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Code of Conduct
TOO “Bekem Trade”
General provisions
TOO “Bekem Trade” (Company) is involved with trade of IT equipment in the Republic of Kazakhstan. Compliance with the current legislation and ethics by its management, employees and partners is the foundation for Company’s business.
Code of Conduct (the Code) is a collection of most important rules of conduct applying to the Company, its employees and partners, ethical standards and internal corporate relations as well as major business principles.
Definitions
"Vendor" - company which manufactures the products that Company purchases for further resale.
"Partner" - company to which the Company sells vendors' products for further resale to end-users.
"Customer" - company that purchases products for its own use.
"Products" - equipment, services, software, work, services sold by vendors.
"Company" – ТОО «Bekem Trade», including all of its affiliates and divisions.
In all cases, when reference is made to vendor, partner, customer or the Company, it also applies to affiliates of the relevant organization, its consultants, contractors, management and employees.
Scope
The Code will be mandatory for all employees and partners of the Company.
If any vendor sets higher standards than the established Code - vendor's standards shall apply.
General Director of the Company controls the compliance with law and ethical norms by employees and partners and also participates in educational programs, preparation of information materials and other events held by the Company for the prevention of illegal and unethical behavior.
Training
Each employee of the Company will be required to undergo basic training in compliance with the current legislation and ethical principles of the Company, organized by the Company.
If any vendor requires that the Company employees shall perform a training organized by the vendor, the Company’s employees responsible for resale of production of such vendor shall perform the vendor’s training.
Compliance with the current legislation
The Company operates in strict accordance with the legislation of the Republic of Kazakhstan and international agreements, following generally accepted standards of business ethics, and standards of vendors.
If the current legislation contains less stringent rules than those of the Code and Vendors' Standards - the Code and Vendors' Standards should apply. On the other hand, if the current legislation includes more stringent requirements - the current legal norms should always apply.
Each employee of the Company shall comply with all applicable laws, rules and regulations, as well as policies and procedures. An employee shall not engage in any activities that violate any applicable laws of the Company, its rules and regulations, and all policies and procedures of the Company. These include, without limitation: laws on anti-corruption, copyright, trademarks and trade secrets, information protection, confidentiality of personal data, protection of competition, export control, negative environmental impact, discrimination in employment, working conditions and safety.
It is assumed that all Company's employees understand and comply with all such laws, rules and regulations, as well as policies and procedures.
Prohibition of improper payments
Company employees are strictly forbidden to make, promise, authorize, solicit or receive, directly or indirectly, any improper payments in cash, property or any other form. Company employees are strictly prohibited from offering, receiving or permitting, directly or indirectly, offering valuable gifts to any member of state or international organization, political party or candidate for public office, employee of a state-owned or controlled entity, employee of non-profit or non-governmental organization (e.g. the World Bank, the United Nations, the International Red Cross), or officers or employees of any organization or their agents, customers or suppliers, or their close relatives in order to obtain improper business advantages.
According to anti-corruption legislation standards, employees are prohibited, directly or indirectly to make, offer, promise or authorize payments in the form of money or anything of value, and to provide any financial or other benefits or advantages to any third party in order to (1) influence their actions due to their position (or ensure inaction), or (2) encourage or reward the improper performance of their duties.
In addition, all employees of the Company will be prohibited to demand, consent to or receive any payments in the form of money or anything of value, and any financial or other benefits or advantages, if receipt of such payments, benefits or advantages (1) is in itself an improper performance of their official duties, or (2) will be a reward for improper performance of their official duties.
Financial Transparency
Recording transactions and safekeeping of documents. The Company will maintain complete and accurate records of all its transactions (concerning purchasing, sales, marketing activities, etc.). The Company maintains a complete and accurate accounting and financial reporting, and makes reports stipulated by its agreements with counterparties.
Financial statements, documents and records must be kept properly, reflect all real business transactions of the Company and should be retained for the period specified by applicable law.
Targeted spending. Spending of funds provided by suppliers, partners and / or vendors will be done only in accordance with procedures established by suppliers, partners and / or vendors or agreed in contracts with suppliers, partners and / or vendors. Any undocumented expenditure of such funds will be prohibited. Similar rules shall apply to expenditure of any funds being provided to the Company for any goals, as well as funds provided by the Company to its employees.
Prohibition of back-dating. All documents will be signed only with the current date. Advance-dated or post-dated paperwork will be prohibited. All documents will be signed only by duly authorized persons.
Representation and other expenses
All costs made by employee of the Company in the interests of representatives of partners, customers or vendors must be reasonable and customary for business practices, so they can not be regarded as a bribe or any other violation of the relevant anti-corruption laws.
In any case, business expenses must be made in such a way that they can not be seen as an attempt to influence the recipient's opinion, so that company could gain an unfair advantage.
Any expenses that the employee performs on behalf of the Company, should be justified, proportionate and documented.
The main criterion for validity and adequacy of expenditure will be whether public disclosure of such information would harm the Company, its customers, partners or vendors.
Employees of the Company may from time to time, accept or make invitations for lunch / dinner or entertainment event, if (a) the cost of such lunch / dinner or entertainment is reasonable (for example, lunch or dinner is of the same value as those offered to other representatives of vendor, partner or customer), (b) the purpose of the meeting is purely business.
Under no circumstances shall the Company employees offer or accept business meetings in places featuring entertainment for adults.
Company employees have the right to accept or offer low cost promotional materials or promotional products.
Compliance with competition law
The Company will strictly follow the current competition law.
In particular, the Company shall refrain from entering into agreements with its competitors:
- On price fixation or price control;
- On manipulation of price proposals;
- On boycotting any vendors (suppliers), partners or customers;
- On division of the market or customers portfolios;
- On limiting sales of any products or product lines.
The Company will not use unfair methods of competition in its activities, such as:
- Dissemination of false, inaccurate or distorted information about the Company's competitors or vendors that compete with each other;
- Misrepresentation as to the nature, method and place of production, consumer characteristics, quality or quantity of the goods, or in respect of its producers;
- Incorrect comparison of the goods of one manufacturer with products of another manufacturer;
- Illegal use of trademarks and other intellectual property rights;
- Disclosure of information constituting a trade secret.
Protection of intellectual property and confidential information
Intellectual property. The Company sells computer hardware, software, and other high-tech products, which are produced with the use of intellectual property objects.
The Company respects intellectual property rights of others and does use the results of intellectual activities of other companies (e.g., trademarks, software, documentation, proprietary technology) without permission.
If during the performance of his official duties, an employee of the Company becomes aware of any violation of intellectual property rights of third parties, he shall immediately notify his supervisor thereof.
Confidential information. The Company protects confidential information, both its own, and received from third parties. The Company protects personal data of its employees as well as third parties.
Materials containing confidential information and / or personal data will be stored in such a way as to prevent unauthorized access, and may be used only by duly authorized officers of the Company.
Every employee will be required to keep commercial secrets of the Company or any third party, except where disclosure of such information is authorized by its owner or appropriate in accordance with the current legislation. Employee's obligations regarding commercial confidentiality remain in force even after the employee leaves the Company.
Conflict of interest
Each employee must act in the interests of the Company. Conflict of interest is a situation where, because of personal, family or other reasons, the employee is unable to make objective decisions in relation to the Company.
The best policy to prevent a conflict of interest is not to participate directly or indirectly in business relationships with vendors, partners, or customers, except on behalf of the Company.
In order to detect and prevent situations that could cause a conflict of interests with the Company, an employee of the Company shall comply with the following rules:
Relations between the Company and its employees
The Company prohibits discrimination of employees based on gender, age, race, nationality, religion, political beliefs, marital status, pregnancy, sexual orientation, etc.
This shall apply to all aspects of employment, including hiring, training, promotion, compensation, discipline and dismissal.
Any employee of the Company shall be employed after studying his resume and interviewing, and if necessary - testing. All candidates will have equal conditions of employment. Any preference, except as to objective advantages or merits of the candidate, will be prohibited.
All employees of the Company will be responsible for creating and maintaining a working environment free from harassment and other inappropriate behavior.
The Company will provide a safe and healthy work environment for its employees. Each employee shall immediately inform their supervisor immediately of all accidents, dangerous conditions and any situation, which, in his opinion, may threaten the lives and health of workers.
Relations with government organizations and officials
The Company will strictly follow the current legislation relating to the supply of goods, works and services for state needs and execution of government contracts.
For purposes of this section, "public organizations" will mean international organizations, non-profit and non-governmental organizations (e.g. the World Bank, the United Nations, the International Red Cross), political parties, public authorities, local governments, enterprises with state ownership or state controlled, municipal enterprises. "Officials" will mean employees of all of the above entities and organizations, as well as candidates for state or municipal offices.
Each employee of the Company should be aware that some of the actions that are acceptable in relationships with non-governmental organizations, may not be appropriate in dealing with government organizations.
When working with government organizations (both directly and through partners), observe the following rules:
Any transaction of the Company with participation or in the interest of a state organization should be agreed in writing by the General Director.
Reporting of violations
If a complicated business decision not covered by the Code should be taken, it is necessary to ask yourself the following questions:
In the case an employee has any questions as to the contents of the Code, interpretation of any of its provisions or doubts as to correct behavior in a given situation, the employee should contact his immediate supervisor and General Director.
If an employee of the Company becomes aware of any violations of the provisions of this Code, applicable laws or vendor's standards, both from the part of another employee of the Company, or from the part of the vendor, partner or customer - he shall immediately notify his immediate supervisor and General Director thereof.
Any employee who violates the provisions of this Code or applicable law, may be subject to disciplinary action.
TOO “Bekem Trade” (Company) is involved with trade of IT equipment in the Republic of Kazakhstan. Compliance with the current legislation and ethics by its management, employees and partners is the foundation for Company’s business.
Code of Conduct (the Code) is a collection of most important rules of conduct applying to the Company, its employees and partners, ethical standards and internal corporate relations as well as major business principles.
Definitions
"Vendor" - company which manufactures the products that Company purchases for further resale.
"Partner" - company to which the Company sells vendors' products for further resale to end-users.
"Customer" - company that purchases products for its own use.
"Products" - equipment, services, software, work, services sold by vendors.
"Company" – ТОО «Bekem Trade», including all of its affiliates and divisions.
In all cases, when reference is made to vendor, partner, customer or the Company, it also applies to affiliates of the relevant organization, its consultants, contractors, management and employees.
Scope
The Code will be mandatory for all employees and partners of the Company.
If any vendor sets higher standards than the established Code - vendor's standards shall apply.
General Director of the Company controls the compliance with law and ethical norms by employees and partners and also participates in educational programs, preparation of information materials and other events held by the Company for the prevention of illegal and unethical behavior.
Training
Each employee of the Company will be required to undergo basic training in compliance with the current legislation and ethical principles of the Company, organized by the Company.
If any vendor requires that the Company employees shall perform a training organized by the vendor, the Company’s employees responsible for resale of production of such vendor shall perform the vendor’s training.
Compliance with the current legislation
The Company operates in strict accordance with the legislation of the Republic of Kazakhstan and international agreements, following generally accepted standards of business ethics, and standards of vendors.
If the current legislation contains less stringent rules than those of the Code and Vendors' Standards - the Code and Vendors' Standards should apply. On the other hand, if the current legislation includes more stringent requirements - the current legal norms should always apply.
Each employee of the Company shall comply with all applicable laws, rules and regulations, as well as policies and procedures. An employee shall not engage in any activities that violate any applicable laws of the Company, its rules and regulations, and all policies and procedures of the Company. These include, without limitation: laws on anti-corruption, copyright, trademarks and trade secrets, information protection, confidentiality of personal data, protection of competition, export control, negative environmental impact, discrimination in employment, working conditions and safety.
It is assumed that all Company's employees understand and comply with all such laws, rules and regulations, as well as policies and procedures.
Prohibition of improper payments
Company employees are strictly forbidden to make, promise, authorize, solicit or receive, directly or indirectly, any improper payments in cash, property or any other form. Company employees are strictly prohibited from offering, receiving or permitting, directly or indirectly, offering valuable gifts to any member of state or international organization, political party or candidate for public office, employee of a state-owned or controlled entity, employee of non-profit or non-governmental organization (e.g. the World Bank, the United Nations, the International Red Cross), or officers or employees of any organization or their agents, customers or suppliers, or their close relatives in order to obtain improper business advantages.
According to anti-corruption legislation standards, employees are prohibited, directly or indirectly to make, offer, promise or authorize payments in the form of money or anything of value, and to provide any financial or other benefits or advantages to any third party in order to (1) influence their actions due to their position (or ensure inaction), or (2) encourage or reward the improper performance of their duties.
In addition, all employees of the Company will be prohibited to demand, consent to or receive any payments in the form of money or anything of value, and any financial or other benefits or advantages, if receipt of such payments, benefits or advantages (1) is in itself an improper performance of their official duties, or (2) will be a reward for improper performance of their official duties.
Financial Transparency
Recording transactions and safekeeping of documents. The Company will maintain complete and accurate records of all its transactions (concerning purchasing, sales, marketing activities, etc.). The Company maintains a complete and accurate accounting and financial reporting, and makes reports stipulated by its agreements with counterparties.
Financial statements, documents and records must be kept properly, reflect all real business transactions of the Company and should be retained for the period specified by applicable law.
Targeted spending. Spending of funds provided by suppliers, partners and / or vendors will be done only in accordance with procedures established by suppliers, partners and / or vendors or agreed in contracts with suppliers, partners and / or vendors. Any undocumented expenditure of such funds will be prohibited. Similar rules shall apply to expenditure of any funds being provided to the Company for any goals, as well as funds provided by the Company to its employees.
Prohibition of back-dating. All documents will be signed only with the current date. Advance-dated or post-dated paperwork will be prohibited. All documents will be signed only by duly authorized persons.
Representation and other expenses
All costs made by employee of the Company in the interests of representatives of partners, customers or vendors must be reasonable and customary for business practices, so they can not be regarded as a bribe or any other violation of the relevant anti-corruption laws.
In any case, business expenses must be made in such a way that they can not be seen as an attempt to influence the recipient's opinion, so that company could gain an unfair advantage.
Any expenses that the employee performs on behalf of the Company, should be justified, proportionate and documented.
The main criterion for validity and adequacy of expenditure will be whether public disclosure of such information would harm the Company, its customers, partners or vendors.
Employees of the Company may from time to time, accept or make invitations for lunch / dinner or entertainment event, if (a) the cost of such lunch / dinner or entertainment is reasonable (for example, lunch or dinner is of the same value as those offered to other representatives of vendor, partner or customer), (b) the purpose of the meeting is purely business.
Under no circumstances shall the Company employees offer or accept business meetings in places featuring entertainment for adults.
Company employees have the right to accept or offer low cost promotional materials or promotional products.
Compliance with competition law
The Company will strictly follow the current competition law.
In particular, the Company shall refrain from entering into agreements with its competitors:
- On price fixation or price control;
- On manipulation of price proposals;
- On boycotting any vendors (suppliers), partners or customers;
- On division of the market or customers portfolios;
- On limiting sales of any products or product lines.
The Company will not use unfair methods of competition in its activities, such as:
- Dissemination of false, inaccurate or distorted information about the Company's competitors or vendors that compete with each other;
- Misrepresentation as to the nature, method and place of production, consumer characteristics, quality or quantity of the goods, or in respect of its producers;
- Incorrect comparison of the goods of one manufacturer with products of another manufacturer;
- Illegal use of trademarks and other intellectual property rights;
- Disclosure of information constituting a trade secret.
Protection of intellectual property and confidential information
Intellectual property. The Company sells computer hardware, software, and other high-tech products, which are produced with the use of intellectual property objects.
The Company respects intellectual property rights of others and does use the results of intellectual activities of other companies (e.g., trademarks, software, documentation, proprietary technology) without permission.
If during the performance of his official duties, an employee of the Company becomes aware of any violation of intellectual property rights of third parties, he shall immediately notify his supervisor thereof.
Confidential information. The Company protects confidential information, both its own, and received from third parties. The Company protects personal data of its employees as well as third parties.
Materials containing confidential information and / or personal data will be stored in such a way as to prevent unauthorized access, and may be used only by duly authorized officers of the Company.
Every employee will be required to keep commercial secrets of the Company or any third party, except where disclosure of such information is authorized by its owner or appropriate in accordance with the current legislation. Employee's obligations regarding commercial confidentiality remain in force even after the employee leaves the Company.
Conflict of interest
Each employee must act in the interests of the Company. Conflict of interest is a situation where, because of personal, family or other reasons, the employee is unable to make objective decisions in relation to the Company.
The best policy to prevent a conflict of interest is not to participate directly or indirectly in business relationships with vendors, partners, or customers, except on behalf of the Company.
In order to detect and prevent situations that could cause a conflict of interests with the Company, an employee of the Company shall comply with the following rules:
- avoid any action that may affect his ability to make objective business decisions in the interests of the Company, for example, refrain from accepting gifts (other than gifts of little value), services and other benefits from persons who have a business relationship with the Company or seek such relationship.
- If an employee of the Company becomes aware of the existence of a conflict of interest between him and the Company, or is unsure if such a conflict exists, he should contact his supervisor;
- it is unacceptable to have a personal interest in the activities of Company's contractors, if such interest is contrary to the business interests of the Company;
- it is unacceptable to take up additional jobs or engage in other after hours activities, if such activities adversely affect the performance of employee's official duties in the Company;
- it is not allowed to receive gifts, favors, loans or other material benefit from natural or legal persons who have business relations with the Company or seek such business relationship;
- it is prohibited to conceal the fact of conflict of interest and its cause.
Relations between the Company and its employees
The Company prohibits discrimination of employees based on gender, age, race, nationality, religion, political beliefs, marital status, pregnancy, sexual orientation, etc.
This shall apply to all aspects of employment, including hiring, training, promotion, compensation, discipline and dismissal.
Any employee of the Company shall be employed after studying his resume and interviewing, and if necessary - testing. All candidates will have equal conditions of employment. Any preference, except as to objective advantages or merits of the candidate, will be prohibited.
All employees of the Company will be responsible for creating and maintaining a working environment free from harassment and other inappropriate behavior.
The Company will provide a safe and healthy work environment for its employees. Each employee shall immediately inform their supervisor immediately of all accidents, dangerous conditions and any situation, which, in his opinion, may threaten the lives and health of workers.
Relations with government organizations and officials
The Company will strictly follow the current legislation relating to the supply of goods, works and services for state needs and execution of government contracts.
For purposes of this section, "public organizations" will mean international organizations, non-profit and non-governmental organizations (e.g. the World Bank, the United Nations, the International Red Cross), political parties, public authorities, local governments, enterprises with state ownership or state controlled, municipal enterprises. "Officials" will mean employees of all of the above entities and organizations, as well as candidates for state or municipal offices.
Each employee of the Company should be aware that some of the actions that are acceptable in relationships with non-governmental organizations, may not be appropriate in dealing with government organizations.
When working with government organizations (both directly and through partners), observe the following rules:
- it is unacceptable to receive any information about a state organization (or an official person) from any source, which is not officially published, any inside information on state organization, or competitive information (e.g. information on price offers);
- any documents issued on behalf of the Company to the state organization shall be made out accurately and precisely, in accordance with the applicable regulations and legislation;
- in relations with officials it is prohibited to give or offer, directly or indirectly, any gift, favor, entertainment, loan or other material provision, except as permitted under the current legislation. The Company applies this rule to all officials;
- it is strictly forbidden to provide or offer, directly or indirectly, any payment or refund ("kickback") in order to gain an advantage with respect to any transaction;
- it is strictly forbidden to provide or offer, directly or indirectly, any payment to any party for a state contract or in order to influence the decision of a state customer.
Any transaction of the Company with participation or in the interest of a state organization should be agreed in writing by the General Director.
Reporting of violations
If a complicated business decision not covered by the Code should be taken, it is necessary to ask yourself the following questions:
- would this be legal?
- would this be honest and fair?
- would this be in line with the Company's interests?
- would this comply with the rules of the Company?
- do you have powers to do it?
- will you feel comfortable, if this information is published in the media?
In the case an employee has any questions as to the contents of the Code, interpretation of any of its provisions or doubts as to correct behavior in a given situation, the employee should contact his immediate supervisor and General Director.
If an employee of the Company becomes aware of any violations of the provisions of this Code, applicable laws or vendor's standards, both from the part of another employee of the Company, or from the part of the vendor, partner or customer - he shall immediately notify his immediate supervisor and General Director thereof.
Any employee who violates the provisions of this Code or applicable law, may be subject to disciplinary action.
This Code contains the basic principles of Company's business ethics. All representatives will be obliged to abide by them, and each employee will be personally responsible for his behavior. Activities that do not comply with legal regulations or this Code can not be justified by reference to the fact that such were the instructions from some of the senior managers.