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Code of Conduct RFA 2023
Code of Conduct (RFA_UA)

Users: Malbi Foods LLC

DPK.K1.CODE 002.01-23

Document version dated 08/28/2023

1. INTRODUCTION

Our Code of Conduct is a commitment to ethical business practices. Our
business practices are based on integrity, honesty and fair conduct.
This Code of Conduct serves as our guidance and describes the principles that form the basis for
our decisions and actions. We, Malbi Foods LLC, build our business actions and decisions on these values.
The Code of Conduct is designed to help our employees and managers understand our
principles and act accordingly. Accordingly, this applies to each individual employee
Malbi Foods LLC.
The Code of Conduct aims to clearly communicate our business partners and customers our
requirements, values and principles.

2. MANAGEMENT COMMITMENT

The Code of Conduct presents mandatory principles that everyone must adhere to
employee of the company. In particular, members of senior management and all managers are responsible for
actively implement this Code of Conduct. They must be a worthy role model
in all respects.
We comply with the laws and other legal regulations of the countries in which we operate.

3. OBLIGATIONS OF SUPPLIERS AND SERVICE PROVIDERS

We expect our suppliers and service providers to adhere to the basic
values of the Code of Conduct, we support them in this and encourage them to do the same in their
companies and supply chains. Our service providers or suppliers must
comply with the laws and other legal regulations of the countries in which they operate.
We, Malbi Foods LLC, respect the rules of fair and open competition and do not enter into
no agreements that have an unacceptable effect on competition. This applies equally to
our suppliers and service providers.

4. CONFIDENTIALITY AND BUSINESS SECRETS

Our employees are obligated to maintain confidentiality regarding corporate and commercial
secrets and other internal matters. This also applies to classified information about any
contractual partners and customers. The obligation to maintain confidentiality continues after
termination of employment relations.

5. DATA CONFIDENTIALITY

In addition to the general confidentiality provisions, confidentiality must be observed
data in accordance with the Law of Ukraine "On Personal Data Protection" (The General Data
Protection Regulation (EU) 2016/679). In particular, it is prohibited to process, disclose, make
accessible or otherwise use protected personal data without permission for any
for any purposes other than those that are part of the relevant legitimate exercise of duties. This
The obligation to maintain data confidentiality continues even after leaving Malbi LLC.
Foods.

6. PRODUCT SAFETY AND QUALITY

We produce high-quality confectionery semi-finished products with all our production and
business units, thus making a significant contribution to customer satisfaction, maintaining
consistent product quality, optimal product safety and specific customer requirements. We
We strive to manufacture our products in accordance with all legislative, regulatory requirements and
customer requirements regarding food safety. Food Safety Management System
products implemented and certified to meet international standards
ISO22000:2018 and IFS Food v.7.
The company implements a food safety culture policy at all levels.

7. BRIBERY, MONEY LAUNDERING AND CORRUPTION

We, Malbi Foods LLC, are strongly opposed to any form of corruption. We do not
We do not tolerate any form of bribery and urge our business partners to take a clear stance
stance against corruption and bribery.
We refuse to do business with money obtained through criminal means.
Every company employee or business partner is required to report any
suspicions or legal doubts regarding the presence of corruption, bribery or money laundering.

8. RESOLUTION OF CONFLICTS OF INTEREST, GIFTS AND INVITATIONS

We recognize that decisions related to professional activities should not be influenced by
private interests or personal relationships. Therefore, situations in which this may arise should be avoided.
conflicts of interest.
The correct way to resolve potential conflicts is to fully disclose all the facts.
Even in connection with gifts and invitations, only absolute transparency can protect against
harm. To avoid creating the impression that a business partner or customer may benefit from
through gifts or invitations, no gifts or inappropriate invitations from a business
partner are generally not accepted. The only exception is low-value gifts, such as
promotional items.

9. FEEDBACK MECHANISM / COMPLAINTS MANAGEMENT

We want to maintain and strengthen the trust of our business partners and suppliers in us.
services, employees and the public. Therefore, feedback is very important to us in any
in any form, because every feedback contributes to continuous improvement. We would like to encourage everyone
business partners and employees to report any misconduct from our
side and inform us about actions that are not in line with our values and ethical principles of this
Code of Conduct.
First of all, we recommend that all business partners and employees contact
directly with your contact person, manager or trusted person in the company who
will look into your problem. You can use the contact form on our home page
page to contact us anonymously regarding any complaints/objections etc. We encourage
our employees also use this channel to solve their problems.

In principle, we will not follow up on complaints. However, if the information has a criminal
significance or violates applicable law, we reserve the right to conduct
investigation. All reports will be handled securely and confidentially.

10. PRINCIPLES OF SOCIAL RESPONSIBILITY

Social responsibility is an important component of value management. We respect
and support the protection of human and labor rights. In this context, we strive to
adhere to the UN Guiding Principles on Human and Labor Rights.
The prohibition of child and forced labor in any form is observed.
Discrimination in any form is not tolerated. We strongly oppose
unacceptable treatment of employees, as well as against violence, harassment, threats,
humiliation or harassment in the workplace.
We encourage equal opportunities and equality for our employees and actively work towards
so that none of our employees are discriminated against on the grounds of gender, ethical or
national origin, religion, age, disability or individual affiliation. We
have implemented a gender management system to promote equal treatment within the company. We,
Malbi Foods LLC, we encourage any employee who feels they are not being treated fairly.
treated equally, contact Confidential Consultants or express your concerns anonymously
concern about the contact form.
Workers' freedom of assembly and association is recognized within the limits permitted by law.
country's legislation. We comply with applicable national legislation and standards
work in terms of appropriate remuneration and maximum working hours. This of course includes
compliance with all provisions of the law governing the general minimum wage. We
We ensure fair working conditions in general. Safety and health at work
is provided within the framework of national regulations. We comply with all laws and regulations,
regarding health and safety at work to protect our employees. To this end
our managers take steps to create a healthy and safe working environment
for our employees.
As for the interests of consumers, the company complies with consumer protection legislation.
consumer rights.
It goes without saying that we expect all business partners and customers to be treated equally.
will adhere to our ethical and social principles.

11. PRINCIPLES OF ENVIRONMENTAL RESPONSIBILITY

Environmental protection is an important topic for us. All our employees
are obliged to treat all natural resources used in our
company (e.g. energy, water, land, etc.). Our responsible use of resources also
demonstrated by the implementation of an energy management system.
Our employees and business partners, as well as customers, expect responsible use
our resources in the production and distribution of our products to protect the environment
environment.

12. CONSEQUENCES OF FAILURE TO COMPLY WITH THE PRINCIPLES

This Code of Conduct integrates applicable laws and company regulations. Commitments
to adhere to the principles set out in the Code of Conduct follows directly from the laws,
company regulations, corporate instructions and directives or from the employment contract.
We, Malbi Foods LLC and all our employees act in accordance with this Code.
We recognize that failure to comply with this Code of Conduct, particularly through
intentional violations, can lead to serious consequences. This applies equally to our
business partners and service providers.

Contact us
Phone:
+38 (056) 794 55 05
or