Ethical Code

Code of Ethics and Conduct

Introduction

Through this document, the CODE OF ETHICS AND CONDUCT – the Code – S.C. STARC4SYS S.R.L. establishes this moral behaviour guide which sets forth the values, principles and standards of action expected from employees and from the company in general, with the purpose of guiding the moral and professional behaviour of employees, both during professional activity and outside of it, to the extent that it affects the company's image. This Code applies to all those who collaborate with STARC4SYS SRL, employees, subcontractors, partners, etc.

The CODE aims at respecting the dignity and integrity of all company personnel, ensuring equitable relations within the company, contributing to the increase of service quality, protecting the company's reputation and complying with applicable legal regulations.

Code of Ethics

S.C. STARC4SYS S.R.L. undertakes to permanently and strictly observe the laws, rules and standards applicable in conducting its own activities, wherever they are carried out. Employees of S.C. STARC4SYS S.R.L. must avoid those activities that lead to the involvement of the organization or its personnel in any kind of illegal actions.

Employees of S.C. STARC4SYS S.R.L. must observe the highest ethical standards: in business, in exercising the responsibilities entrusted to them; in relations with: the public, colleagues, business partners, public authorities, mass-media, etc.

All employees must act with integrity, competence, seriousness, respect, consideration in relation to public officials, external partners (clients, suppliers or potential collaborators), colleagues within the company. All employees must show special concern for the company's interests and assume commitment to these values. Employees must consider the integrity of the profession and the interests of clients above their personal interests.

Code of Conduct

Compliance with Legislation and Internal Regulations

Compliance with the law is the most important principle underlying the company's policies. All employees must respect and comply with the legislation and regulations in force. In addition to complying with specific laws and regulations, all employees have the obligation to perform their duties with integrity and to observe the highest standards of professional conduct in relations with suppliers, clients, governmental and non-governmental institutions and/or with the partners of S.C. STARC4SYS S.R.L.

Professional Conduct of Employees

The principles governing the professional conduct of S.C. STARC4SYS S.R.L. employees are the following:

Respect for the supremacy of the Constitution and the law – employees of S.C. STARC4SYS S.R.L. have the duty to respect the Constitution and the laws of the country;
Priority of service interest – employees of S.C. STARC4SYS S.R.L. have the duty to consider the service interest above personal interest in exercising the attributions of the function/position held in the organization;
Professionalism – employees of S.C. STARC4SYS S.R.L. have the obligation to perform their duties with responsibility, competence, impartiality, efficiency, correctness and conscientiousness, applying the knowledge, skills and experience acquired;
Impartiality and independence – employees of S.C. STARC4SYS S.R.L. are obliged to have an objective, neutral attitude towards any political, economic, religious or other interest, in exercising their function;
Moral integrity – employees of S.C. STARC4SYS S.R.L. are forbidden to request or accept, directly or indirectly, for themselves or for others, any advantage or benefit in consideration of the position they hold or to abuse in any way this position;
Freedom of thought and expression – employees of S.C. STARC4SYS S.R.L. may express and substantiate their opinions, with respect for the rule of law and good morals;
Honesty and fairness – in exercising their function and performing their duties, each employee of S.C. STARC4SYS S.R.L. must act in good faith, with integrity, correctness and incorruptibility;
Openness and transparency – the activities carried out by all employees of S.C. STARC4SYS S.R.L. in exercising their function are free, open and transparent and may be subject to monitoring by authorized persons.

Loyalty towards the Company

Employees of S.C. STARC4SYS S.R.L. have the obligation to loyally defend the prestige of the company in which they carry out their activity, as well as to refrain from any act or deed that may cause prejudice to its image or legal interests. Disclosure of confidential information or release of documents containing such information, at the request of representatives of a public authority or institution, is permitted only with the written consent of the company's management. The provisions of this code of conduct cannot be interpreted as a derogation from the legal obligation to provide information requested by authorized state institutions, under the conditions of the law.

Professional Attitude

Employees of S.C. STARC4SYS S.R.L. must:

Have an open and proactive attitude, focused on finding the best and most efficient solutions for each situation;
Consider the company's interest above any other interest, in exercising functional attributions;
Promote relationships based on respect, good faith, fairness, courtesy and mutual trust;
Totally disapprove any type of discrimination based on race, ethnic belonging, religion, nationality, colour, sex, age, citizenship, marital status, disability, etc.;
Assume responsibility for their own actions and make firm decisions in order to achieve objectives and find efficient and creative solutions in any situation;
Avoid conflicts and approach tense situations diplomatically, in order to dismantle them;
Protect, promote and defend the image and reputation of the organization;
Maintain confidentiality regarding any type of information referring to the company and the business environment in which it operates, trade secrets and intellectual properties of the company;
Never promise what cannot be achieved;
Not allow the interference of business environment interests with friendship relations;
Be a vector of positive image (role model) for those around them.

Use of the Internet and Email Account

Electronic media cannot be used for knowingly copying, transmitting, retrieving or storing information that may be:

Discriminatory and harassing;
Unfavourable to an individual or group;
Violating any license governing the use of software;
Used for any purpose that is illegal or contrary to the Company's policy or in a manner contrary to the Company's best interests, in a manner that discloses confidential or proprietary information of the Company or third parties or for personal pecuniary gain;
Copyright protected, only if the employee has the author's permission or by accessing a single copy only for the employee's reference.

Computers, electronic media and services provided by the Company are primarily for business use, to assist the employee in carrying out their activities. The Company assumes no liability for loss, damage, destruction, alteration, disclosure or misuse of personal data or messages transmitted through or stored in the Company's technological resources.

Internal Communication (with Colleagues/Internal Clients)

To the extent appropriate for the Company, it will provide all employees with the information necessary to perform their tasks and responsibilities efficiently. Appointments to positions as well as messages from the Company's management bodies are communicated to personnel also by email. To bring issues to attention, any initiated email will also copy (CC) the direct superior of the sender, even if the resolution of the matters brought to attention in the email content is not within their competence, but concerns another department/another person.

Attitude towards Conflict

Employees and the Employer have the obligation to resolve labour conflicts through mutual understanding or through procedures established by legal provisions in force. The procedure for resolving labour conflicts is according to the provisions of Law No. 62 of 10 May 2011 on social dialogue, with subsequent amendments and completions.

External Communication (Clients, Suppliers, Partners)

External communication shall include at least the following:

Meetings with external partners are announced in advance with: date, time, location, subject and purpose (what results are expected following the meeting);
All meetings with external partners are announced to the direct hierarchical superior, who makes the decision on participation;
Attire at all external meetings (with partners) is "business", mandatory. The attitude at these meetings is always professional, assertive and firm;
The attitude of the S.C. STARC4SYS S.R.L. employee will reflect the organization's values in verbal and non-verbal language, attire and feedback;
All documents used in meetings by the S.C. STARC4SYS S.R.L. employee will have the organization's letterhead or be part of the image elements set;
At the first meeting, the S.C. STARC4SYS S.R.L. employee is obliged to offer a business card and request a business card from the interlocutor. If not possible, they will ensure they have transmitted and received the interlocutor's contact data (name, position, company, phone, email);
After the meeting, the employee will make a short meeting report which will be sent by email to the direct manager, alongside which the important aspects discussed and, if applicable, the next stages of the collaboration will be specified with: deadlines/objectives/proposals;
The meeting will always be prepared by S.C. STARC4SYS S.R.L. with clear objectives that must be achieved. Their status and the actions to follow will be reported after each meeting. If objectives are not achieved, the causes are substantiated realistically;
The attitude towards any collaborator must be positive and firm in any situation; the main objective of each employee of S.C. STARC4SYS S.R.L. is to promote the positive image of the organization, its products and services and colleagues.

Communication with the Press

Communication with the press shall be done only by the General Manager/Executive Director/Marketing Manager/other designated specialists within the company, after receiving management approval. All messages or requests coming from mass-media will be directed to the Marketing Manager. Communication with mass-media will be based on principles such as: honesty, fairness, business ethics, keeping evidence in this respect. Data permitted to be communicated in mass-media, regarding business evolution, business strategy, services, products, etc., shall be established by the organization's mass-media communication policy. This policy will be communicated by the General Manager/Executive Director/Marketing Manager.

Compliance with Competition and Trade Laws

Competition is necessary for achieving economic efficiency and thus constitutes a key element of free initiative. Most countries have implemented competition laws that prohibit unfair practices, such as: secret agreements, unfair market domination, dumping. S.C. STARC4SYS S.R.L. respects internal and international regulations concerning competition and trade, bases its principles and strategies on these regulations, permanently carries out analyses regarding the relationship between existing institutional regulations and the activities carried out. All employees involved in activities related to competition and trade have the obligation to know the related legal provisions and to strictly comply with them. The company is legally obliged not to make any understanding or agreement with any of the competing firms. This standard requires completely avoiding any conduct that violates or could merely appear to violate antitrust laws, which prohibit any kind of understanding or agreement between competing firms regarding prices, terms of sale, market sharing, customer allocation or any other activity that limits competition, either by sellers or buyers.

Compliance with Anti-Corruption Laws

Promising or offering money or other undue benefits, directly or through intermediaries, to a public and/or private official, with the purpose of obtaining favourable treatment or influencing the outcome of a negotiation, is prohibited. Such acts are illegal in most countries, constituting violations of the legislation in force regarding the fight against corruption. Any employee of S.C. STARC4SYS S.R.L. who violates these provisions will bear the corresponding legal sanctions, civil and criminal, provided by Law No. 78 of 08 May 2000 for the prevention, discovery and sanctioning of corruption acts, respectively the provisions of Art. 289 and Art. 290 of the Criminal Code.

Prevention of Conflict of Interest

Relations with a competitor, client or supplier – Conflicts of interest arise when the private interests of a person conflict with the interests of the company in a certain professional engagement. Conflicts of interest arise when an employee or one of their family members has a business relationship with a competitor, client or supplier of the company, in the context of negotiations or in the case of signing an agreement or executing works for S.C. STARC4SYS S.R.L.

Receiving money, in the form of advance, loans, guarantees or services for the purpose of influencing a decision to be made by the company constitutes a conflict of interest, as well as the situation when an employee works simultaneously for a competitor, client or supplier or holds significant shares in such companies. Each employee must prevent situations of conflict of interest by avoiding engaging in financial interests with a competitor, client or supplier of the company outside their professional activities. Employees have the obligation to carry out activities in compliance with regulations that prohibit present or subsequent conflicts of interest. Employees have the obligation to avoid any actual/potential/apparent conflict between their personal interests and those of the Company.

Transactions with natural or legal persons outside S.C. STARC4SYS S.R.L. must be carried out within the framework established and controlled by the Company, with the approval of its management. Commercial transactions with external natural/legal persons must not lead to unusual gains obtained directly or indirectly for employees. Unusual gains refer to bribes, product bonuses, additional special gains, unusual price reductions and other unexpected gifts with the purpose of bringing a direct/indirect benefit to the employee.

An actual/potential/apparent conflict of interest occurs when:

An employee is in a position to influence a decision that may result in personal gain for that employee or a relative of theirs due to the Company's commercial transactions or has obtained a gain of another nature than remuneration, from transactions/relationships involving the Company;
An employee engages in a business or any other activity during private time that has the same nature or is similar to the activity carried out by the Company;
An employee has concluded or is about to conclude an agreement/commitment on behalf of the Company with a provider/supplier that has been or is controlled/managed by a close friend or relative;
An employee uses confidential information obtained through exercising their duties at the workplace within the Company for their own advantage or for a friend or relative, or exploits for their own benefit an opportunity where the Company has an interest.

Payments, Gifts and Benefits

Employees of S.C. STARC4SYS S.R.L. are forbidden from requesting or accepting gifts, money, loans, presents or advantages of any other nature from companies or persons with whom they officially collaborate, during the execution of the contract, for the purpose of fulfilling or not fulfilling their duties. Gifts of symbolic value received as representation materials, offered during protocol meetings, may be accepted. Offering these or providing hospitality are common practices, usually, in relations between professionals. Offering hospitality to business partners is a common practice of organizations and commercial companies and it is recognized that this can be beneficial to efficient business conduct. Invitations to lunch or dinner received from representatives of organizations or commercial companies with which S.C. STARC4SYS S.R.L. collaborates or intends to collaborate may normally be accepted, as long as their purpose is to have a fair relationship, and accepting the invitation does not contravene the interest of the company S.C. STARC4SYS S.R.L.

Respect for Persons

Within S.C. STARC4SYS S.R.L. we permanently desire an atmosphere of trust, open communication and respect. Relations with colleagues, subordinates or managers must be carried out according to a partnership model, individual behaviour being subordinated to devotion to the company's ethical conduct. We are convinced that our most important resource is people. Therefore, collaboration between colleagues is important to be achieved according to the mentality of a winning team, whose efforts actively contribute to the development and success of our clients.

Human Resources Policy

In particular, our human resources policy is:

To select, employ and pay people who work within S.C. STARC4SYS S.R.L. based on their professional competences for the respective work, without discrimination based on age, citizenship, marital status, race, religion, nationality, ethnic origin, colour, sex, gender identity, sexual orientation, disability or any other characteristic protected by law;
To maintain an open working environment and achieve a level of excellence, attracting and retaining employees from diverse backgrounds;
To provide training, instruction and promotion opportunities that allow career development and hierarchical advancement for all those working within S.C. STARC4SYS S.R.L.;
To conduct performance evaluations that provide fair results;
To remunerate performance, recognize and reward individual or team contributions that exceed the usual attributions of the respective position;
To prohibit sexual harassment or any other type of harassment of S.C. STARC4SYS S.R.L. employees by any person, at the workplace or during activities related to the company;
To avoid creating favours at the workplace in accordance with the policies and procedures adopted by the company;
To respect confidentiality by collecting, processing, using and retaining personal information of employees only as long as necessary and in accordance with applicable national legislation in force. The company's GDPR policy can be consulted here – https://www.starc4sys.ro/gdpr.html;
To strive to eliminate any possible sources of danger at the workplace, to provide S.C. STARC4SYS S.R.L. employees with a safe and healthy working environment and to strive to comply with all applicable occupational safety and health laws and standards;
Not to exploit children through labour. Exploitation of children through labour is defined as employing a person who has not reached the legal age according to the law or without having the consent of their legal representatives;
To contribute to maintaining a safe, healthy and productive working environment for all employees within S.C. STARC4SYS S.R.L. and for others, by:
- Prohibiting the possession, consumption, sale or distribution of illegal drugs or special drug-related instruments, on the property of S.C. STARC4SYS S.R.L. or during working hours;
- Prohibiting carrying out activity within the company under the influence of alcohol or narcotic substances;
- Prohibiting the possession or use of weapons/firearms or ammunition on company property or during company activities according to legal provisions;
- Immediately notifying management regarding any case of alcohol or narcotic substance consumption or weapon possession at the workplace.

Health and Safety at the Workplace

Ensuring the health and safety of its employees is a priority of S.C. STARC4SYS S.R.L. All employees have the right to work in a safe and healthy environment and have the obligation to participate in such efforts, through responsible behaviour. The health and safety policy applies to all employees, subcontractors and other third-party service providers, and is actively managed and monitored, for the continuous improvement of occupational safety and health conditions. Health measures, which may be generated by various risks with incidence on the health status of the population, as a result of a possible aggravation of a particular situation, on the territory of Romania, are taken through own occupational safety and health instructions.

Prevention of Discrimination and Harassment

Employee diversity within S.C. STARC4SYS S.R.L. must be seen as an opportunity for development and learning, for creating a successful organizational culture. S.C. STARC4SYS S.R.L. undertakes to offer all its employees equal opportunities in terms of recognition and appreciation of merits at work and performance achieved, and does not tolerate any discrimination or harassment of any kind. In exercising the specific attributions of management positions, managers of S.C. STARC4SYS S.R.L. have the obligation to ensure equal opportunities and treatment regarding career development for subordinate employees. Moreover, the company permanently invests in the development of our colleagues, through specialized courses, participation in various trainings and conferences, a principle that is part of the company's values.

Employee Dress Code

The image of S.C. STARC4SYS S.R.L. personnel is very important, as it is an integral part of the Company's long-term strategy. In relations with partners/clients/suppliers/representatives of authorities and other third parties with whom they come into contact in the line of duty, adopting a professional attire is indispensable at the level of all employees. When dressing for the job, the objective of each S.C. STARC4SYS S.R.L. employee should be to project an image that denotes competence, seriousness and professionalism. Everyone can add personality, character and good taste to the attire worn at the office without in any way compromising their own clothing style. Such attire shows respect for colleagues, superiors, acceptance of company policy, all of which represent principles that lead to success.

The professional attire of the Company's personnel is the following: uniform, business attire and smart casual attire:

The uniform (occupational protection equipment) is intended for personnel within the production section, warehouse area, as well as those who carry out practical works designated by the company's management;
Business/smart casual attire is specific to personnel who carry out their activity in offices;
- Smart casual is a slightly more elegant everyday style. A smart casual outfit is neat, comfortable, close to a business one, but less "tense", in which all the clothes you wear "combine intelligently" with each other.
Casual attire will be avoided, being intended for wearing during free time (e.g. shorts, skirt/dress with an indecent length) and opting for clothing with a suitable cut, which enhances the person;
Any clothing must be impeccably clean and ironed; appearance is indispensably linked to individual hygiene. Also, footwear must be clean;
In presenting the dress code, the premise was that each employee of the Company knows that an unrefined attire will have repercussions not only on the employee as an individual, but also on the Company, as an organization they are part of. The employee must know that they cannot present themselves at meetings or at the workplace in inappropriate attire; the employee must take care that the elements composing their attire are in complete harmony, and their colour scheme does not harm the eyesight of those around them.

Respect for the Environment

As part of its commitment to sustainable development, S.C. STARC4SYS S.R.L. has integrated environmental aspects into its organizational strategy and culture. The company's commitments in this regard are represented by compliance with applicable national legislation in force, through undertaking contracts with public and private authorities responsible for waste management, as well as carrying out environmental protection actions at the level of the company's locations/points of work, or of the final beneficiaries.

Protection of Patrimony

Fairness and Protection of Information

S.C. STARC4SYS S.R.L. undertakes to ensure the legal framework for transmitting accurate information to those to whom it is addressed, so as to enable them to perform correct and objective analyses and reports. This also involves protecting information, while also ensuring its confidentiality. Confidential information includes all strategic, financial, technical or business information, such as: formulas, industrial processes, industrial know-how, business plans, financial and strategic plans, financial forecasts, business negotiations (including bidding), marketing studies, commercial and technical information about clients, suppliers, partners, existing or potential, disclosure of which would lead to material, financial and moral (image) damage to S.C. STARC4SYS S.R.L.

No employee of S.C. STARC4SYS S.R.L. may compete directly or indirectly in the commercial relations concluded by S.C. STARC4SYS S.R.L. All requests for financial information or concerning the organization's activity, coming from mass-media, the financial community or the public, must be directed to the General Manager and/or the Executive Director. Employees of S.C. STARC4SYS S.R.L. are not allowed to disclose confidential information to any person outside the organization, without having special authorization/mandate signed by the General Manager/Executive Director.

Protection of Company Assets and Resources

According to the principles of civil law, the company's patrimony consists of all goods and obligations with economic value, belonging to the organization. All employees are responsible for the correct use of S.C. STARC4SYS S.R.L. assets and resources and for their protection. These include, among others, intellectual property, such as: trade secrets, patents, trademarks, as well as: IT equipment, work equipment and financial resources. These assets and resources must be used in accordance with their business purpose or within established processes. They cannot be used for personal business, unless otherwise use has been explicitly authorized by established procedures.

All employees must actively act to protect the company's assets, goods and resources against any damage, alteration, fraud, loss or theft. Leaving the building, during or after the completion of the work program, with resources of any type (equipment, goods, etc.), belonging to the organization is strictly forbidden. Derogations may exist only in the case of activities carried out by various specialists, in key departments (commercial and/or technical) pre-established and approved. Portable goods such as: phone, laptop, data storage units or specific documents are excluded from the aforementioned interdiction, only when necessary. The goods with which the employee may leave the company location are all those goods handed over to them by minutes by the responsible person for each area (auto, IT, telephony, tools and equipment, etc.).

Employees will use, maintain and protect all goods and properties of the organization. No employee is permitted to take/borrow/sell/alienate to a third party, any of the organization's properties, regardless of its value/condition, unless they have the prior written consent of the Company's Management, direct manager and the responsible person for each area (auto, IT, telephony, tools and equipment, etc.). Organization goods will not be used for personal use, except in cases where written acceptance from the Company's Management is obtained. When employees use organization goods in common, they have the obligation to keep them in proper working condition, protecting and respecting the values of the organization and the group of colleagues. Specially arranged spaces used in common (kitchens, bathrooms, terraces, passage and access hallways, offices, exhibition spaces) will be kept in order and cleanliness, also requiring individual responsibility of each employee for this purpose. Keeping in good working condition of equipment, utilities, objects used solely by an employee becomes their responsibility.

Documents and software located and used within the organization are the property of the organization, and employees do not have the right to multiply, distribute, alter or use them for personal purposes. Each employee is responsible for protecting the organization's goods when using the computer network, related technology, when accessing or transmitting electronic information through the organization's resources. Company employees are not allowed to use for their own interest the goods and information belonging to the organization, without the approval of the hierarchical superior. No employee is entitled to use the goods belonging to the organization, the information or the position they hold to obtain an undeserved personal gain. Also, no employee may compete directly or indirectly with the organization. The duty of employees towards the company is to promote its legitimate interests, within the framework of their work activities and attributions.

Patents and Intellectual Property - "I.P."

"I.P." is intellectual property over valuable information (technical or business), protected by patents, trademarks, copyrights or trade, industrial, functional secret law, as defined and regulated in the incident national legislation on copyright and related rights, invention patents, utility models, trademarks, designs and models (from design), unfair competition, trade secret and know-how. The interests of the organization require it to maintain its intellectual property, not to jeopardize its value and thus to be in a position to bring maximum profit from its use or purchase. In the same way the organization treats patents, professional secrets, trademarks and copyrights as assets of the organization, the legitimate intellectual property rights of other organizations and persons must be respected. S.C. STARC4SYS S.R.L. will not knowingly infringe the property right over patents, trademarks/industrial or copyrights of other companies or natural persons.

Fairness in Financial Reporting

The integrity of financial reporting is essential to ensure the proper management of the authorized activities of S.C. STARC4SYS S.R.L. Accounting records, journals and accounts, as well as the company's financial statements must adequately reflect the transactions carried out and must comply with applicable legal requirements, generally accepted accounting principles and the internal control system. Employees operating accounting records must act with accuracy and honesty, and ensure that each record is properly documented. All employees must follow the rules and guidelines that apply to recording and documenting invoices, expenses and other items taken into consideration in journals. The rules and procedures applicable in accounting records are established in the company's financial policies, in accordance with applicable law. Reports drawn up and transmitted to authorized state institutions must present complete, correct, accurate information, within the term provided by law. All accounting documents, records, accounts and financial statements of the organization must be detailed, reflect (in time) the organization's transactions and comply with the laws and norms in force, the organization's control system and the accounting principles regarding the International Financial Reporting Standards IFRS. Employees of S.C. STARC4SYS S.R.L. who work with the bank-financial accounts of the organization or will have access to accounting documents and/or financial resources, will strictly follow the working procedures approved by management and legislation.

Importance of Internal Control

Internal Control

Internal control has an essential role within S.C. STARC4SYS S.R.L. It is designed to guarantee management the correctness of financial and business information, protection of assets, compliance with regulations, internal norms and procedures, as well as the efficiency and relevance of managing the control of the company's operations.

Responsibility

Responsibility for establishing, implementing and continuously managing internal control processes rests with the company's management. These processes relate to maintaining an adequate control environment, assessing general and financial risks, carrying out controls, exchanging information within and outside the Group, as well as general monitoring of the process.

Implementation of Procedures and Disciplinary Liability

Implementation of Procedures

The application of the Code of Business Conduct is based on organization and on procedures that combine consistency with flexibility. The Company is responsible for applying this Code, taking into account also the local conditions in which the activity is carried out, which could be imposed by the laws and regulations in force. S.C. STARC4SYS S.R.L. emphasizes establishing business relationships with clients, suppliers and partners who carry out their activity based on the same principles.

Disciplinary Liability

Each employee of S.C. STARC4SYS S.R.L. is obliged to unconditionally cooperate in internal investigations, organized and conducted according to legal provisions in force. Any effort by an employee to obstruct the investigation, through false or misleading information or through refusal to provide information they hold, entails disciplinary measures, including termination of the employment contract.

Obligation to Report

Employees report any behaviour or action that contravenes the provisions of the Code of Conduct (preferably before the incident occurs). Failure to report or facilitation of an inappropriate action may be considered proving factors for non-compliance with the required ethics;
The employee is recommended to discuss any possible violation of the Code of Conduct with the direct superior or department manager. Additionally, the employee may also communicate with the direct superior/department manager. Any report submitted by an employee is considered confidential, treated and debated as such and without repercussions on the carried out activity;
Direct superiors and managers are responsible for analysing and treating any form of violation of the Code of Conduct. All measures will be taken so as to maintain the confidentiality of information. The Company will not remove, suspend or harass in any way an employee who has reported a violation of the Code of Conduct;
Sanctioning employees who violate this Code or other internal or legal norms in force shall be done according to the legal provisions provided by labour legislation and the Company's Internal Regulation.

Final Provisions

S.C. STARC4SYS S.R.L. has confidence in its employees and firmly believes in the capacity of each employee to act with responsibility and discernment. This Code is an integral part of the legislative system, under the incidence of the Internal Regulation and applies to all employees of S.C. STARC4SYS S.R.L., without exception. Any deviation from the rules provided in this Code will be sanctioned accordingly, according to the disciplinary provisions of the Internal Regulation. The provisions of this Code will be brought to the attention of employees, clients, suppliers and partners of S.C. STARC4SYS S.R.L.