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Ethical Commandments

As a member of an international financial group, SGEF adheres to SG Group’s codes, specifically the Group Code of Conduct and the Anti-corruption Code. We expect our business partners to observe the same rules.

WE CONDUCT OURSELVES ETHICALLY AND RESPONSIBLY TOWARDS OUR EMPLOYEES AND THE ENVIRONMENT
  • We adhere to the principles laid down in the SG Group Code of Conduct.
  • We deliver on the commitments undertaken by SG as a responsible Group.
  • We are committed to the protection of human rights and fundamental freedoms, and we guard against any threats to them.
  • We treat all employees fairly and take care to comply with all legal requirements.
  • We protect the health and safety of our employees.
  • The foreign nationals we employ hold permits to reside and work in the Czech Republic where this is required by law. We are committed to environmental protection and sustainable development.
  • We have crisis response procedures and scenarios in place to mitigate any losses we or our business partners may incur.
WE HAVE NO CRIMINAL RECORD AND NO INTERNATIONAL SANCTIONS HAVE BEEN IMPOSED ON US
  • Neither our company nor its assets are subject to any judicial, administrative or arbitration proceedings.
  • The discharge of our obligations under supply contracts is not compromised by any criminal prosecution of our company or members of its governing body.
  • No members of our company’s management are subject to criminal penalties or to measures imposed for reasons of protection or prevention, and none of them has been convicted of a criminal offence in the past.
  • No economic or financial sanctions, trade embargoes or similar measures adopted by the UN, the US, the UK or the EU have been placed on us.
WE PAY VAT
  • We are reliable payers of VAT.
  • The payment we charge for taxable supply is economically justified and consistent with the open market price.
WE FIGHT CORRUPTION
  • We adhere to the SG Anti-corruption Code.
  • We comply with anti-corruption legislation in all cases.
  • We do not engage in conduct that might be construed as corruption or bribery.
  • No authority has disqualified us from participating in public tenders on grounds of corruption or bribery.
  • We apply rules and processes to safeguard against corrupt practices and to ensure that any suspected corrupt practices are investigated with due diligence.
  • We maintain detailed and meticulous accounting, files and other records related to supply contracts.
  • We do not accept or offer any special privileges or gifts of any kind.
CONFIDENTIAL INFORMATION AND PERSONAL DATA ARE SAFE WITH US
  • We hold confidential information in strict confidence.
  • We use confidential information, know-how, databases and business information solely within the framework of contractual cooperation and do not exploit it for our personal or third-party gain.
  • We adhere to all legislation governing the protection of the personal data of our clients, employees and contractual partners.
  • We handle personal data in a manner that precludes unauthorised access and processing, alteration, destruction, loss or misuse.
WE HAVE ZERO TOLERANCE OF MONEY LAUNDERING AND TERRORIST FINANCING
  • We comply with obligations imposed on us by the Ant-money Laundering and Terrorist Financing Act.
  • We are not a politically exposed person, as defined by that law.
  • We thoroughly screen prospective customers, conduct ongoing checks, report suspicious transactions in a timely manner, provide staff training, and maintain a system of internal policies.
     

WHISTLEBLOWING

We adhere to ethical principles and legal standards in our business and treat our business partners and customers with respect. If such principles or standards are breached, a whistleblowing report may be filed, in which case the whistleblower is guaranteed complete anonymity and confidentiality. You can email a whistleblowing report to whistleblowing@kb.cz (Komerční banka’s internal reporting system). Alternatively, you can directly contact the following members of staff, who are responsible for handling whistleblowing reports:

We will send our reply to the email address from which we have received the alert. Outside the environment of Komerční banka, you can also send a whistleblowing report to the Ministry of Justice  as the competent authority for handling whistleblowing reports.