Code of Ethics ELTEK Group – Revision 2 - Issued 2017 – Page 1 of 21
ELTEK GROUP CODE OF ETHICS
Code of Ethics ELTEK Group – Revision 2 - Issued 2017 – Page 2 of 21
This Code of Ethics has been developed to define, in a clear and
transparent way, the values inspiring the ELTEK Group and the
rules of conduct to be derived therefrom.
Compliance with these standards is required to all employees of
the Group, as well as to those who, in any other capacity,
collaborate in the business activities.
The Directions of all Group divisions and plants are responsible
for divulgation and implementation of this Code through
widespread distribution, promotion and factual example, daily.
INTRODUCTION
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WHAT IS A CODE OF ETHICS?
It is a document that summarizes and explains the reference
values of the ELTEK Group and behaviours to ensure compliance
with the said values.
WHO IS IT FOR?
All ELTEK employees, regardless of their level and their plant.
The Code of Ethics also applies to third parties who, for various
contract reasons (such as project workers, agents, etc.), act in the
name and on behalf of ELTEK.
WHY?
To illustrate clearly the patterns of behaviour to which we must
adhere, and provide information about entities to which we can
turn to report any situations and inappropriate behaviours.
INTRODUCTION
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As part of its activities, the ELTEK Group refers to the following
essential values:
Legality:
We adhere unconditionally to the principle of legality.
All ELTEK plants act within the laws, regulations and rules of the
countries where they operate.
Business ethics
We pledge to work with honesty, integrity and fairness, and we
expect the same approach by our counterparts. We do not allow
any actions which, although in the interests of the Group, may
involve a violation of the regulations in force or this Code.
Orientation to the future
To be future-oriented, for us means:
acting in the interests of the Group, to ensure its
profitability and therefore continuity over time;
acting in the interests of civil society, and especially of
future generations, by preserving non-renewable resources and
the environment in which we operate and where our products are
used.
Human rights
We respect, we affirm the universality and we promote the
compliance with internationally recognized human rights.
Child labour
We respect children's rights and we condemn child labour.
Freedom of choice of work
We reject all forms of forced labour; the work is a right and a free
choice.
Non-discrimination
We condemn all forms of discrimination against employees and
third parties, based on gender, race, nationality, disability, sexual
orientation. We respect all political and religious beliefs, provided
that they are based on democratic principles and guided by
tolerance.
THE VALUES OF THE ELTEK GROUP
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Freedom of association
We recognize the fundamental right of association and pledge to
work constructively with labour unions. No employee may be
discriminated or favoured because of his/her labour union
membership.
Working conditions
The wages paid to our employees is at least equal to the standards
of the law or to national or local arrangements which apply.
Working hours and holidays are compliant with applicable
regulations.
The employees can always contact their superiors if they judge to
be treated unfairly or to report any abnormal situations.
A worker may not be discriminated or punished for a complaint
or a report presented, in any way.
Training
We invest resources in training our employees, aware of the
return in terms of their professionalism, competence and
personal satisfaction.
Safety and health in the workplace
We do not accept any compromise on the safety of our workers
and the environment in which they operate.
All ELTEK plants work in compliance, at least, with the laws and
regulations in force and adopt every appropriate measure to
ensure the health of the workplace.
Environment
Every day, we are committed to the protection of the
environment with factual actions that include an eco-conscious
design, the limitation of emissions and waste, and the choice of
manufacturing processes that allow limiting the consumption of
resources, especially non-renewable ones.
All ELTEK plants work in compliance, at least, with the laws and
regulations in force.
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Our reference values are translated into standards of conduct
that engage the employees individually and the Group
companies, as a whole.
These rules can be resumed as follows:
Compliance with the regulations in force
The ELTEK Group complies with the laws and regulations in force
in the countries in which it operates. Laws and regulations are to
be intended broadly, including in this context all tax,
environmental, workers' health- and safety-related provisions,
provisions on protection of intellectual property, competition,
etc.
What does this actually mean?
From the operator of the line up to the CEO, everyone who, in
various ways, represents and acts on behalf of ELTEK is required
to comply with this requirement.
When acting on behalf of the Group and, we hope, even in your
private life, you must not be engaged in any act that violates the
regulations, even if you feel that this may be an advantage for
ELTEK.
If you have any doubts about the legality of your actions, contact
your local Legal Department before acting.
RULES OF CONDUCT LE
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Conflicts of Interest
Conflicts of interest arise when the interests and personal
activities influence decisions that should be taken in the interest
of the Group.
To determine a conflict situation is sufficient that others perceive
an influence, it is not necessary that this is effectively exercised.
Any possible conflicts of interest, even potential, must be
reported to superiors or to the Board and implies that the subject
abstains from actions that could damage the company or grant
him/her an unfair advantage.
What does this actually mean?
When acting on behalf of ELTEK, always be professional and
impartial, especially in relations with suppliers and collaborators.
If you believe you are in a situation of conflict of interest, report
it to your supervisor and refrain from activity.
Even if you feel to be impartial, remember that the mere
perception of a conflict can seriously harm the company's
reputation. In this case, refrain from taking any decisions that
could be perceived as unduly favourable to you or to a party close
to you.
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Money laundry
ELTEK employees and collaborators must not engage or be
involved in any activity that may imply money laundering. The
provisions on money laundering, also internationally, must be
scrupulously complied with.
Before establishing a business relationship with third parties,
ELTEK shall review the current information to verify the legitimacy
and integrity of such business relationship.
All financial transactions, including intercompany transactions,
are conducted in order to ensure full traceability of financial flows
and compliance with all legal requirements.
What does this actually mean?
Money laundering means accepting or using money for lawful
activities, originated from criminal actions.
You must not entertain any relationship with those involved, or
suspected of involvement, in illegal activities.
Before starting a business relationship, you must verify any
information available on your counterparty and you must not
establish any relationships with customers, suppliers or thirds,
the activity and origin of property of which is not clear.
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Bribery
The ELTEK Group is committed to ensure that all relationships
with employees and third parties, be they collaborators,
customers, suppliers, public administration, are characterized by
maximum transparency and fairness.
No form of bribery, active or passive, or of collusion aimed at
obtaining or granting favours in your own interest or in the
interest of ELTEK, is admitted.
It is not permitted to offer money or any other benefits to
influence the counterparty.
It is not permitted to receive money or any other benefits from
any supplier, or potential supplier.
An exception is the utility of low value bestowed or received by
guests as a courtesy, as required by company procedures.
What does this actually mean?
Refrain from offering gifts, favours or money in exchange for a
business advantage.
Refrain from accepting gifts, favours or money in exchange for a
favourable treatment by the counterparty.
Refrain from any action that could be interpreted as a form of
improper payment.
Report to the Legal Department each suspicious episode.
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Relationships with Customers
Customer satisfaction is the cornerstone of the ELTEK Group
business.
ELTEK is committed to building courteous, professional,
transparent and cooperative relationships, with the aim of
meeting the demands of customers with diligence and with
impeccable quality levels.
What does this actually mean?
Be committed to maintain the exchange with gentle and
professional tones.
Provide accurate, truthful, complete and timely information.
Be proactive, when possible; do not wait for the Customer to ask.
If the Customer asks you to act contrary to this Code, explain to
him/her that is impossible to do so and the reasons why.
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Relationships with suppliers
Selection and management of suppliers of the Group is entrusted
to the Supply Chain Management and its plant divisions.
The selection is based on objective criteria including skills, quality,
price and integrity.
ELTEK strives to create and maintain professional and
constructive relationships with suppliers.
The Group does not use suppliers suspected of illegal activities or
which fail to ensure fair working conditions for their employees.
In particular, it is unacceptable that ELTEK suppliers:
- Use child labour
- Use forced labour
- Carry out operations that endanger the health of employees
- Fail to ensure working conditions (wages, benefits and rest) in
line with local regulations.
What does this actually mean?
Strive to establish and maintain correct, transparent and
collaborative relationships with suppliers.
In the relationship with the supplier, follow the policies of the
Supply Chain.
Operate in accordance with local regulations and require strict
compliance to such regulations by the supplier.
Ask the supplier to adhere to the values of this Code.
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Donations and Sponsorships
ELTEK Group adheres to requests for donations and sponsorships
for social and sports activities, provided that they come from non-
profit associations, duly constituted and authorized.
What does this actually mean?
Every year ELTEK allocates some funds to sponsor social activities.
If you wish, you can submit your sponsorship proposal to the
Group's Financial Department and they will decide on the
authorization and the allocation of available funds.
In the absence of requests or preferences expressed by
employees, the same Finance Department shall define the
destination of the funds.
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Accuracy and confidentiality of information
In providing information on the Group, ELTEK agrees that such
information is accurate, truthful and consistent.
Employees are expressly obliged not to disclose information
about ELTEK or information acquired by company without
permission, and never to use or disclose it for purposes unrelated
to work.
The ELTEK Group also ensures that the information in its
possession are collected, handled and protected as provided by
law.
Any research concerning the tastes, preferences or otherwise the
privacy of employees is prohibited.
What does this actually mean?
Respect the individual right to privacy, protecting carefully, and
according to instructions, personal data that have to be treated
at work.
Do not collect, treat or store any personal information not
relevant.
Do not disclose personal information, unless previously
authorized by your superior and only if this is absolutely necessary
for the work.
If you need to provide information on ELTEK, make sure that this
information is accurate, truthful and consistent. Check also that
authorization to proceed, if necessary, has been obtained.
Do not disclose any information to the press, to competitors or
suppliers, or to external organizations, unless expressly
authorized by your superior or by the central management.
Do not disclose any confidential information, unless specifically
authorized by your superior or by the central management.
Always remember that you may not use or disclose information
acquired by the company for purposes unrelated to work.
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Protection of Intellectual and Industrial Property
The ELTEK Group acts in full compliance with intellectual property
rights held by third parties.
Employees and collaborators must refrain from deliberate
violation of these rights.
Equal attention has to be paid to the protection of the company's
know-how. Employees and collaborators must follow carefully
the instructions and refrain from disclosure or misuse of patented
corporate assets.
What does this actually mean?
Submit timely design innovations to the analysis of the
"Intellectual Property" department. In this way, you protect the
most important asset of the company, its know-how.
Contact "Intellectual Property" department whenever you are
afraid of being in the position of violating others' intellectual
property or you need any clarification.
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Personnel selection
Personnel is selected according to the principles of equality and
non-discrimination.
Candidates are evaluated according to how closely their
characteristics and skills correspond to business needs.
Candidates can't be asked for personal information or
information not relevant to the assessment needs.
The recruitment officers must avoid any favouritism or conflict of
interest. Any pre-existing personal or working relationship with
the candidates must be declared, so that the recruitment officer
is excluded from the selection process.
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Establishment and management of the employment
relationship
ELTEK employees are hired with regular employment
agreements.
No form of irregular employment is allowed.
New employees receive a detailed description of the job to be
done and related responsibilities, the detail of their remuneration
and the necessary training on aspects of safety and environment.
Later in the relationship, the company is committed to providing
equal opportunity in career advancement and to managing
promotions and prizes exclusively on the basis of merit and
matching of skills of the employee with the specifications
required by the business role.
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Harassment in the workplace
Working in a serene environment, in which interpersonal
relationships are characterized by fairness, mutual respect for
freedom and human dignity, is a fundamental right of all female
and male workers.
ELTEK is committed to remove all obstacles to the
implementation of these rights, in order to ensure a work
environment in which women and men respect the inviolability of
the person.
Harassment may include:
creating an intimidating or hostile work environment or isolating
individuals or groups of employees;
unjustified interference in the work performance of others;
any action or unwanted behaviour - physical, verbal, non-verbal -
of a sexual nature or based on sex that offends the freedom,
dignity and inviolability of the person to whom it is addressed.
The witness of harassing or discriminatory actions must assume
an attitude of solidarity with the victim, notify the ELTEK HR
Department and testify, if necessary.
The victim of harassment within an ELTEK Group plant can report
the incident to HR Department and has the right to obtain the
termination of any unwanted behaviour.
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Protection of safety and health at work
ELTEK Group promotes the dissemination of a strong safety
culture among its employees, through knowledge of the risks,
proper behaviour and applicable regulations.
All Group companies operate in full compliance with current
regulations, with particular emphasis on preventive measures.
The same diligence is required of the contractors and, in general,
to any third parties acting at the ELTEK facilities.
Improving safety and working conditions is constantly pursued
through critical analysis and upgrading of business processes.
What does this actually mean?
You are entitled to receive comprehensive training regarding
safety. Training must be appropriate to your function in the
company and the risks to which you may be exposed.
Adopt responsible behaviour, in line with the information
received; any misguided actions can represent a risk to yourselves
and to others.
For any doubt, contact the Safety Manager or workers' safety
representative (for plants in which this figure exists)
If you have a doubt about the risk of an action, stop immediately
and call the Safety Manager before.
If you see any inappropriate behaviour and potentially risk, do not
hesitate to report them to the Safety Manager.
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Our environmental policy
For years, we have been committed to protecting the
environment, by trying to combine economic interests and social
and environmental considerations.
Starting from the minimum requirement of compliance with
government regulations, all plants of the ELTEK Group are
reaching the goal of ISO 14001 environmental certification.
These are the areas in which we commit ourselves concretely:
In the design phase, with the ECO project, we try to
develop products with a minimized environmental
impact throughout their entire life cycle.
In the engineering phase, we favour processes to reduce
consumption, especially of non-renewable resources,
and pollution.
In production, we train our employees so that they are
aware of the impact of their individual behaviour on the
environment.
We give them information and tools for reducing this
impact.
We inform them promptly of the results.
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Comments, suggestions or notices about this document can be
directed to your manager, the HR department or the offices
indicated from time to time in the Code.
All ELTEK employees and collaborators have a right and duty to
report situations that appear in conflict or dubious with
references to the rules of conduct contained herein, i.e. frauds,
dangers, risks that could damage Customers, Colleagues,
Shareholders and the company reputation.
Reports can also be emailed anonymously to
ELTEK will not allow any punitive or intimidating behaviour
towards employees who have submitted a report.
HOW TO COMMUNICATE WITH THE COMPANY
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Compliance with the provisions of the Code of Ethics is an
essential part of the contractual obligations of employees,
pursuant to and for the purposes of the applicable regulations.
Violations of the Code of Ethics may constitute a breach of the
primary obligations of the employment relationship or a
disciplinary offense, with the consequences of the law.
To third parties with whom ELTEK has contractual relations, the
adoption of behaviour that violates this Code may constitute a
breach of agreement, with all legal consequences.
COMPLIANCE WITH THE PROVISIONS OF THE CODE