EBA CODE OF CONDUCT
INTRODUCTION & PURPOSE
The European Business Association (hereinafter — the EBA), being a voluntary union of legal entities, a non-governmental and non-profit organization, has designated the following Code of Conduct for application and implementation by its Members.

This Code of Conduct is an integral part of the EBA Internal Rules and Procedures.

The aim of this Code of Conduct
is to provide a framework for Members' ethical behaviour in their daily activities. The Code sets the expectation of best practice in doing business and determines guiding principles for EBA Members regarding personnel development and professional growth.

Notwithstanding anything else set out in this Code of Conduct, the EBA Board retains the right to amend this Code of Conduct at its sole discretion.
APPLICABILITY
As an organization committed to high standards of conducting business, collaboration and professional behaviour, the EBA requires adherence to this Code of Conduct.

Each Member is expected to comply with this Code of Conduct and shall be responsible for ensuring that its personnel are aware and comply with this document.

A lack of awareness or a misunderstanding of the Code's provisions is not itself a defence to a charge of unethical conduct.
BREACHES OF THE CODE
In case any EBA Member violates any principles/rules stipulated in this Code of Conduct, the EBA Board shall be entitled to review membership of the respective company in the EBA.
RAISING QUESTIONS & CONCERNS
If a Member is in doubt as to any provision of this Code of Conduct, they may contact the EBA at membership@eba.com.ua for further information and clarifications.
CONDUCT REQUIRED
As a Member of the EBA, the company shall commit to the following, as set forth in this Code:
promote fair and transparent competition and best business practices, including maintaining professional conduct in interactions with other EBA Members and all external parties. Members shall not gain advantage through illegal means or unethical behaviour;
contribute to fighting against corruption. Members shall refrain from any bribery* direct or indirect or corruption-related activities;
respect and comply with property rights;
respect and make every effort not to infringe upon the intellectual property rights of others;
respect privacy of information about the EBA, its personnel, other Member-companies and apply measures for proper use of such information;
operate in a manner that recognises and supports the rule of law, encourage compliance with the letter and spirit of prevailing legislation at all times;
promote development of Ukraine's law-based society;
respect employees' rights, including but not limited to rights to a safe, secure and healthy workplace, to be free from discrimination** in hiring and employment practices and to have equal opportunities at work. Members will not use or allow to use verbal or physical harassment or abuse to discipline personnel;
recognise the importance of professional development as a prerequisite for economic growth in Ukraine. To this end, Members strive to undertake actions to create favourable conditions for their employees to improve a broad variety of skills;
seek to develop constructive relations with state and local government bodies to achieve a favourable business climate;
avoid acts that in any way harm the reputation of the EBA or compromise the EBA's purposes. Members shall maintain a respectful and polite tone in oral communication and written correspondence with the EBA Board, EBA Executive office, and other EBA Members;
maintain a respectful and polite tone in communication with EBA guest speakers at all EBA events. Where relevant, Members shall recognise that it is preferable to address questions to guest speakers in writing, especially if these questions concern specific areas of interest to the company and/or to the EBA Members in general, as answers may need special preparation in advance of respective event (meeting);
respect local communities;
ensure that business is conducted in a manner that does not violate EU, US, UN, UK or Ukraine sanctions;
be socially responsible and recognise the importance of environmental protection. Members will strive to comply with all applicable environmental regulations;
not perform on the EBA platform any coordinated actions, which may limit the competition between the EBA Members. For the purpose of this clause, coordinated actions relate to:
  • price of goods being traded;
  • quantity of product being manufactured;
  • standard formulas for the price being calculated;
  • support of fixed proportion between competing though not identical goods;
  • cancellation of price discounts or setting same discounts;
  • credit agreements spreading on customers;
  • not lowering the price without warning all the other participants of coordinated actions beforehand;
  • buying goods in excessive quantity, offered for low prices (with the aim of supporting a higher goods' price);
  • appointing a single sales agent able to control amount of goods' selling of all participants of coordinated actions;
  • customer allocation among participants of coordinated actions;
  • market division for the purpose of purchasing or selling goods between participants of coordinated actions;
promote the application of these principles/rules by those with whom the EBA Members do business;
use the EBA's logo in accordance with guidelines for use specified by the EBA. Companies must remove the EBA's logo from their websites and/or all materials in the event that they cease to be an EBA Member for any reason whatsoever, as well as remove the EBA's logo from the relevant section about partnerships on the company's website and/or other materials in case of partnership's termination.
For the purpose of this Code of Conduct «bribery» means giving, receiving, offering, promising or soliciting of an advantage as an inducement for action in order to receive any unlawful benefits for individual and/or business.
For the purpose of this Code of Conduct «discrimination» means treating a person unfairly because of who they are or because they possess certain characteristics (examples of such characteristics: age, gender, race, skin color, disability, political, religious or other beliefs, pregnancy and maternity, sexual orientation, gender reassignment, ethnic, national and social origin, citizenship, family and property status, residence, language or other characteristics).
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