All employees must strictly comply with the ATTC's policies relating to the use of alcohol and the possession, sale, handling or use of all illicit substances. It is forbidden to drink alcohol at work or within the ATTC's premises, except for specific events that take place after approval by the Administration. In any case, the possession, use, sale or distribution or supply of illicit narcotics or other illegal substances is prohibited during work or within ATTC premises. Additionally, it is forbidden to go to work, or to drive a corporate vehicle under the influence of alcohol or any illegal narcotic or banned substance.

 

  1. Environmental Protection and Reduction of Carbon Emissions

The ATTC is sensitive to environmental issues and encourages its staff and partners to always adopt within and outside the workplace the best practices of a responsible consumer to reduce pollutants and carbon dioxide emissions. Employees, staff, customers, and partners are informed through corporate communications, newsletters and events to maximize natural resource savings, recycle waste and reduce pollutant emissions, actively supporting recycling practices and energy saving measures.

 

If an employee is unsure of his or her responsibility or duty based on the above, he/she must seek help and guidance from his/her supervisor or manager or staff manager.

 

  1. Employee Personal Data

The ATTC deeply respects human dignity and personal data of its staff and former employees. For this purpose, only information referred to in the Personnel and Associate Resume, required by the Authorities or those details that contribute to the effective operation of the ATTC, are requested and maintained. Information of this nature and, in particular, personal data of employees are considered confidential and only the authorized personnel has access to them.

 

The ATTC administration keeps an individual file for each employee, which records the required data such as past employment records, identification and certificates of education, vocational training, and specialization. The type and manner of keeping these records and files is determined by the ATTC's Management and is perfectly legal with the applicable law, and any collaborator or employee having access to the personal records and personal data of employees is bound by confidentiality indefinitely and after any termination of his/her employment relationship with the ATTC, unless otherwise provided by law or by a Public Authority or by a Court.

 

  1. Continuous Training in New Technologies and Skills

The mentality of the ATTC is summarized in the continuous enhancement of its human capital, i.e. the cognitive level and skills of its personnel, which ensures that is maintained in high levels of competitiveness in relation to the continuous technological developments, possessing the ability to innovate through the acquisition of new skills technical and vocational training, etc.

 

To this end, the ATTC encourages, urges and endeavors to finance its staff to participate, for example, in educational seminars, in obtaining technical and vocational training certification, etc. The Company is of the belief that its own development is inextricably linked with the development and improvement of the employee's capabilities.

 

The Company offers its employees education and training opportunities through educational programs and seminars, on the job training and rotation, through reorganization and job developments, extensions of responsibilities, etc.

 

  1. Record keeping, Auditing and Notifications

ATTC employees are required to prepare documents, reports and memos in a timely manner and with due care and to check the completeness and correctness of the information they provide in order to enable responsible and sound business decisions to be made by the management body.

 

Each corporate expense must be documented and recorded in a timely and accurate manner. If there is any doubt as to the legitimacy of a specific expense, employees should contact the ATTC Administration where they will be provided with the required information.

 

All records, accounts, financial data, and financial statements of the ATTC must be kept in detail and accurately reflect the ATTC’s transactions. They should also be immediately disclosed when required by law, as well as be in line with the corporate internal control system and applicable law.

 

Often corporate records and communications are made public. To avoid misunderstandings, this should be done without exaggeration, negative comments, speculation or inappropriate descriptions of persons or legal entities. This also applies to e-mails, internal memos and official reports or documents.

 

Records must always be either maintained or destroyed in accordance with corporate policy and applicable tax, accounting, labor, and insurance legislation.

 

  1. Confidentiality

Employees and ATTC staff are required to discretely handle the confidential information disclosed to them by reason of their relationship with the ATTC, that are about the ATTC, its clients, suppliers, associates, contractors or competitors and to always and in any way avoid, prevent the unlawful disclosure of such information unless this is approved in writing by the Board of Directors or required by law or by a court. The obligation to preserve confidential information is binding even after termination of employment or in any way termination of the relationship even if otherwise provided by the contract in question.

 

Confidential information is defined as the information available to the ATTC, or information that the ATTC's suppliers and customers have trusted the ATTC with it, as well as any non-public information the disclosure of which could be harmful to the ATTC, its customers, its suppliers, contractors or associates, or to be useful to its competitors or against the ATTC's interests.

 

  1. Security

The ATTC has an access control system within the ATTC's buildings so that only authorized employees can have access to confidential information. Furthermore, the company's facilities are also supervised 24/7, by a private security company and systems, to prevent any unauthorized removal or theft of confidential information. All employees must be informed regarding the existence of Security Procedures and any certifications available to the ATTC and comply with the requirements and prerequisites for such certification.

 

  1. Proper Use and Protection of Company Assets

All employees of the ATTC must protect the ATTC's assets and ensure their efficient use.

 

Embezzlement, negligent handling, and waste of these have a direct impact on the ATTC's profitability and viability. All Company assets should only be used for legitimate, appropriate, and authorized business purposes. Any possible occurrence of fraud, theft, embezzlement, or improper use should be reported directly to the Administration in order to investigate and take appropriate action, by notifying the competent authorities, e.g. the Police.

 

The ATTC's assets may not be used for non-corporate affairs or activities except prior approval of the Board of Directors. Employees should not seek or perform non-corporate business transactions for their own benefit without the prior notification and approval of the Board of Directors during paid employment.

 

ATTC assets that are subject to employee protection include property information such as the design and implementation of customer solutions that are intellectual property and constitute a reputation for specialization and subsequent attraction of such customers, clients, suppliers, contracts, contacts and all kinds of commercial information relating to them for past, present and ongoing projects, all trade secrets and know-how, trademarks, copyrights, as well as business co-operation and co-operation plans, marketing and shareholder information and capital markets, engineering and construction ideas, plans, databases, records, salary data, personnel files and personal data, and generally any unpublished financial data, internal business performance analyses and reports. The misuse or dissemination of this information is taken as a breach of corporate policy and constitutes an offense incurring both civil and criminal sanctions.

 

  1. Commercial Issues and Compliance

The trade embargo or other commercial sanctions imposed on governments or regions by the Greek Government, other states, the European Union or the United Nations must be respected. The Administration of the ATTC is in a position to provide proper information on the current situation in relation to any such issues that may arise.

 

  1. Code Waiver

Any waiver of this Code by senior executives and directors of the ATTC is permitted only if it has been approved by decision of the Board of Directors and is immediately communicated as required by applicable law.

 

  1. Illegal or Unethical Behavior Reporting

Employees and staff are encouraged to address openly to supervisors, directors, Human Resources Officers, Legal Services on a case-by-case basis to best deal with phenomena of identified or likely or doubtful violation of the Code, Corporate Policy or applicable law.

 

It is an ATTC policy not to allow third party retaliation or unfavorable treatment of personnel who in good faith make such reports for the protection of the ATTC's interests.

Furthermore, employees have to offer their cooperation during an internal investigation of such cases.

 

  1. Directors Additional Obligations

Company directors, in addition to their responsibility as employees and their duty to act in a fair and equitable judgment, should behave by presenting a good example, by inspiring respect towards their employees with a standard of professional ethics, demonstrating honesty, integrity, sincerity, always protecting corporate interests and never operating for their own benefit, reinforcing the morale of staff, always respecting the rules of decency, courtesy and dignity, morals and exercising their business activity in an, ethical, honest and fair manner. They must promote open and honest two-way communication with employees in order for employees and partners to know what the ATTC expects in terms of performance from them and how they expect that they contribute to the ATTC's goals, to be able to easily seek guidance and help solving problems as well as information related to the Code.

 

  1. Compliance Procedures

We must all constantly ensure that the provisions of the Code are applied in an uninterrupted manner and consistently and that they are not breached.

 

However, sometimes it is not easy to distinguish right from wrong. Employees must always be guided in their decision-making by the following basic principles:

 

  1. Avoid any behavior that could harm or compromise the ATTC or its reputation.
  2. They act legally and honestly.

III. They put the ATTC's interests above their personal interests.

 

Since it is not possible to predict any possible future situation, it is important to have a way of approaching and evaluating new data or problems.

 

These are the logical steps recommended:

(a) Make sure you have all the data. In order to make the right decision, we need the fullest possible information.

 

(b) Ask: What am I specifically asked to do? Can it be considered unethical or inappropriate? This will allow you to focus on the specific problem and any alternative treatment options. Use your common sense and judgment as if something seems unethical or inappropriate, it might well be.

 

(c) Discuss the problem with your supervisor or manager. This is the fundamental principle for the correct handling of any situation. If you feel uncomfortable discussing your problem with your Chief Executive Officer or Director, you can contact the Legal Advisor, the Chief Executive Officer or the Human Resources Officer.

 

(d) You can report any violations, confidential and without fear of retaliation. If handling a given situation requires that your identity be kept secret, then your anonymity will be protected. The ATTC prohibits retaliation of any kind against employees who in good faith have made reference to possible violations of the law, the Code or ATTC policy.

 

(e) First ask, make sure and then act. If you are not sure about your choice, look for help before you take action.

 

The Code applies to all ATTC manpower, employees and associates and defines internal control procedures in case of violation of these principles.

 

Human Resources should be aware of, comply with these principles and procedures and encourage external partners, customers and suppliers to follow the principles of professional ethics.

 

Those who violate the Code are subject to sanctions that, depending on the gravity and risk of their offending conduct, may include disciplinary proceedings, termination of their employment relationship with the ATTC for great cause, claim for compensation for any positive and consequential damages, or even criminal prosecution, in accordance with the applicable law.

 

In order to ensure compliance with this Code of Conduct, the Code is posted on the ATTC website and the ATTC invites all those who comprise its manpower, employees, associates, customers and suppliers to be informed on all the provisions of the Code of Conduct.

 

On behalf of the ATTC Administration

Mrs Tatiana Zombola

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