Code of Conduct

We are fully aware of the responsibility we bear towards our customers, employees and the communities in which we work. Thus, we have given ourselves a strict set of work rules and ethical standards to guide us in our business dealings.
Laws and Ethical Standards
We comply with all laws applicable to our business. We support the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organization Declaration on Fundamental Principles and Rights at Work, in accordance with Syrian laws and practice. This especially applies to:
Human Rights and Fair Labor Practices
• Child Labor
We do not employ children under the age of 18 and we adhere to Syrian labor law.
• Forced Labor
We do not use any form of forced, bonded or involuntary labor. All labor is voluntary. Workers are allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). We ensure that workers do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. We responsible for payment of all fees and expenses (e.g. licenses and levies) relating to workers, where legally required.
Punishment, mental and/or physical coercion are prohibited. Disciplinary policies and procedures are clearly defined in accordance with Syrian labor law and communicated to the workers.
• Compensation and Working Hours
We comply with all applicable Syrian laws and mandatory industry standards regarding working hours, overtime, wages and benefits. We pay workers in a timely manner and clearly convey the basis on which workers are being paid.
• Freedom of Association and Collective Bargaining
Our employees are free to join or not to join a union/employee representation of their choice, free from threat or intimidation. We recognize and respect the right to collectively bargain in accordance with Syrian laws.
• Diversity
We promote an inclusive work environment that values the diversity of our employees. We do not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin or any other characteristic protected under law.
Health & Safety
We strive to implement the standards of occupational health and safety at a high level by applying a health and safety management approach appropriate for the business.
We comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of employees, safeguard third parties and prevent accidents, injuries and work-related illnesses. This includes regular workplace risk assessments and the implementation of adequate hazard control and precautionary measures. Our Employees are adequately educated and trained in health and safety issues.
Data Protection and Disclosure of Information
We adhere to relevant data protection and security laws as well as to respective regulations, in particular with regard to personal data of customers and employees. We comply with all said requirements when personal data is collected, processed, transmitted or used.
We safeguard and make only appropriate use of confidential information. We do not disclose any information that is not known to the general public.
Bribery and Corruption
We comply with all Syrian and international anti-bribery regulations as well as applicable anti-corruption laws, regulations and standards. We do not (either directly or indirectly) offer or promise to provide anything of value to improperly influence an official act or to secure an improper advantage in order to obtain or retain business.
Gifts, Hospitality, and other benefits
The employees must not take advantage of their jobs to accept any gifts or hospitality of any kind, it is strictly forbidden to request any gifts or hospitality or personal benefits.
Trade Regulation
We comply with all applicable trade and import regulations including sanctions and embargoes that apply to our activities.
Money Laundering & Financial Records
We comply with applicable laws and regulations designed to combat money laundering activities. We maintain financial records and reports according to international and Syrian laws and regulations.
Fair Competition
We comply with applicable competition and anti-trust laws.

Conflicts of Interest
A conflict of interest arises when an individual has a private/personal interest which could appear to influence their decisions. Such conflict of interest situations include a relationship by blood or marriage, partnership, business partnership or investment. We disclose any actual or potential conflict of interest.
Environment
We comply with all applicable environmental laws, regulations and standards.
Conflict Minerals
We comply with all applicable laws and resulting due diligence obligations with respect to the sourcing of minerals and materials from conflict affected regions and high-risk areas, which may contribute to human rights abuses, corruption, the financing of armed groups or similar negative effects.
Community Outreach
We give back to our local communities and engage in initiatives and activities that reflect the UN Sustainable Development Goals.
Business Continuity Planning
We are prepared for any disruptions of our business (e.g. natural disasters, terrorism, software viruses, illness, pandemics, infectious diseases). This preparedness especially includes disaster plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.
Business Partner Dialogue
We encourage our own suppliers to adhere to this Code of Conduct as part of fulfilling their contractual obligations.