1. GENERAL PROVISIONS AND OBJECTIVES OF THE CODE
1.1 This Code of Ethics and Business Conduct (hereinafter referred to as the “Code”) is designed to inform all interested parties of the high standards of corporate Business Ethics of IE VOSKRESENSKAYA MARIA ALEXANDROVNA (hereinafter referred to as the “Company”), and is intended to ensure fair, ethical and lawful business interaction between all employees, officers, directors and counterparties of the Company.
1.2 The Code has been developed in accordance with legal requirements, recommendations of local and international regulatory bodies of the countries where the Company operates, international law and standards of global business practice, as well as other Regulatory Documents. In addition to this Code, the Company has internal Regulatory Documents that disclose certain provisions of the Code.
1.3 The Code applies to all Employees and Senior Management of the Company, regardless of their position, as well as to third parties who have business relations with the Company or act on its behalf or in its interests throughout the world. The Code applies to the Company and its controlled entities, regardless of where they are located.
1.4 Our Code is a set of internal corporate policies that apply to the Company and are the foundation of our business.
1.5 Recognizing our responsibility to our Employees, our Business Partners, shareholders and other stakeholders, we emphasize the principles of corporate Business Ethics in all areas of our business and believe that this is the only possible way to grow our business and the industry as a whole.
2. COMPANY EMPLOYEES AND WORKING RELATIONSHIPS
Decent working conditions and respect for human rights
2.1 We are proud of our team and strive to create a comfortable and safe working environment, competitive remuneration and comprehensive motivation for everyone.
2.2 We value the rights and personality of each member of our team and promote a favorable and safe working environment and cultural diversity within the team. Violence, harassment and discrimination in any form are unacceptable in the Company.
2.3 Every Employee of the Company has equal opportunities to realize his/her labor potential. In our activities we rely solely on the personal qualities and professional competencies of Employees at all stages of their career with the Company.
2.4 The Company adheres to the principles of observance of labor rights in accordance with the requirements of local regulatory bodies of the countries where the Company operates, international law and standards of global business practice, and undertakes to ensure compliance with regulatory documents in the field of occupational health and safety, as well as to implement relevant best practices in this area.
2.5 The Company supports the practice of supported employment for young people with disabilities, graduates of orphanages and remedial schools.
Protection of personal data
2.6 The Company adheres to the principles of ensuring the security of Employees' personal data in order to protect their rights and freedoms, including protection of the rights to privacy, personal and family secrecy, as well as compliance with Russian and international laws in the country of operation.
2.7 We treat personal information as confidential and take a responsible approach to its storage and prevention of its dissemination.
2.8 The Company fully complies with applicable laws and additional requirements contained in the Regulatory Documents on Collection and Protection of Personal Data in all countries of its presence.
3. CONDUCTING BUSINESS PROPERLY
Quality of products and goods
3.1 Our reputation is directly related to customer confidence in the quality of the products we sell. We recognize that quality products distinguish us from our competitors and are our commitment as a good and ethical Company.
3.2 We believe that cosmetics should be safe and we have strict quality control procedures for all products. We believe that quality depends on our employees at every stage, from the production of the raw materials used in our products to their delivery to our markets and end consumers.
3.3 We engage independent organizations to test and trial our products on an annual basis.
Investors and shareholders (fill in if relevant)
3.4 The Company guarantees observance of investors' and shareholders' rights, creates favorable conditions for shareholders' participation in the management of the Company, and publishes timely and reliable information on its activities and financial position.
3.5 We maintain an effective dialog with investors and shareholders and strive to meet their expectations by fulfilling the stated goals for the Company's financial condition and development.
Fair competition
3.6 The Company complies with antitrust laws designed to protect fair competition in the marketplace.
3.7 We believe it is unacceptable to enter into unethical and unlawful agreements with competitors regarding market allocation, customer allocation, strategy or marketing plans, pricing or other collusive agreements.
Combating corruption and bribery
3.8 The Company relies on the law and corporate Business Ethics to conduct its business. We oppose any form of Corruption, avoid Bribery and any ambiguous situations that jeopardize our business reputation.
3.9 We adhere to the principle of “zero tolerance” to any form of Corruption - a total prohibition for Company Employees and other persons acting on behalf of and/or for the benefit of the Company, directly or indirectly, personally or through any intermediary, to take part in Corrupt Activities, regardless of business practices in any country. Any other action that could be construed by the public as the receipt, offer, transfer, promise or provision of a Bribe or Commercial Bribery is also prohibited.
3.10 The Company will never ask Employees or any third party to make unreasonable payments, give gifts, hospitality or other tangible or intangible goods on behalf of the Company in order to provide an improper advantage to the Company.
Conflict of Interest
3.11 Employees of the Company shall act in good faith and solely in the interests of the Company. In the performance of their job duties, Employees must avoid real or potential personal interest that could harm the interests of the Company.
3.12 We expect Employees to disclose situations potentially involving a Conflict of Interest in good faith.
3.13 We support all possible and necessary measures to identify, prevent and manage Conflicts of Interest.
Business Partners
3.14 Consistent with our ethical principles, we expect all Company Business Partners to:
- Ensure fair and timely payment of wages;
- establish reasonable working hours;
- create safe and healthy workplaces;
- maintain transparency in the manufacturing process;
- comply with all applicable environmental laws;
- maintain confidentiality of information;
- adhere to the principle of “zero tolerance” to any form of Corruption.
Gifts and Events
3.15 We recognize that gifts, treats, entertainment invitations and other tangible or intangible items may influence or create the appearance of improper influence on the recipient's ability to make decisions.
3.16 We may only provide gifts, entertainment and other valuables when they are part of common cultural practices or business protocols, are offered lawfully, on an occasional basis, are not a luxury item and their value is within the limits set out in the laws of the countries in which we operate.
3.17 As a Company with high ethical standards, it is always unacceptable for us to give or receive gifts that:
- are given in the form of money or cash equivalent;
- violate local laws;
- may be perceived as a Bribe or Commercial Bribery.
Interaction with Government Officials
3.18 The Company takes all reasonable steps to ensure that relations with Government Officials and governmental organizations are open, transparent and constructive.
3.19 The Company fully complies with the requirements of applicable law.
Political Activities
3.20 We respect the rights of Employees to hold political views and participate in political activities, but Employees are prohibited from engaging in political activities on behalf of the Company or giving the impression of doing so.
4. SUSTAINABLE DEVELOPMENT
Care for nature and the environment
4.1 Customer care is at the heart of our strategy: by monitoring compliance with environmental and ethical standards in the production of goods, improving our practices in the field of environmental management and Corporate Social Responsibility, as well as providing a high level of service and supporting Employees' professionalism in the field of sustainable development, the Company provides customers with the opportunity to follow the principles of responsible consumption.
4.2 The cult of “Conscious Development” reflects our desire to minimize our impact on nature and the environment. We strive to reduce our own negative impact on the environment by implementing energy efficient solutions, reducing waste, and increasing the use of eco-friendly packaging.
Responsible supply chain
4.3 We aim to ensure supply chain transparency and traceability, and work with suppliers to improve their environmental and Corporate Social Responsibility practices.
5. INFORMATION AND PROPERTY MANAGEMENT
Intellectual Property
5.1 We recognize that protecting intellectual property is essential to the success of our business. We take all necessary measures to protect intellectual property.
Confidential and insider information
5.2 We are responsible for protecting confidential information of the Company or third parties from unauthorized use or disclosure.
5.3 We are responsible for ensuring the confidentiality of insider information. It is prohibited to use such information in bad faith or provide it to others (inside and outside the Company) without a reasonable business need and the Company's authorization.
5.4 The Company is prohibited from:
- Purchase or sell Company goods based on insider information for the personal benefit or gain of another person.
- Purchase or sell Company goods during any restrictive trading periods that are imposed on specific groups of Employees.
- Communicate or share insider information inside or outside the Company without proper authorization (e.g., to journalists, financial analysts, family members or friends).
- Make recommendations to anyone to buy, hold or sell Company merchandise using insider information.
Information systems and devices
5.5 We use our information systems and devices appropriately, taking care, among other things, of the security of our data.
5.6 Any information stored on the Company's information systems and devices is the property of the Company.
5.7 Company employees must only use the Company's information systems and devices for the purpose of performing their job functions.
Record keeping and financial reporting
5.8 All transactions conducted by the Company that may have an economic impact must be accurately and timely recorded in appropriate reports as a fair representation of the transactions conducted and must be available to internal and external auditors.
5.9 We are committed to ensuring the accuracy, completeness and integrity of financial information to be disclosed to the market and the public in accordance with applicable Regulations.
5.10 The Company is committed to maintaining an appropriate system of internal control over financial reporting, ensuring regular improvement and compliance with legislation.
Disclosure of corporate information and interaction with the media
5.11 The Company is committed to ensuring that all customers, Business Partners, shareholders and investors have full, current and accurate information about its business.
5.12 The Company and all of its Employees are aware that any statements or speeches made on behalf of the Company may reflect on its reputation. In particular, the publication of any confidential or insider information in the public domain is unacceptable.
5.13 The Company has defined a circle of persons authorized to represent it in the public field. In this regard, in any communications in the media concerning the Company's activities, it is necessary to contact the PR-service.
6. CHARITY AND SPONSORSHIP
6.1 The Company regards charitable activities as an integral part of its Corporate Social Responsibility and at the same time as a significant stage in the Company's sustainable development.
6.2 The Company welcomes and provides Charity assistance not only in the form of monetary contributions, but also in kind and encourages its Employees to perform volunteer work. Donations in the form of material goods, including clothing, occupy a special place in the Company's Charity activities. The Company also supports the employment of people with disabilities.
6.3 The Company takes all reasonable and necessary steps to ensure that its Charitable Activities are not used as a cover for Corrupt Activities or for any other unlawful purpose.
7. WHISTLEBLOWING AND WHISTLEBLOWER PROTECTION
7.1 Employees should immediately report any known or suspected violation to the Company's Direct Line by one of the following methods:
- by telephone: +79043619001
- by e-mail: info@radarusskikh.ru
7.2 Reporting may be made with the name of the person reporting or anonymously. The Company guarantees that there will be no negative consequences for Employees who report potential or actual non-compliance with the provisions of the Company's internal Regulations or applicable laws.
7.3 The Company guarantees that it will treat reports in a confidential and impartial manner. No action may be taken against Employees without a proper internal investigation.
7.4 Employees should facilitate the investigation of breaches by providing information and documents required to verify the circumstances and factors of the breach.
8. FINAL PROVISIONS
8.1 All new and existing Employees of the Company must be familiar with the provisions of the Code and be guided by them in the course of their professional activities.
8.2 Employees should be mindful of their responsibilities in complying with the provisions of the Code.
8.3 The Code (or an abridged version thereof) shall be available on the Company's website for all Employees and other interested parties.
8.4 The Company has the right to post data on violations of the Code on corporate sites on the Internet and in the mass media (subject to legal requirements, including provisions on personal data protection).
8.5 Responsibility for the implementation of and compliance with the Code rests with senior management, the Human Resources Department, the Legal Department, and the Internal Control Service.
8.6 The Code shall come into force upon approval by the General Director and shall remain in force until a new version is adopted. All previous versions of the Code shall be deemed null and void upon approval.
8.7 Revision of the Code is planned on a regular basis to ensure that it remains up to date. It may be amended at any time by order of the Company's General Director.
8.8 The Code is not an exhaustive regulatory act containing prescriptions for all situations arising in the course of work and business processes. In case of disputable issues not covered by the Code, an Employee may seek advice from his/her immediate supervisor or the Internal Control Service.