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Sugar Factory Osijek ltd. produces white crystal sugar by processing sugar beet and refining raw sugar. Produced sugar and by products meet the highest industry standards .

Principles of Business Conduct PDF


(Business Conduct Guidelines)


A1. Acting in accordance with the law

First and most important principle for our company states the necessity of treatment of our employees in accordance with legal regulations. Each employee is required to prevent at all costs unlawful conduct, especially in the case of misdemeanors punishable by a prison or a fine (eg tax offense, offense against the security of persons and property, theft, etc.). Every employee in the case of violations, which violate employee  obligations under a contract of employment, must reckon with disciplinary consequences - regardless of the sanctions provided by law.

A2. Responsibility for the company's reputation

The reputation of our company is greatly affected by performance, actions and behavior of each of us.
Even the inappropriate behavior of a single employee can cause great damage to our company. Therefore, each employee is expected to take into account the social reputation of our company, and therefore when performing job duties, each employee shall act in a way to take care about the reputation of our company

A3. Respect for personal dignity and integrity

Our staff respects personal dignity and privacy rights of every individual, regardless of gender, nationality, culture, religion and skin color. Nor in any form does not accept discrimination, sexual or otherwise personal insult. As a reliable partner and odogovoran give only those promises that we can actually accomplish. These principles apply as for cooperation within our company and conduct our partners and the public.

A4. The principles of leadership, accountability and oversight

Each manager must gain the confidence of entrusted employees,  based on their own exemplary behavior, performance, openness and social responsibility.

The manager sets a clear, ambitious and realistic goals for employees and guides them by giving them maximum possible responsibility and space to achieve the goals.
Trust between manager and employees should be such that employees may at any time contact him in case of business and personal problems.
Each manager must meet organizational and supervisory duties. He is responsible for ensuring that in his area of responsibility does not come to any violation of laws and internal procedures, which could prevent or hinder appropriate supervision. The manager is equally responsible in case of delegating the specific tasks to staff.

In this respect the following rules apply:

1. The obligation of the selection – Manager performs selection of employees according to their personal and professional qualifications, with special attention given to
Selection of employees who will perform the important work jobs/tasks.
2. The obligation of making - Manager is obliged to define job tasks accurately and completely, emphasizing particularly compliance with statutory requirements
3. The obligation to control legality - The manager is required to continuously ensure the implementation of positive legislation, particularly the provision of safety at work.
4. The obligation to sanction - Managers must make clear to employees that violations of law and internal procedures will not be tolerated and will have employment related and legal consequences.

B) relationships with business partners and third parties

B1. Compliance with the provisions of the Competition

Each employee is required to comply with the rules of fair competition. Assessment in accordance with the provisions of the Law on the Protection of Competition can sometimes be problematic, and yet there are still behaviors that represent a violation against the provisions of the Law on Protection of Competition (for example, employees may not have talks with the competition in which prices or capacity are agreed). In particular, the illegal agreements with competitors to abandon the competition, the delivery of bogus offers for bidding, or the division of customers, regions or production programs. In relation to our customers, employees shall not influence or attempt to influence the prices for resale, nor should they try to achieve a ban on exports or imports.

B2. Offering and Granting Advantages

The main motto of our company is that for new customers / orders we compete with the quality and prices of our products and services. No employee shall offer or grant unjustified benefits to customers in connection to particular affair, either directly or indirectly, and neither in the form of money or other counter-favors. Promotional gifts for business partners must be selected so that the recipient may not incur the slightest impression of immorality and unfairness. In case of doubt, recipient of gift should ask his superiors to obtain prior permission for the gift. If the recipient acts in opposite, it shows that he himself reception of  the gift considers improper. Civil servants and other officials shall not be given any gifts. Employees who sign contracts with consultants, brokers, agents, or similar third parties must take into account the fact that they do not provide or grant unjustified benefits to our employees.

B3. Demanding and Accepting Advantages

No employee shall use his official position to demand, accept, obtain for himself or ask for benefits to be promised , directly or indirectly, and neither in the form of cash or other form of counter-favors. This does not include occasional gifts of insignificant value, while all other gifts must be refused and / or returned with the proper explanation relating to our business and Corporate behavior.

B4. Special Rules for Awarding Contracts

We believe that everyone who is competing for a contract, expect from our company that we will honestly and objectively examine his offer. Employees who are engaged in the awarding contracts must particularly abide by the following rules:

  • the employee must notify their supervisor of any personal interest that may exist in connection with the implementation of its work tasks.
  • suppliers in competition for contracts should neither  unfairly  prefer nor hinder.
  • Invitations from business partners may only be accepted if the occasion and scope are appropriate and if rejection is not in line with the rules of cultural behavior.
  • Gifts from business partners must be refused or returned, unless if they are insignificant and occasional gifts of small value.
  • no employee shall engage private enterprise for own private purposes with which he has an official business cooperation, in order to  gain some personal benefits. This is true especially when employee has or may has direct indirect impact on awarding contract to that particular enterprise in order to do any job for our company or any associated company to us.
  • every employee is required to promptly notify their supervisor in any potential case of conflict of interest

B5. Donations

Our company, as a socially responsible company, provides financial and material donations for education, health, science, art, culture and social purposes.
Various organizations, institutions and organizations turn to us with requests for donations.

For granting donations, the following rules apply:

  • individual requests for donations must be rejected in general
  • payments at private accounts are not permitted for any donation
  • donations can not be granted to organizations or individuals that could damage our reputation or can damage social morality and have a negative perception in society,
  • The donation must be transparent. Recipient of donation and  actual purpose of donation must be known prior to granting process.

Reasons for granting donation and practical use of it must be provable at any time.

  • tax deductible donations are preferable.
  • Quasi-donations are not in accordance with the principles of transparency and are therefore prohibited, because they look like donation, but in reality they represent compensation for performed service or work.

C) Avoiding Conflicts of Interest

For an efficient and fair conduct of their jobs, our workers must not be in the interests and loyalty conflicts. Such conflicts can occur if an employee works for another company or has interests in it. For this reason, for all of us, the following rules apply:

C1. The Clause on unfair competition

It is forbidden to manage a company which is in complete or partial competition with our company or companies that are part of the Group.

C2. Shares in companies that are not listed in the Stock exchange

It is forbidden to have direct or indirect interests in a company not listed on the Stock Exchange, which is in complete or partial competition with our company or companies that are part of the Group. Prior written permission is required to hold the shares  in the following the following companies (regardless of the quotation):

  • in companies with which our company or companies that are part of the Group cooperate
  • in companies that are market leaders in the activities being performed by our company or companies of the Group;
  • in companies in which our company or companies that are part of the Group, directly or indirectly have more than 20% of voting rights;
  • Company management gives prior consent for holding shares and it is recorded in the personal file of employees.

Permission is not given or can be withdrawn if an employee, as part of their work, cooperates with the company in concern.

The same applies if the employee can influence the business policy of the company, which are an integral part of the Group, in relation to that company for which employee works.

If any member of immediate family or employee have a stake in the competitor company or in any of the above and described companies, the employee (if he knows of) - has to inform in written form department of human resources and information given remains recorded in his personal file.

C3. Perform additional activities

The employee must inform their supervisor by prior written notice in case of engagement in additional activities for which he receive compensation. The additional activity may be banned if leads to a decrease in employee performance, if it is in contrary to employees’ obligations to the company or if there is a risk of collision of interests. This rule does not apply for occasional activities (writing articles, etc.), lectures and other similar activities.


Apparatus and equipment in offices and workshops (eg phone, fax, copier, personal computer including software and internet / intranet, machines, tools) are permitted to be used only for official purposes. Exceptions of this rule and compensation for using company equipment is regulated by special decision of the competent authority of the company. With regard to using  IT equipment, especially is emphasized prohibition of downloading or forwarding information which refer to hatred of other races, the glorification of violence, and sexual indecency or incite criminal acts or other content which is unmoral within understandings of culture in question. No employee shall create plans, files, video and audio copies, without consent of the managers, if that are not directly influenced by his work assignments.


E1. Records and reports

For an honest and efficient co-operation complete, timely and credible reporting is required. This is true both in relation to investors, employees, customers, business partners and in relation to the general public and all governmental bodies. All records and reports, which are produced internally and distributed externally, must be accurate and truthful. In accordance with the principles of proper bookkeeping, data and other records must be complete, accurate, timely and in accordance with the law. The rule regarding the true worth of data also apply for the calculation of costs (travel, etc.) and other rights for which workers have right to compensate from company.

E2. Confidentiality

Company’s internal affairs and information which are not given to the public must be kept confidential. This applies primarily to the details concerning the organization of the company and equipment, business procedures, production data, information about status of  research and developmental project, the internal reporting figures, numerical date of internal reporting, personal data of employees, their economic rights and the status and relations with business partners. The obligation to maintain such confidentiality shall extend beyond the termination of employment.

Communication of business events and business information is strictly prohibited and punishable to people outside the company as well as to individuals within the company which, who are not authorized to communicate such information. This also applies to the dissemination of information, especially the false and malicious, both about our workers and company as a whole and business partners and competitors.

E3. Data protection and data security

An essential prerequisite for the effectiveness of each of us and for business success in general is to have access to Internet and Intranet, to global electronic information exchange and electronically   supported business activities. The advantages of electronic communication are associated with risks in regard to privacy and data security.

Effective prevention against these risks is an essential component of IT management, tasks of management and the behavior of each individual. Personal data can be collected, processed or used only if there is  necessary for a pre-determined, clear, and legitimate purposes. High standard must be guaranteed for data quality and technical safeguards against unauthorized access.

For individuals required to provide their personal data, must be transparent and clear for which purpose data will be used, and also their rights to information and correction and possibly a complaint, blocking and deletion of provided data must be guaranteed.

All employees are obliged to comply with internal procedures related to work on the Internet and Intranet, as well as the use of IT equipment and software, particularly in the area of data protection and information systems of company

E4. The rules regarding the internal (insider) information

People who have internal (inside) information regarding our company or companies that are part of the Group shall not trade in securities of companies listed on stock exchanges or in free trade. Internal information is any information not known by the general public, suitable for investors' decision making about buying, selling or keeping any security. In order to avoid even the suspicion of a violation of the rules of inside information (insider rules), members of the highest circle of management shall not perform any operations with securities of our company or companies that are part of the Group in a period of two weeks before the end of the quarter until two days after the publication of quarterly results, and for a period of two weeks before the end of fiscal year two days after publication of the results of the last fiscal year. This also applies to employees of the Concern who at the basis of their job duties or functions have access to financial results not yet published. Internal (insider) information must not be given to unauthorized persons outside the Group (eg, journalists, analysts, customers, consultants, family members or friends). This information are allowed to be given within the Concern/ Group only if the recipient of this information really needs such information for the accomplishment of his job duties. In addition, it must be ensured that internal (insider) information are kept safe against access of unauthorized persons. People who have (insider) information are not allowed to give advice for investing in securities.

In addition, one should bear in mind the fact that mangers are personally liable for damages made by violations of internal (insider) by an employee,  if that damage could have been prevented bye proper supervision and / or internal procedures.

F) Environment, Safety and Health

F1. Environmental and technical safety

Protecting environment and conserving natural resources are social objectives with high priority for our company. In development of our products, important goals must be to design in a manner that is not harmful to the environment, technically safe and health protective. Every employee must work on these areas in order to be an example to others.

F2. Safety at Work

Responsibility to employees and colleagues requires the highest possible prevention against accidents. This is true both for the technical planning of workplaces, equipment and processes and for safety management and personal behavior in the workplace. Work environment must be designed in manner that takes care of health of employees.
Each employee must pay constant attention to safety and consistently comply with legal and internal guidelines and restrictions

G) Complaints and Comments

Every employee is encouraged to present personal grievance to their immediate supervisor, the Head of Department or any other person / agency that is designated, or to refer to the circumstances which point to a violation of this Code of Business Conduct. Any of such matters or remarks will be reviewed and , if appropriate, it will lead to appropriate measures. All documentation in this regard will be kept confidential.


Implementation and control of principles of business conduct within our company is task and duty of all our employees. Responsibility in the implementation and monitoring of the implementation increases with the level of authority that each employee in our company has.

This document was created with the aim of improving business responsibility and culture of our employees, which will certainly affect business efficiency and the social reputation of our company.

Consequently, all employees of our company and subsidiaries are required to consistently and persistently implement the adopted principles of business conduct.

In Osijek, July 2011.