alpmetal@alpmetal.si +386 45 11 78 36

CODE OF CONDUCT & ETHICAL CODE

CODE OF CONDUCT

Code of conduct and ethical code

1. Purpose and goals

Alpmetal & CO must take care to enjoy the reputation of a highly professional, impeccable and honest company.

With these rules, we set the principles of conduct and rules of conduct that should support our efforts to:

  • a positive image of the company among employees, our customers and partners and the general public,
  • strong trust of all interested parties in the professional, impeccable and fair operation of all staff, both permanent and occasional employees;
  • appropriate relationships with customers of our products, business partners and employees.

2. Responsibilities

The principles and rules set out in these rules must be observed by all employees and individuals acting as representatives of ALPMETAL & CO.

The Code, to which we are bound by these rules, are primarily guidelines and not explicit guidelines for conduct. We comply with the explicit provisions consistently, while we act in the spirit of the principle with others. Compliance with the code of ethics is ensured by the director of ALPMETAL & CO is that:

  • inform all staff, ie permanent staff, subcontractors and other external collaborators, of the provisions of these rules,
  • supports and supervises the implementation of the provisions of these rules;
  • keep records and reports related to the implementation of the provisions of these rules. Violation of the provisions of these rules is the responsibility of the director.

3. Principles of conduct

3.1 Commitment

The principles of conduct in points 3.2 to 3.6 are formed in the first person singular. The statements in this way express the commitment of each individual employee to the given principles.

3.2 Basic ethical principles

  • I perform my work and tasks flawlessly and diligently
  • I am constantly striving to raise the capacity and grow the reputation of the company, so in both internal and external communication I spread good news,
  • I use my knowledge and skills to advance the company and consequently our well-being, and to promote safety and quality.
  • I respect the relevant general legal regulations and specific legal regulations that apply to the implementation of the activities of ALPMETAL & CO.

3.3 Socially responsible behavior

I demonstrate socially responsible behavior by:

  • I perform my tasks accurately, reliably and in such a way that safety is never compromised,
  • I present my work and merits with dignity and modesty.

3.4 Fairness of operation

  • I never use my position in the company, either directly or indirectly, for personal gain.
  • I take great care not to jeopardize confidence in my judgment or in the exercise of my judgment in any way
  • Duties.
  • I have no links with our customers, suppliers of products or services, competition or others in such a way that such a link could lead to a conflict of interest or influence the company's decisions or actions.

3.5 Relations with the employer and customers

  • I perform my profession in such a way that I am a trustworthy contractor for each of our customers.
  • If I have business connections, interests, or any other relationships that could compromise my integrity, I notify the employer.
  • I do not disclose information relating to business matters or technical processes without the consent of any current or former employer or customer.

3.6 Relationships with co-workers

  • I make sure that the credit for the work done goes to the one who does it.
  • I strive to support the professional development and advancement of my co-workers, especially those who work under my supervision.
  • I do not compete unfairly; I strive for friendly and sincere relationships with co-workers.
  • I communicate openly and reject rumors that no one has verified.
  • If I have a dilemma and I have no evidence, I check first, only then I speak.
  • I talk to my colleagues openly and directly.

4. Rules of conduct

4.1 Considered aspects of conduct and order

The rules in points 4.2 to 4.6 refer to the following aspects of conduct and order, which are important for establishing a positive image of ALPMETAL & CO and appropriate relationships with our customers and partners:

  • respectful attitude,
  • handling disputes,
  • business presents,
  • orderliness of employees,
  • tidiness of premises.

4.2 Respectful attitude

We build appropriate, impartial and respectful relationships with our customers and partners by:

  • listen to their wishes, requests and questions,
  • we deal with their requests, orders or questions as soon as possible;
  • the order is executed within the agreed deadline and with high quality; in doing so, we try not only to meet but also exceed their expectations,
  • we are aware that there are no insignificant things for us,
  • we are aware that each employee represents the company when in contact with customers and partners,
  • we are friendly and listen to the needs or problems of the customer.

4.3 Resolving disputes

A conflict (disputed) situation can arise when the customer, for example:

  • tries to influence the course and results of our work;
  • tries to obtain, directly or indirectly, confidential information about our customers / partners or any other confidential company information,
  • acts contrary to the agreements reached.

When a conflict situation arises, we act in accordance with the following principles or recommendations:

  • we insist firmly, we are kind and give the customer appropriate and sufficiently detailed explanations,
  • we propose an alternative solution that should meet the needs of the customer and would not be in conflict with the requirements of regulations or our quality system,
  • If we are unable to resolve the conflict situation on our own, we consult with the director or make sure that the customer contacts the director of ALPMETAL & CO

Within ALPMETAL & CO to increase mutual trust and respect, we encourage:

  • constructive problem solving,
  • patience and tolerance,
  • flexibility and self-control.

In this way, well-functioning groups can be formed, consisting of people of different character traits, who are inherent in creating conflicts, but are also able to resolve them constructively.

4.4 Orderliness of employees

The tidy appearance of the staff is important for the image of the company created by our customers and business partners, as well as the general public. It is the duty of all employees to take care of proper personal arrangement both at their permanent workplace and at work outside their permanent location, for example on visits to fairs, conferences, on business trips and wherever they represent ALPMETAL & CO

4.5 Tidiness of the premises

The heads of organizational units are responsible for the appropriate arrangement of the premises, each of whom is responsible for ensuring that

  • the business premises, production, warehouses, and corridors are clean and tidy and that the inventory in them is clean and properly maintained,
  • the premises in which we receive customers and business partners are appropriately arranged and equipped,
  • provide regular or occasional additional cleaning if necessary.

5. Other rules

5.1 Child labor

Under our law, the work of children under the age of 15 is prohibited. Even if such work were not prohibited by law for the sake of morality and ethics of management, the child would not be employed under any circumstances. Between the ages of 13 and 15, children can also do other light work, but only during the school holidays. In both cases, strict rules and restrictions apply, which are already prescribed by the Employment Relationships Act (ZDR-1) due to special protection for child labor. Even in this particular case, we do not employ children due to the nature of our work.

Also, not all of our suppliers exploit children to work in production, which is quite clear, as our suppliers do not come from certain areas, e.g. Asia and Africa.

5.2 Young workers up to 18 years of age

Our workers who have not yet reached the age of 18 enjoy special protection in the employment relationship. If the employee has not yet reached the age of 18, he or she is subject to special rights or restrictions regarding work. These workers are not allowed to do the following:

  • heavy physical work,
  • parts that are at risk to their health due to extreme cold, heat, noise or vibration,
  • a part that could in any way harm their health and development.

We consider the following:

  • that they are only allowed to work 8 hours a day and only 40 hours a week,
  • if they work at least 4 and a half hours a day, they must have a 30-minute break,
  • must have at least 12 hours of rest each day,
  • are not allowed to work between 10 pm and 6 am,
  • Exceptionally, they can work at night if adults are not available, but this may only be exceptional (in case of force majeure).

Workers are entitled to an additional 7 working days of leave until they reach the age of 18. ALPMETAL & CO identify what may endanger the safety and health of the young worker, assess the risks and take preventive measures.

5.3 Pregnant women, workers who have recently given birth and workers who are breastfeeding

A pregnant worker is any pregnant worker who informs the employer of her condition with a medical certificate; pregnancy is counted from the time of pairing ALPMETAL & CO with pregnancy to childbirth. A worker who has recently given birth is a worker who gave birth less than 12 months ago and who informs ALPMETAL & CO of her condition with a medical certificate

A breastfeeding worker is a worker who is breastfeeding a child and who informs ALPMETAL & CO about her condition with a medical certificate In this regard, ALPMETAL & CO we follow the following rules: LINK

5.4 Protection of whistleblowers (applicants)

With regard to the protection of applicants, any irregularities and violations are taken into account in ALPMETAL & CO general guidelines and directives, as the size of the company does not oblige us to draw up specific internal rules regarding their protection.
Should this occur, the recommendations and guidelines would be followed: LINK

6. General code of conduct

Committing to the Highest Ethical and Legal Standards

Alpmetal & CO is committed to upholding the highest legal and ethical standards, regardless of when and where we conduct our business. Our Code of Conduct (Code) provides basic guidelines to assist us in making good decisions on behalf of the Company, in doing our jobs ethically and in compliance with Alpmetal & CO policies and the laws of the countries where we do business. As an Alpmetal & CO employee you are required to read, understand and abide by the Code of Conduct and you are encouraged to refer to it when you have a concern or face a difficult ethical dilemma.

Upholding the Code and Following the Law

No matter where you work or what your position, as an employee of Alpmetal & CO , you are obligated to:

Follow the tenets of the Code

The Code applies company-wide and worldwide to all Alpmetal & CO employees, officers and directors, as well as to all employees. In addition, we expect our agents, independent contractors, consultants to act in a manner consistent with applicable Code tenets.

Comply with the laws and regulations of the countries in which we do business

You are expected to meet the ethical and legal standards that apply in the countries where we do business. If you are concerned that the laws or regulations in your location appear more strict than, or seem to differ from, our Code, you should seek guidance from your supervisor. Any failure to comply with the law will be considered a Code violation

Non-Retaliation and Confidentiality

We are committed to protecting employees who, in good faith, make reports, seek advice or ask questions. Our anti-retaliation policy aims to ensure that no employee will suffer undue harm because he or she raises an issue, reports a Code violation or cooperates with an investigation. It is designed to protect you from unwarranted actions by the Company, fellow Alpmetal & CO employees or a manager or supervisor. If you believe you are the victim of retaliatory action, you should contact your manager or supervisor.

Failure to Comply with the Code

Any failure to comply with the standards contained in the Code will result in appropriate discipline, up to and including termination of employment, referral for criminal prosecution and restitution for any losses or damages resulting from the violation. The extent of the discipline will be based on factors such as the severity and frequency of the offense.

Manager’s Responsibilities

As an Alpmetal & CO supervisor or manager, you are responsible for understanding and complying with the Code, applying it daily and being aware of the ethical standard of your business behavior. You also are obligated to direct any questions, concerns or issues that require additional guidance to other Alpmetal & CO resources, such as Human Resources.

Updates

Alpmetal & CO regularly reviews the content of our Code, as well as related corporate policies. We will make modifications to the Code as required by changes in law, policy or other significant developments.

Fostering a Respectful Workplace

At Alpmetal & CO , we aspire to create an inclusive and respectful work environment; one in which employees recognize one another’s worth and dignity. Any conduct that detracts from the worth and dignity of our employees is contrary to our values and has no place in our culture. We also are committed to showing respect to people and cultures in the countries where we do business. As a representative of the Company, you should strive to be sensitive to the cultures and customs of those with whom you work.

Diversity and Equal Employment Opportunities

Alpmetal & CO is committed to maintaining a diverse workforce, a culture of mutual respect and an appreciation for the differences of others. Providing equal employment opportunities is the right thing to do and it is important to our success. To ensure that we comply with applicable labor and employment law and never discriminate, Alpmetal & CO s recruitment, hiring, compensation, promotion, transferring, training, corrective action and termination practices are based exclusively on an individual’s qualifications and ability to perform the job. Only criteria which are relevant to the job are considered.

Harassment and Workplace Respect

Respect for one another is basic to Alpmetal & CO ’s culture. Disrespect can disrupt the productivity of our employees and threaten Alpmetal & CO ’s success. To help ensure an environment of mutual respect, Alpmetal & CO will not tolerate any form of harassment or other intimidating behavior, including physical, emotional or verbal abuse. We prohibit any form of harassment, whether by an employee, a temporary employee or an external vendor, in which:

  • submission to the harassment or abusive conduct is an explicit or implicit term or condition of employment;
  • submission to, or rejection of, the harassment or abusive conduct is used as the basis for an employment decision;
  • the harassment or abusive conduct has the purpose or effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Violating this policy will subject an individual to disciplinary action, up to and including termination of employment.

Workplace Violence

All Alpmetal & CO employees have the right to perform their jobs in an environment that is free from violence, bullying, threats or intimidation. Whether at work on Alpmetal & CO property or in work-related relationships, no Alpmetal & CO employee should cause others to reasonably fear for their personal safety or the safety of their families, friends or property. If you encounter a situation of violence, bullying or threats, you should speak to your manager if necessary, call the appropriate emergency authorities. Unless contrary to local law, Alpmetal & CO prohibits the possession or use of weapons on Company property or while conducting Company business.

Corporate Social Responsibility

Alpmetal & CO takes seriously our responsibility to the communities we serve. We believe in compensating our employees fairly and in compliance with local laws. We promote the well-being of our employees, our customers and our customers’ customers by contributing to programs and initiatives that enhance the quality of life in the communities in which they work and live. We respect the rights of all people and hold our suppliers to the same high standard of social responsibility. The Company does not engage in the use of forced or child labor, nor do we condone the mistreatment of any individuals who conduct business with, or on behalf of, Alpmetal & CO .

Commitment to a Safe and Healthy Workplace

Alpmetal & CO places the highest value on the safety and well-being of our employees, as well as the safety and well-being of the communities and environments in which we operate. Each of us is responsible for complying fully with applicable health and safety laws and knowing, understanding and following the Company’s safety policies, practices and procedures. Each of us has a personal responsibility to maintain a safe workplace and to use Alpmetal & CO ’s equipment and materials in a safe manner, always exercising good judgment in our daily work life. As an employee, if you observe or learn about conditions or practices at your work location that could threaten your health and safety or that of your colleagues, please report your concerns immediately to your supervisor, or if necessary, the appropriate emergency authorities.

Drugs and Alcohol

The abuse of alcohol and drugs can threaten the health and safety of our employees and have adverse effects on job performance and Company reputation. Whether working on Alpmetal & CO property or performing Company business off-site, you are prohibited from the unlawful manufacture, sale, distribution, dispensing, possession or use of controlled substances. Alpmetal & CO will not tolerate employees consuming or being under the influence of alcohol or drugs while performing their jobs, including driving on business. Exceptions may be made to allow the consumption of alcohol at sanctioned social events for which prior approval has been granted and at which employees maintain proper behavior. If you suspect that an employee may be under the influence of alcohol or a controlled substance in violation of Alpmetal & CO , you should report it immediately to your supervisor. Employees who violate our drug and alcohol policy may be subject to potential criminal liability as well as appropriate disciplinary action, up to, and including termination of employment.

Product Quality and Safety

Alpmetal & CO complies with all laws and regulations concerning product quality and safety. By complying with the laws, regulations and Company policies that govern the manufacturing, testing, inspection, storage etc. use and disposal of our products, we help ensure the integrity of the Alpmetal & CO good reputation. No employee should take any action that could jeopardize our customers’ confidence or trust in the quality and safety of our products.

Commitment to Sustainability and Protecting the Environment

At Alpmetal & CO, we are committed to providing and protecting what is vital: clean water, safe food, abundant energy and healthy environments. Strengthened by the expertise of our employees and combined with our dedication to social responsibility. Our commitment to sustainable development is articulated in a document called CSR policy. We should all strive to follow and promote these principles.

Acting in the Interests of Alpmetal & CO

Alpmetal & CO expects employees to avoid situations that could create conflicts between their personal interests and the interests of the Company.

Conflicts of Interest

Conflicts of interest arise when your personal activity or interest interferes with the business interests of the Company. In many cases, even the appearance of a conflict of interest can have serious consequences for you and the Company.

Conflicts of interest can arise in many different situations, both direct (you are involved) and indirect (someone with whom you have a personal relationship is involved). You should take care to properly address any conflicts of interest. For instance:
Outside Employment or Activities: You should not engage in employment outside of the Company if that employment (i) interferes with your duties to the Company, (ii) causes you to compete with, or work with an organization that competes with, Alpmetal & CO , or (iii) leads you to provide services or assistance to an Alpmetal & CO competitor. Outside employment that requires you to use Alpmetal & CO time, facilities or property to perform the job would be considered a conflict of interest. To assess whether a second job will create a conflict of interest, employees are required to obtain approval from their supervisors before accepting additional employment outside the Company.
Corporate Opportunities: As an employee, you should never take personal advantage of any business opportunities in which the Company would have an interest. You also should not make those opportunities available to others when you know Alpmetal & CO has an interest in the opportunity. For example, employees should avoid purchasing real estate or financial interests in firms that Alpmetal & CO has a known interest in acquiring.
Family Members: If members of your family or other close personal relations work at Alpmetal & CO or provide services to the Company or a competitor, supplier or customer, you should immediately disclose those relationships to your supervisor to avoid actual or perceived conflicts of interest. Alpmetal & CO will not purchase any goods or services from a firm employing a Company employee, or a close relative of a Company employee, unless there is prior approval from a supervisor. Special care should be taken when you participate in the procurement decision involving a company which employs a relative.

Giving and Receiving Gifts, Entertainment and Hospitality

The exchange of gifts, entertainment and other favors may be customary and appropriate in certain circumstances, locations or cultures. However, to safeguard the reputation of the Company, we must be sure that gift exchange is consistent with applicable law, our customer contracts, good business practices and custom. Follow these guidelines whenever offering or accepting anything of value.

  • If it is a gift, it should be of only nominal value.
  • If it is entertainment or hospitality, it should be reasonable in cost, amount, quantity and frequency.
  • It should not be offered or given in an effort to influence a business decision.
  • It should not violate the normal and accepted business ethics of the country in which it is provided.
  • It should not reasonably be construed as a bribe, payoff or kickback.
  • It should involve no element of concealment.

Its public disclosure should not embarrass Alpmetal & CO or damage the Company’s reputation.

  • Under no circumstances may you, as an employee, provide or accept cash, cash equivalents or personal loans in conjunction with Alpmetal & CO business.

Preventing Bribery and Corruption

Alpmetal & CO strives to do business through proper means and actions. Therefore, we must avoid any behavior that could be perceived as a form of bribery or corruption. Bribery arises when one party, directly or indirectly, offers something of value to another party in order to improperly gain business or obtain favorable treatment. Violating not only could result in significant disciplinary action from the Company, but also could result in serious criminal and civil penalties for both Alpmetal & CO and you (including imprisonment and monetary fines).

Fair Competition

At Alpmetal & CO , we believe in free competition and strive to outdo our competitors through honest and fair business practices. In our relationships with customers, distributors, suppliers and competitors, we should never seek any unfair advantages or misrepresent facts about our business or our products. Likewise, we should avoid making false or misleading statements about our competitors or their products. Alpmetal & CO ’s reputation for fairness and honesty is too valuable to risk by behaving otherwise. It is our policy that employees have no inappropriate contact with our competitors. Any business activity which involves repeated or unusual contact with competitors - whether at meetings (such as trade association meetings), in telephone calls or by correspondence - must be approved by your supervisor .

Avoiding Insider Trading

During the course of your job, you may become aware of information that is not yet publicly available that could be important enough to influence someone’s decision to buy or sell Alpmetal & CO stock. Information of this type is often referred to as “material inside information.” As an employee, you must never buy or sell Alpmetal & CO stock while possessing material inside information about Alpmetal & CO . Similarly, if during the course of your job you become aware of material, non-public information about companies with whom we do business, you should not trade in those companies’ securities until the information has been made public. Failure to observe this prohibition could expose you and the Company to civil and criminal penalties. You also are prohibited from passing along inside information to others (including other employees, relatives or friends) who have no work-related reason to know. If you have material, non-public information that could influence an employee or any other individual to purchase or sell the Company’s stock, you should not disclose it.

Protecting and Properly Using Alpmetal & CO Assets and Property

Each of us is responsible for conserving and protecting Alpmetal & CO ’s assets, including financial assets, trade secrets and other proprietary information as well as its physical property. Resources such as raw materials, equipment, office supplies and technology are intended exclusively for business purposes and their theft, loss, abuse or misuse must be prevented. It is up to each of us to help identify when the use of our physical assets is not in accordance with Alpmetal & CO ’s policies. Alpmetal & CO managers have a heightened obligation to maintain good controls and protect our physical assets.

Confidential and Proprietary Information

Information to which we have access may be proprietary or confidential in nature. Alpmetal & CO places great value on its confidential and proprietary information. As employees, we must protect and guard against its unauthorized use or disclosure. Examples of Alpmetal & CO ’s confidential and proprietary information could include our:

  • Long-term strategies
  • Product development plans
  • Personnel records
  • Sales plans
  • Marketing plans
  • Communications plans
  • Financial information
  • Competitive intelligence
  • Customer buying habits
  • Acquisition or divestiture plans
  • Manufacturing methods

As an employee, you should never use the Company’s confidential or proprietary information for personal gain either during your employment with Alpmetal & CO or after you leave the Company. Unauthorized disclosure of confidential or proprietary information could destroy its value and/or give unfair advantage to others. Thus, it is your responsibility to make sure the necessary confidentiality/non-disclosure agreements are in place and limit disclosure of proprietary information only to those who have a business need to know. You also are obligated to respect and protect the confidences of our suppliers and customers by not divulging their proprietary or confidential business information. If you become aware of a situation in which Alpmetal & CO ’s proprietary information has or may have been compromised, you should report it immediately.

Intellectual Property

Alpmetal & CO ’s product plans, patents, trademarks, copyrights, trade secrets and know-how — its intellectual property — are valuable assets that we must safeguard. All Alpmetal & CO employees have an obligation to comply with applicable laws and regulations that help us protect our intellectual property. By following the law, we help protect Alpmetal & CO ’s research, ideas, processes and products from theft or misuse — and in doing so, we help ensure that they are available to us for future innovation. As an employee, you also are obligated to respect the intellectual property rights of others. It is our policy never to knowingly violate another company’s intellectual property and always to obtain the necessary licenses and permissions before copying, using or distributing the intellectual property of others. Violations of intellectual property laws can be costly to the Company.

Ensuring Data Privacy and Data Security

Alpmetal & CO maintains sensitive data and other information that is valuable to the Company. It is imperative that this data not end up in the wrong hands. Alpmetal & CO has strict policies and procedures to help protect sensitive or confidential information, including electronic data stored in our systems. All employees are responsible for complying with Alpmetal & CO ’s data privacy and security policies. Only employees who have a need to use confidential data or sensitive information as part of their jobs will be granted access to it. Whenever Alpmetal & CO receives requests to disclose or share potentially sensitive or confidential information stored on our systems, any disclosure must be both appropriate and legally necessary.

Customer and Supplier Information

We have an obligation to protect the privacy of data that our customers and suppliers share with us. In accordance with data protection laws, only Alpmetal & CO employees who have a business need should access or use customer or supplier information. When you need to access or use customer or supplier information as part of your job, you should do so only within the limited scope of your business need, taking great care to never jeopardize the security or sensitivity of the information we maintain.

Employee Privacy

To conduct our operations effectively, Alpmetal & CO may collect, maintain and appropriately share certain personal information about you. We will respect and protect your personal information to the fullest extent required under applicable data protection laws. We understand that any loss or improper use of sensitive information belonging to you could lead to unwanted consequences, including identity theft and disclosure of harmful or embarrassing information. Just as the Company respects and protects your personal information, it is your responsibility to handle the personal information of co-workers with utmost care in order to protect their privacy.

Alpmetal & CO’s Compliance & Ethics Resources

Alpmetal & CO encourages a work environment in which our employees feel free to ask questions and raise concerns. If you observe something that seems questionable or if you have any doubt as to whether certain activity or behavior complies with the Code of Conduct, you should consult one of the resources listed below:

Whom You Should Contact:

Contact

Adress

Selca 86, 4227 Selca, Slovenia

Telephone

+386 4 511 78 36

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Location - production unit

Selca 168, 4227 Selca
Kidričeva 58, 4220 Škofja Loka