The Company values
Elcore is an international distributor of equipment for creating information systems, consumer electronics, software, cloud services and cybersecurity solutions.
We have been operating since 2006 and help clients make their business more predictable and profitable. With offices in 11 countries in Eastern Europe and Asia, we are dedicated to provide comprehensive technological solutions to meet the evolving needs of our clients.
Our mission is to unite the best equipment for creating information systems, consumer electronics, software, cloud services and cybersecurity solutions with the needs of people; to make new technologies available in emerging markets, providing predictable logistics and transparent system of responsibility.
Brand values:
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Respect: we openly share knowledge, discuss and find solutions to any issues.
Development: we are not afraid of changes, strive to explore the new and provide our employees with opportunities for professional learning and growth.
Honesty: we always uphold transparency in our relationships with partners and employees. We are open and honest.
Reliability: we build long-term relationships with partners and employees.
Innovation: we form our portfolio of offers based on technological novelty of products and solutions.
Ethic Business and Sanction Compliance Policy of Companies of Elcore Group
Updated in January 2024
Approved by Elcore Group
PRINCIPLES OF BUSINESS CONDUCT
Relationships between employees of the Company, regardless of their position, and our partners and customers are based on the principles of:
• Honesty;
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Fair competition;
• Decency;
• Respect;
• Good faith;
• Sense of responsibility;
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Legality;
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Economic feasibility.
FAIR COMPETITION
Antitrust and competition laws are enforced to promote fair competition and protect partners and customers from unfair business practices.
Fair competition is one of the fundamentals of an open market economy. Compliance with the competition law shall be a prerequisite and one of the Company’s basic principles.
Unfair competition covers any actions in a competition that are contrary to trade and other fair business practices. Unfair competition refers to acts by the operator which violate the provisions of the anti-fair competition law, undermine the lawful rights and interests of other operators and disrupt the social and economic order.
It is in our best interest to develop in a market that respects the highest standards of doing business. Elcore is committed to treating all its current and potential partners fairly and creating equal conditions.
We always take into account the legal requirements of the countries of our counterparties with which we do business. Any manifestations of unfair competition or abuse of dominant position are prohibited in the activities of the Company, as the Company strictly complies with the antitrust laws of the applicable jurisdictions. The employees of the Company shall have no right to unreasonably criticise the products and services of competitors.
Anti-fraud policy
The Company pledges the commitment to preventing and detecting all forms of fraud.
Fraud is a type of intentional theft or misrepresentation that may result in illegal gain, profit, advantage, damage or loss to the Company or another party.
Any actions that deliberately conceal or misrepresent the facts to mislead others, including customers, suppliers, third parties or colleagues, are considered fraud.
The Company shall strictly oppose all forms of money laundering and will take measures to prevent the financing of money laundering operations.
To prevent fraud within the Company, it may initiate internal audits to identify financial risks or evidence of fraudulent activities of the Company’s employees, or initiate an independent audit of the Company’s financial condition, prosecution under applicable law or submit the case for consideration to the competent government authorities.
All payments shall be made in accordance with the applicable legislation. The employees shall be obliged to comply with the applicable anti-money laundering and counter-terrorist financing legislation.
Trade compliance
We are aimed to ensure that all import and export transactions to be subject to conformance with the laws and regulations of the countries involved and where the Company operates.
In the context of trade compliance we take into account the assessment of risks posed by clients, customers, products, services, supply chain, intermediaries, counterparties, transactions, and geographic locations.
Our Trade compliance comprises two general operating practices:
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Customer due diligence and supplier vetting using sanctions lists or restricted or denied parties lists to ensure that the trade transaction is not destined for a sanctioned individual, company or country.
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Managing commodity-based import and export controls in a compliant manner across our group supply chain, in order to know and assess where the goods to be delivered, high-risk jurisdictions and end-users customers, terms of financial transactions, requirements of applicable legislation, taxation and customs regulations, export restrictions and sanctions regulations, contractual risks of title transfer and risks of loss and damages.
We rely on vendor’s knowledge and expert opinion as a producer of respective goods, therefore, we clarify and negotiate about all requirements with respect to export/import control (dual-use goods, specific licenses and approvals) of the goods in advance. We consider the producer as a source who knows the best option how to meet and adhere to the legal and trade requirements and take into account its opinion.
We engage respective specialists (legal, logistic, accounting, brokers) at each stage of supply chain to satisfy the trade compliance at each jurisdiction we carry on business.
We stick to clear communication of our policies and procedures to all relevant staff including business units operating in different areas as well as external parties, if any, performing on behalf of the our Company.
Zero tolerance of bribery, corruption or abuse of authority
The Company does not tolerate any form of bribery, corruption or abuse of position.
We adhere to international principles on human rights, labour, environment and anti-corruption. We adhere to the principle that all enterprises must act against all forms of corruption, including extortion and bribery.
Corruption involves the use by a person of authority granted to him/her or associated opportunities to obtain unlawful benefit or receipt of such benefit or receipt of a promise/offer of such benefit for himself/herself or others, or respectively the promise/offer or granting of an unlawful benefit to the person or upon his/her request to other individuals or legal entities with a view to persuade the person to unlawfully use his/her authority granted to him/her or associated opportunities.
The Company recognises and adheres to the provisions of international anti-corruption laws, including the UN Convention against Corruption, the USA (US FCPA) and UK (UK Bribery Act) legislation, Framework for OFAC Compliance Commitments, OECD Anti-Bribery Convention, Criminal Code of Switzerland.
Relationships with customers, suppliers, and state bodies
Mutual trust and honesty are important to us in our business relationships with partners and suppliers. When choosing our partners and suppliers, we make sure that they work in accordance with our values and principles.
We must offer our customers understanding, respect and knowledge. We must always try to meet the customer’s needs in the best possible way subject to the business ethical principles. Similarly, we must treat suppliers impartially and fairly.
The Company shall interact with business partners (customers, suppliers, contractors, consultants) on the basis of long-term cooperation, mutual benefit, respect, trust, honesty and fairness.
We cooperate with reliable business partners engaged in legitimate activities. We fulfil our contractual obligations to business partners in good faith and demand the same from them. We resolve conflicts legally, seeking to find mutually acceptable compromises.
Confidentiality and data protection
Information security and IT security is one of our key priority and competencies.
Well-known companies and corporations rely on our certified consulting services. Therefore, it is extremely important that we ourselves internally guarantee the highest level of security when processing Company data, as well as customer and employee data. This includes, but is not limited to, protection against unauthorized access, unauthorized or improper use, loss and premature destruction.
In addition to technical and organizational measures we use to protect data and information, each employee is personally responsible for handling all personal data of customers, employees and suppliers with care and confidence.
With a high sense of responsibility, we ensure that all internal rules to ensure an equally high level of data protection are consistently followed and regularly reviewed. It is important to us that everyone can learn about the category and amount of data we choose. We collect and process confidential data only with the consent of the data subject, if this is permitted by law or necessary to fulfill contractual obligations.
In addition, we collect, process and use personal data only to the extent necessary, for the necessary period of time and only for the intended purposes. We respect the comprehensive rights of individuals whose data we collect, process and use.
All employees of the Company undertake to protect their company's data and operational interests. Information from and about our company must be treated confidentially and will not be disclosed unnecessarily. We do not leave business documents, files or software open for viewing or open on computers for others when we are not at work or working in public places.
Compliance with the policy
Violation of the Policy can have serious consequences. Therefore, violations must be detected, analyzed and properly punished. Each employee must actively seek to comply with the requirements of the Policy and applicable law and inform his or her senior if he or she suspects a violation of laws, instructions or rules of conduct. Seniors ensure that request is taken seriously and applicants are listened to openly in an atmosphere of trust.
We strongly desire that any misconduct be evaluated and analyzed thoughtfully, and that groundless reports are not made. We must remember that false or unsubstantiated reports of misconduct harm the reputation of colleagues. Such behavior itself violates the ethical principals.
In addition, Elcore punishes deliberate, illegal actions and violations within the framework of legal norms consistently and regardless of the rank and position of the person who committed them in the Company. This applies in particular to corrupt behavior or if the company's assets have been damaged by criminal activity.
Whistleblowers who provide information to the best of their knowledge and belief will not suffer any adverse consequences unless they themselves have violated the applicable laws. The correct contacts are the manager, as well as the responsible employee for compliance and legal support of the Company. The Company's Legal and Compliance Officer provides assistance in case of questions and uncertainties regarding the interpretation of the provisions of the Policy and current legislation and in situations that are difficult to assess.
If you want to avoid personal communication, you can send a letter to the mailbox of the responsible employee for compliance and legal elcore@compliance.com , which will ensure the confidentiality of the request, you can also ask questions and get answers here.