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Code of Ethics

  1. The Code of Ethics applies to all employees in technical, economic and worker professions, company management and company directors. Certain provisions relate to the specific groups of employees (e.g. sales persons) or subjects outside the Company (e.g. suppliers) in the Czech Republic and in foreign countries where ATRAK a.s. operates.
  2. ATRAK a.s. requires its employees and partners to maintain legal regulations as well as the highest ethical standards based on fair conduct, mutual trust, transparency, honesty, integrity and responsibility.
  3. ATRAK a.s. has joined the Transparency International program of safe technologies, and its employees are obliged to meet the requirements of the program and refer to it in their activities.
  4. ATRAK a.s. management is generally responsible for the compliance with the anti-corruption program; the anti-corruption program is carried out by the Human Resources manager, who has direct access to the Company management in the matter of the anti-corruption program and is responsible for continuous compliance with the ethical and anti-corruption agenda in the Company. She is also responsible for monitoring and evaluation of the ATRAK´s ethical and anti-corruption program and for implementation of the formal procedure to resolve corruption concerns.
  5. ATRAK a.s. strictly rejects and prohibits any corruption conduct of its employees. In the event of demonstrably corruptive behavior, the Company claims damage compensation and usually terminates the employment immediately and within its legal liability, the Company reports the corruptive action to the Police of the Czech Republic which can instigate prosecution.
  6. ATRAK a.s. prohibits any conflict of interests of its employees. Therefore, the employees may not participate in any contractor and business relations with ATRAK a.s. as suppliers or consumers of goods and services in any direct or indirect way and may not receive any personal profit from such relations from other subject than ATRAK a.s. Conflict of interests resulting e.g. from family relationships or friendship in suppliers´ or customers of company bodies or those holding shares in such companies should be reported by the concerned employees to the ATRAK a.s. Human Resources manager.
  7. In the event of suspected unethical, corruptive, occupational safety or environment disrupting behavior or behavior damaging the Company´s goodwill, an employee or any person who plausibly gets known hereof, should report to ATRAK a.s. via the ET-LINK.
  8. However, this does not apply to petty-minded, evidence-lacking or false reports submitted with the aim to unjustly accuse a person or company. The reporting person is held fully responsible for such reports and can be sanctioned regarding to the fact that s/he disrupts the trust and standard working relationship in the Company, and as a consequence, they are contrary to the Code of Ethics.
  9. The ATRAK a.s. employees, especially marketing and sales persons, are obliged to acquaint the external partners, mainly the suppliers, with the ATRAK a.s. anti-corruption program, especially with parts hereof that concern such external partners.
  10. The ATRAK a.s. sales persons are obliged in the process of business opportunities evaluation and business meetings to take corruption risks in consideration. The risks depend on whether a client comes from the public or private sector and on the situation of a client´s country of origin in the global anti-corruption Transparency International scale and on the method of public tender opening (competitions or addressing one subject).
  11. The ATRAK a.s. sales persons are obliged to check the available media and Internet resources for possible proven corruption cases related to the ATRAK a.s. external partners and take them into consideration in the making of business decisions, including the option of termination relationships with partners involved in corruption.
  12. ATRAK a.s. provides standard services for their partners in the context of building acceptable professional relationships including the option to cover the costs of accommodation during their partners’ stays and to extend gifts and hospitality. However, it is forbidden to provide a disproportionately luxurious accommodation, unethical and expensive entertainment or give gifts of a clearly unreasonable value. These actions are considered potentially corruptive in relation to the ATRAK a.s. partners. Similarly, managers and employees of CSG member companies, especially in their sales departments, are forbidden to accept such inappropriate services or luxurious gifts. In case such offers are extended by a partner, the employee is required to report this to their superior.
  13. At certain foreign markets, state employees are allowed to legally require facilitation payments. It is strictly forbidden for CSG companies to provide such payments. Facilitation payments do not include business provisions for private sector partners, e.g. based on dealer agreements, license agreements or sales representation contract.
  14. Sponsorship relating to any business opportunity in the public or private sector is strictly forbidden. This rule applies also to gifts to political parties and movements.
  15. The aim of the Code of Ethics is its implementation in ATRAK a.s. and support to the anti-corruption agenda and fair business in the general public and enterprises in the Czech Republic and in foreign markets where ATRAK a.s. operates.

The Code of Ethics is effective from 1. 1. 2020

Aleš Kvídera,
Chairman of the Board, CEO