Code of ethics

Code of Ethics of Office Max SRL

1. CODE OF ETHICS

The code of ethics defines the set of values ​​and principles underlying the company's activities, therefore stating the principles of corporate conduct that the company recognizes as its own and which must be respected by all employees. For this reason it is an essential component of the company's preventive control system.

Its purpose, therefore, is not only to inform the public about the company's commitment to the fight against illegal practices, but also to increase awareness and information about corporate policies among all employees, amplifying the sense of belonging and possibly changing different behaviors.

The values ​​and rules of conduct of the Code of Ethics are the basis of our corporate culture, which is based on the attention given to qualitative excellence obtained through a permanent technological innovation, ensuring the guarantee and full protection of Customers and the environment. These principles and rules must be an integral part of the company's cultural heritage and represent a significant competitive advantage.

OFFICE MAX SRL is aware that the adoption of a Code of Ethics is essential in the prevention of crimes, considering at the same time that the adoption of such a code can guarantee the reliability of the company, as well as the integrity of its reputation. Therefore, this document, adopted by the Administrator of Office Max, establishes the ethical principles that OFFICE MAX SRL respects in carrying out its activities and whose strict compliance it also requires from the company's representatives, its employees and all those who participate in his mission.

For this purpose, the widest dissemination of the Code of Ethics is ensured, including through an appropriate training and awareness program regarding its content.

1.1 RECIPIENTS

The code of ethics of OFFICE MAX SRL is addressed to the Company's staff and third parties. The code of ethics also applies to third-party recipients, i.e. to persons who, without being part of the company, participate directly or indirectly in achieving its objectives (for example: agents, consultants, suppliers, etc.) These persons, within the limits of their competences and their responsibilities, are obliged to comply with the provisions of the Code of Ethics.

For this purpose, a series of special clauses will be inserted in employment decisions and/or contractual agreements to confirm the third party's obligation to fully comply with the Code of Ethics, as well as to provide, in the event of a violation, to request compliance with it or the application of penalties or even termination of the contract.

1.2 DISCLOSURE

The code of ethics of OFFICE MAX SRL is disclosed by all possible means. Each employee and collaborator will receive an electronic copy. The code is also made available to suppliers, customers and all interested parties via the OFFICE MAX SRL website.

2. GENERAL PRINCIPLES

The main objective of OFFICE MAX SRL is to carry out the activity respecting all the components of the Company, of third parties and, in general, of the legislation in force. Economic and financial strategies and derivative operations are designed in this direction, inspired by the efficient use of resources but, at the same time, by respecting the rules underlying them. To pursue this objective, the Company, as well as all its components, adheres to the following principles of conduct.

2.1 IMPARTIALITY

Decisions regarding the relationship with customers, shareholders, staff, suppliers, local community and institutions are based on impartiality; in this way OFFICE MAX SRL avoids any discrimination related to age, sex, state of health, race, nationality, political opinion or religious beliefs.

2.2 HONESTY

As an active and responsible member of the community in which it operates, OFFICE MAX SRL undertakes to respect and ensure compliance by all employees, internally and in relations with the outside world, of the laws in force in the places where they do their work. carries out the activity and the ethical principles accepted and established by the national and international standards for the conduct of business. It abhors and condemns resorting to illegal or dishonest behavior to achieve its economic goals.

2.3 FAIRNESS AND CONFLICT OF INTEREST

Staff must avoid involvement or facilitation of transactions that involve real or potential conflicts of interest with the company, with OFFICE MAX SRL, as well as activities that may interfere with the ability to impartially take decisions in the interest of the company and in accordance with the provisions this code. In particular, staff must not have a financial interest in a supplier, competitor or customer and must not perform activities that could lead to a conflict of interest. In the event of the existence of a conflict of interest, even a potential one, the staff must communicate it to the superior and take no action.

2.4 CONFIDENTIALITY

The staff must treat with absolute confidentiality, even after the termination of the employment relationship, the data, news and information brought to their attention and/or in their possession, avoiding their dissemination or speculative use in their own interest or that of others . Confidential information may be disclosed within the company only to those persons who need to know it for business reasons. The Company considers confidentiality as a fundamental and necessary rule of any conduct and therefore ensures the confidentiality of information in its possession, refraining from using confidential data, unless expressly and knowingly authorized and , however, always strictly respecting the legislation in force regarding the protection of privacy.

2.5 VALUATION OF HUMAN RESOURCES

OFFICE MAX SRL recognizes the centrality of human resources, which are the key to the success of any company. In this perspective, if, on the one hand, the Company is committed to increasing the level of professionalism of each employee, on the other hand, the employees are committed to expanding their knowledge through constant updating in a field of competence.

2.6 CREATION OF VALUE

The OFFICE MAX SRL company is actively involved in order for the economic/financial results to protect and increase the value, in order to properly remunerate the risk assumed by the shareholders.

2.7 ANTI-MONEY LAUNDERING/CONCEALING

Within the various relationships established with the Company and outside of it, neither the Company's companies nor their employees must, in any way and under any circumstances, be involved in events related to money laundering from illegal or criminal activities.

Staff will be required to use all tools and take all necessary precautions to ensure transparency and fairness in business transactions. In particular, it is mandatory that:

a) entrusting various tasks to service companies and/or natural persons who deal with the economic/financial interests of the company to be carried out in written, e-mail or holograph communication, indicating the content and the agreed economic conditions;

b) the competent persons to verify the regular payment to all parties involved and the correspondence between the person in whose name the order is made and the person collecting the amounts is always controlled;

c) the minimum objective / established and necessary requirements for the selection of the entities from which goods and/or services will be purchased must be strictly observed;

d) to establish the objective criteria for evaluation of offers;

e) regarding the commercial/professional reliability of suppliers and partners, all necessary information be requested and obtained;

f) in the case of concluding agreements aimed at making investments, full transparency is guaranteed.

2.8 INTEGRITY OF THE PERSON

The company OFFICE MAX SRL is committed to encouraging a work environment and behaviors based on respect for the dignity and personality of the individual, as well as for the protection of the health and safety of workplaces and workers.

2.9 TRANSPARENCY AND FULL DISCLOSURE

OFFICE MAX SRL collaborators must provide complete, transparent, easy-to-understand and accurate information, so that shareholders can make autonomous and informed decisions regarding the interests involved, the alternatives and the relevant consequences.

2.10 FAIR COMPETITION

OFFICE MAX SRL ensures the market and the community, in general, while protecting competitiveness, full transparency regarding its activities, refraining from engaging and/or facilitating those behaviors that may constitute forms of unfair competition. It is committed to promoting fair competition, considering it to be the best solution both in its interest and that of all market participants, customers and consumers.

2.11 QUALITY

The activity carried out by OFFICE MAX SRL aims to satisfy and protect its customers, favoring the continuous improvement of the quality of products and services.

2.12 PROTECTION OF THE ENVIRONMENT

The OFFICE MAX SRL company has always fought for the investments made to be ecological and sustainable, trying to prevent risks for local communities and the environment, taking into account scientific research on this topic.

3. CONDUCT CRITERIA

3.1 RULES OF CONDUCT REGARDING CORPORATE GOVERNANCE

The governing bodies act and decide autonomously, respecting the principles of legality and fairness, pursuing only the interests of society. The independence of judgment is an essential requirement of the Governing Bodies, therefore they must ensure maximum transparency in the administration of operations in which they have particular interests. The company promotes transparency and periodic information of shareholders, in accordance with the laws and regulations in force. Any special or biased interest is denied: all associates' interests are promoted and protected equally. OFFICE MAX SRL aims for the correct conduct of meetings, ensuring each participant the right to actively participate in the debate. The company aims to spread information regarding the company's accounting in the most transparent way. Staff will need to pay particular attention to the preparation of financial statements and other corporate documents. In this sense, it is necessary to ensure adequate cooperation with the persons responsible for drawing up corporate documents; the completeness, clarity and accuracy of the data and information provided; compliance with the principles of preparing accounting documents. The company promotes and spreads the culture of control, at all levels of the company, sensitizing its employees on the importance of the internal control system and compliance with the legislation in force and company procedures for the performance of activities. Each action, operation or transaction must be correctly recorded in the company's accounting system, in accordance with the criteria established by law and the applicable accounting principles, while being properly authorized, verifiable, legitimate, consistent and appropriate.

3.2 RULES OF CONDUCT FOR EMPLOYEES

The staff is selected through transparent and documented procedures, in accordance with the principles of equality and equal opportunities, thus avoiding any form of favoritism. Employment relationships are formalized through contracts, rejecting any form of illegal work.

OFFICE MAX SRL rejects any form of discrimination regarding its employees and promotes the professional development of all collaborators by offering appropriate training plans. OFFICE MAX SRL authorizes the use of the company's IT systems, however the staff must use, in the performance of their professional activities, IT or telematics tools and services in full compliance with the regulations in force (especially with regard to IT crimes, IT security, privacy and copyright) and with internal procedures. Personnel may not upload borrowed or unauthorized software to company systems, and unauthorized copying of licensed programs for personal, company or third-party use is also prohibited. The staff must use the computers and IT tools provided by the company only for the purpose of carrying out the professional activity within the company; therefore, the company reserves the right to control the content of the computer and the correct use of computer tools. At the same time, the staff is obliged not to send e-mail messages containing threats or insults, not to resort to language expressions that are not in accordance with the company's style or inappropriate language.

3.3 RULES OF CONDUCT FOR CUSTOMERS AND SUPPLIERS

In relations with customers, suppliers and service providers / other third parties, the staff must show full fairness and transparency, taking into account the rules for carrying out the activity and the specific ethical principles on which the company's activity is based. Professionalism, competence, availability, courtesy and fairness are the essential principles that must guide the company's employees in their relations with customers and suppliers.

3.4 RULES OF CONDUCT IN REGARDS TO PUBLIC ADMINISTRATION

All relations with civil servants or representatives of public services must be fully compliant with the legislation and regulations in force, as well as with the Code of Ethics, in order to ensure the legitimacy, transparency and integrity of the Company's activity. In particular, it is prohibited for Company personnel to accept, offer or promise, even indirectly, money, gifts, goods, services, benefits or favors (including in the form of employment opportunities or through activities - including commercial - in the direct interest or indirectly of the employee) in their relations with public officials, with representatives of public services, in order to influence their decisions in order to obtain preferential treatment, unjustified services or for any other purpose, including the performance of their official functions. Gifts and favors for public officials, public service managers or other public employees are allowed only when, being of small value, they do not compromise in any way the integrity and independence of the parties and cannot be interpreted as tools for obtaining undue advantages. No action that falls under the umbrella of corruption can be justified or tolerated by the fact that it is a "custom" in the business sector or in the activity carried out. It is not permitted to solicit or accept benefits that can only be provided by compromising the values ​​and principles of the Code of Ethics or by violating applicable laws and procedures. In the case of investigations, inspections or requests by public authorities, the staff is obliged to cooperate in full compliance with the legislation in force.

3.5 COMMUNICATION WITH THE OUTSIDE

Relations with the press and the means of communication and information are only the competence of the persons expressly authorized for this, in accordance with the degree of representation of the company, the procedures and policies adopted by the company.

4. HEALTH AND SAFETY AT THE WORKPLACE

Personnel must take care of their own health and safety and must carry out their work in such a way as not to affect the health and safety of other persons in the workplace, in accordance with what they have learned during the training courses, with the instructions and equipment provided by to the employer. In particular, staff must:

a) Contribute, together with the employer, directors and managers, to the fulfillment of their obligations under the rules of health and safety protection at work;

b) To comply with the provisions and instructions of the employer, directors and managers for the purpose of collective and individual protection;

c) To correctly use equipment, dangerous substances and preparations, means of transport and protective equipment;

d) To adequately use the protective equipment made available to him;

e) To immediately inform the employer, the director or the person in charge of the lack or malfunction of the equipment from letter c) and d), as well as to any dangerous situation that is brought to his attention, acting personally, in case of emergency and within the limits of his own skills and abilities, with the exception of the obligation provided for in letter f), in order to eliminate or reduce serious and imminent dangers, informing the employee representative responsible for security;

f) Not to remove or modify safety, warning or control devices without authorization;

g) To take care of the personal protective equipment provided, without changing it on his own initiative and to report any defects to the employer or the director or the person in charge;

h) Not to carry out on their own initiative operations that may compromise their own safety or that of other workers;

i) To participate in training programs organized by the employer;

j) To carry out the medical checks provided for by law or required by the competent doctor.

5. OFFENSES

The rules of the Code of Ethics are an essential part of any contractual obligation of the staff. In particular, employees are obliged to:

- to strictly comply with the provisions of the Code of Ethics, refraining from any behavior contrary to them;

- to report to superiors or, alternatively, to the administrator any information regarding alleged violations of this Code of Ethics within the company;

- cooperate fully in the investigation of possible and/or alleged violations of this Code of Ethics;

- to inform third parties who collaborate with the Company about the requirements of the Code of Ethics and request their compliance.

They are obliged to respect the principles of the Code of Ethics and the Company's collaborators (including, by way of example, consultants, agents, representatives, intermediaries, etc.) and any person who has business relations with the Company (with the exception of public entities, consumers and those who works in a monopoly regime).

The company imposes disciplinary sanctions for violating the rules of this Code of Ethics.

Contact address reclamatii@officemax.ro