Code of Conduct

UAB SANITEX, specialising in wholesale, retail and distribution of various goods, is deeply committed to providing the clients with high-quality goods in compliance with the proper workplace and work conditions that meet the client requirements and international standards. The company aims to develop a transparent, professional, fair and ethical business practice and complies with all applicable laws and legislation in all jurisdictions of the company’s business. We hope that our employees, engaged in their daily tasks, our partners and suppliers are socially-responsible, respect the human rights, environmental goals and comply with labour laws and other applicable standards, and thus we have adopted this UAB SANITEX Code of Conduct (hereinafter – the Code).

The purpose of this code is to establish the major behavioural standards, followed by UAB SANITEX, its entities, partners and employees, compliance to which ensures the implementation of the highest standards of business ethics in the supply chain.

This Code is based on the international law, i. e. United Nations’ (hereinafter – UN) Universal Declaration of Human Rights, conventions of the International Labour Organisation (hereinafter – the ILO), Guidelines for Multinational Enterprises of the Organization for Economic Co-operation and Development, the UN Guiding Principles on Business and Human Rights, the Principles of the UN Global Compact, the Children’s Rights and Business Principles, corruption prevention and other legislation. This Code is universally applicable to the business of UAB SANITEX and the legal entities under its control, all of their employees, representatives, intermediaries, and all companies that supply goods and/or services to UAB SANITEX, regardless of the size, geographic location or industrial sector of the supplier company (hereinafter – the Supplier).

UAB SANITEX constantly monitors the application of the provisions of the Code, regularly conducting trainings and discussions on the topics of the application of the Code with the employees in order not only to ensure its full application in practice, but also to achieve higher sustainability and transparency standards.

UAB SANITEX adheres to the highest business integrity standards and will not tolerate any practices that do not comply with the principles of integrity, fairness and transparency, thus expecting that all Suppliers have already applied the standards, indicated below.

UAB SANITEX remains the right to conduct regular inspections of any of the Suppliers or their subcontractors to make sure that they adhere to the requirements, established in this Code, and, should they refuse to allow such an audit or in case of any violations and refusal to eliminate them, terminate any cooperative relationship.

Child labour

Children under the age limit, established by the national legislation, will not be employed and their employment will not be encouraged. Employers that legally employ workers above the statutory minimum working age, but under the age of 18 must guarantee proper conditions to ensure their health, safety and well-being. These employees, employed under applicable legislation, must be protected from participation or work, which, by its nature or circumstances, could be detrimental to their safety, health and morale. Employees under 18 years old cannot be appointed for night shifts also hard and/or dangerous work.

Forced labour

Prisoner or forced labour, as it is defined in the ILO Convention No. 29, will not be used or encouraged. Measures to secure labour, such as paying security deposit, retention of employees’ original documents, or refusal to pay salary or other payments, will not be used. All employees are employed at their own will and can finish their work at the agreed daily working hours with no application of penalties or salary reduction, and can resign from their position upon notice, as established in the law, and work overtime only upon free agreement between the employee and the employer.

Staff safety and health

The company must ensure a safe and healthy environment for all employees, taking all necessary measures to prevent potential accidents at work and compliance to all legislation, related to staff safety and health requirements. The company and all workplaces must undergo risk assessment to reduce them and improve the quality of the working conditions. The company must establish and implement procedures on documenting, analysing and preventing accidents based on the applicable legislation. Before starting to work, all employees undergo trainings and are introduced to work safety, fire safety requirements, instructions of using machinery and equipment, and all instructions must be documented. Machinery and equipment, used at work, must be safe to use, comply with all quality and safety requirements, be certified and, if required by the law, regularly inspected for compliance to these requirements. Employees are provided with appropriate work equipment and personal safety measures. They must be provided with good working conditions that are as comfortable as possible (proper temperature, lighting, noise control, etc.), have free access to first aid kits and fire extinguishing equipment in clearly marked places, and, in case of emergency, they must know how to provide first aid or take other safety measures. The company must implement a procedure, enabling to prevent work under the influence of alcohol or other psychotropic substances that interfere with safe and efficient work.

Employees’ involvement in the organisation

The company undertakes to ensure freedom to all employees to establish, organise and join trade unions or other organisations of their own choice, also enter into collective agreements with the employer. These rights of the employees will be respected, not subject to any restrictions, while the establishment, operation or administration of such employee organizations will not be hindered. The company must ensure that employees participating at trade unions or other organisations are not subject to discrimination, harassment, threats or other negative outcomes, or that they are not subject to any privileges or other special treatment. The Supplier must ensure that all employees can report their grievances at work with no negative consequences,


Discrimination in terms of employment, salary, training, promotion, termination of employment or retirement and in other areas in terms of race, national, ethnic or social origin, marital status, religion, disability, illness, gender, sexual orientation, membership at unions, political views, age or any other conditions that could give rise to discrimination, will not be practised or encouraged.

Respectful treatment

All employees will be treated respectfully and with dignity. Corporal punishment, psychological or physical violence, insults or bullying, any forms of physical, sexual, verbal or psychological harassment, humiliation or mobbing will not be used or tolerated. Any threatening, insulting, exploitative behaviour, sexual violence, including gestures, verbal of physical contact at work and/or other premises of the company or beyond is forbidden. Employees that violate the company’s work procedure will be immediately subject to measures, established only in lawful provisions of disciplinary practice. No fines or deductions from salary are allowed, except to the extent allowed by the national legislation.

Working hours

The company will adhere to the legislation regarding working hours, holidays, also entitlement to and payment for non-working days and vacation. A standard working week cannot exceed the requirements, established in the national legislation. Overtime must be voluntary and coordinated by mutual agreement between the employer and the employee. Employees’ work and resting time regime must comply with the requirements, established in the national legislation, and it cannot compromise the work-life balance of the employee.

Work payment

The company respects the employees’ right to a fair remuneration for their work and guarantees that the remuneration for a standard working week will not be lower than the minimum wages, established by the law, and will be sufficient to meet the employees’ basic needs, considering the average standard of living in the country. Overtime must be paid at the increased rate, established by the national legislation. There can be no consistent pattern of short-term employment agreements, or fictitious training programmes, used for the purpose of attempting to evade obligations to the employee, related to the labour law and social security regulations.

Business ethics

The economic commercial activity is conducted according to the highest standards of ethical behaviour and all applicable legislation, including, but not limited to: all necessary permissions and licenses, adherence to all applicable corruption prevention, fair competition legislation, fair financial accounting, and all applicable taxes are calculated, declared and paid to the state. All documents, records and reports must be correct, clear and reliable. Reasonably and lawfully requested information about the business must be provided objectively, honestly, without concealing or falsification of facts. The company’s employees are introduced to the rules of business ethics and apply them at their daily activities.

Environmental protection

The company complies to the international and national environmental laws, rules and standards, applicable to its business, and takes responsibility for its impact on the environment. The company complies with any requirements, related to air pollution, ground pollution and waste water management. Any type of pollution must be immediately eliminated and reported to appropriate institutions. Waste water must be managed according to applicable legislation, and the waste water management facilities must be properly operated, maintained and renewed. The company must conduct constant monitoring of the environmental impact on the current business and operations, periodical reviews of the environmental impact mitigation plans, and take action to fulfil the goals of mitigating the environmental impact. The company has a properly implemented waste management, disposal and recycling policy, adheres to applicable legislation and pays established waste-related fees. The company ensures proper waste sorting, recycling and disposal, based on their type, including hazardous waste.

Fair competition

The company is well-aware of its dominating position in the market, if any, and also aware of the impact any of its decisions may have on the clients, competitors or service providers. Any company agreements, association decisions or coordinated action with the aim to prevent, limit or distort competition will not be tolerated. Any agreements of this kind are forbidden even if their resulting in such outcome is accidental. The company does not engage in any practice or activity, which violates any legislation on competition or monopoly prevention, or could give rise to such violations. The company takes no action or enter into any agreements, which would hinder or harm customers, competitors or service providers, or which could be regarded as contradictory to legislation on competition.

Corruption prevention

The company adheres to corruption prevention legislation and rules, and will not tolerate any non-transparent relations between the company or its partners and other business or governmental institutions. Any offer, encouragement, promise, agreement or acceptance of any bribe or other types of illegal payments, including concessions, any types of gifts or other financial and/or non-financial benefits, also direct or indirect promise, agreement, payment or offer of any other types of valuable reward or other benefit, are prohibited. The company and its employees cannot offer or accept gifts, money, travels or hospitality, which is used as encouragement to make a certain decision or a reward. The company does not support any political parties or candidates to governmental institutions, does not engage in any political activities during work and does not use the company’s funds, premises or other resources for this purpose. The company’s leadership will fully disclose any information on any support to political parties or governmental institutions, or any other possible cases of a conflict of interest. The company adheres to the duty of reporting any information, which may be related to criminal activity, or other possible cases of corruption to law enforcement authorities. The company constantly monitors compliance with anti-corruption provisions and organises appropriate staff trainings.

Money laundering prevention

All financial operations will be transparent and ethical, with adherence to the standard processes, and the company will not take part at any transactions, which involve unrelated parties and (or) unusual payment methods, and (or) unusual terms and conditions. Before entering into any transaction, the company will carefully check the third parties and apply highest transparency requirements to any related parties of the transaction. Any suspicious transactions and financial activity is always reported to the company’s leadership and responsible law enforcement institutions.

Reporting and communication

Adherence to the Code is strictly monitored. The company encourages immediate reporting of existing and / or suspected violations of applicable laws, regulations, internal procedures and the Code. Employees can report suspected or existing violations to their direct managers or use the company’s whistleblower channels. In any case, the company guarantees anonymity of the whistleblowers and persecution, dismissal or any other forms of punishment for employees or Suppliers that have reported suspected violations in good faith, is forbidden.

With no limitations to this Code, UAB SANITEX continues to improve its practice, which complies with highest standards of business ethics, and strives to ensure compliance with the provisions of the Code in cooperation with its suppliers and subcontractors. UAB SANITEX expects the same from the Suppliers, hoping for open communication and cooperation any compliance issues and the application of the Code.