1. Introduction

PRO COMMERCE, d.o.o. (hereinafter referred to as the “Company”) is committed to maintaining high ethical standards in the conduct of its business activities. The reputation of PRO COMMERCE as an ethical business organization is of key importance to its continued success. Therefore, all managers and employees are expected to be well acquainted with these standards, to adhere to them personally, and to consistently demonstrate this commitment in the performance of their duties.

2. Scope of Application

This Code applies to all managers and employees of PRO COMMERCE, d.o.o., including permanent employees as well as temporary and occasional collaborators.

3. Purpose of the Code

The Management has adopted this Code of Conduct to define the fundamental principles of business behavior. The Code requires all managers and employees to act in accordance with company policies and applicable laws. The Code represents a set of principles that provide guidance and reflect the Company’s approach to business conduct – it is not an exhaustive list of behavioral rules.

4. Business Ethics

(a) Openness, Honesty, Fairness, and Integrity – Employees and managers must act with openness, honesty, fairness, and integrity in business relationships and in their interactions with others.

(b) Mutual Respect – Employees are expected to treat all persons they work with respectfully and courteously.

(c) Ethical Conduct – Managers and employees must act ethically when making business decisions.

(d) Compliance with Laws – Employees must comply with all laws and regulations governing the operations of PRO COMMERCE, as well as internal company policies.

5. Business Conduct

Employees must perform their business duties in accordance with appropriate standards of conduct.

(a) Legal Compliance – Managers and employees must comply with all legal requirements applicable to the operations of PRO COMMERCE.
If there is uncertainty regarding regulations, they must consult their supervisor and, if necessary, obtain approval from the Managing Director or the President of the Management Board to seek legal advice.

(b) Intellectual Property – Each employee is responsible for protecting the Company’s intellectual property rights. All intellectual property created by an employee or contractual partner in connection with PRO COMMERCE is the exclusive property of the Company.

6. Personal and Professional Conduct

(a) Financial Integrity – PRO COMMERCE applies strict accounting procedures under the supervision of management and external auditors. The use of company funds or assets for unethical purposes is prohibited.

(b) Giving Gifts – PRO COMMERCE does not allow the giving of money, gifts, or services for the purpose of obtaining business benefits or influencing decisions in favor of the Company. Such conduct is also prohibited under the Criminal Code of the Republic of Slovenia.
Small promotional gifts and business hospitality are permitted only for legitimate purposes – to maintain good business relationships, not to influence decisions.

(c) Accepting Gifts – Employees must not accept personal gifts or extraordinary hospitality, accommodation, or travel that could influence or appear to influence business decisions.

(d) Business Agreements and Contracts – The Company is committed to fair and ethical competition. Employees involved in negotiations must act lawfully and obtain all necessary approvals prior to signing contracts.

(e) Confidentiality and Data Protection – Employees must not derive personal benefit from the Company’s confidential information. Confidential information must be protected and used exclusively for business purposes.

(f) Public Statements – Employees may not make public statements on behalf of the Company without the explicit authorization of the Managing Director or the President of the Management Board.

(g) Smoking, Alcohol, and Drugs – Employees must contribute to a safe working environment. Smoking and drug use are prohibited on Company premises. Alcohol consumption must be moderate and responsible.

(h) Gathering Information on Competitors – Information must not be obtained through illegal or misleading methods.

(i) Conflict of Interest – Employees must avoid relationships or situations that could conflict with the interests of the Company. In case of doubt, they must consult their supervisor or the Company Secretary.

(j) Use of Company Assets – Company assets may be used only for proper and lawful purposes. They may not be sold, lent, or disposed of without authorization.

(k) Email and Internet – These systems are intended for business use and must not be used for personal gain or illegal activities.

7. Respect for Others

(a) The Company and Employees – The Company supports equal employment opportunities and does not tolerate discrimination or harassment. Compliance with occupational health and safety legislation is expected.

(b) The Company and Suppliers – The Company treats its suppliers fairly, respectfully, and transparently.

(c) The Company and the Community – The Company respects the rights of the community and the environment and operates in a responsible manner.

8. Reporting Irregularities

Compliance with this Code is overseen by the Management, which investigates alleged violations and takes appropriate action.
Employees must report suspected unethical or fraudulent conduct to the Managing Director or the Company Secretary.

Whistleblower information is treated as strictly confidential, and identity is disclosed only with the individual’s consent. Reporting in good faith will not result in any retaliatory measures.

False or malicious reports are treated as violations.

CODE OF CONDUCT FOR SUPPLIERS – PRO COMMERCE

Commitment to Ethical Standards

PRO COMMERCE is committed to the highest ethical standards in all procurement activities. This Code defines the Company’s expectations toward suppliers, including transparency, accountability, zero tolerance for corruption, prohibition of child or forced labor, avoidance of conflicts of interest, fair representation of capabilities, and reduction of environmental impact.

Policy on Corruption and Conflicts of Interest

Suppliers:

  • must not offer money, gifts, or services to obtain benefits,
  • must not provide any benefits to PRO COMMERCE employees,
  • must immediately report if a PRO COMMERCE employee attempts to obtain an improper benefit,
  • must disclose whether they have relatives employed by PRO COMMERCE.

Failure to disclose is considered a conflict of interest.

Workplace Code of Conduct

Suppliers must respect:

  • lawful employment and workers’ social rights,
  • non-discrimination,
  • prohibition of harassment,
  • prohibition of forced labor,
  • prohibition of child labor (under 15 years of age),
  • the right to freedom of association,
  • safe working conditions and environmental protection,
  • working hour limitations,
  • fair wages.

Environmental Impact

Operations and the supply chain must be organized in a manner that protects and preserves the environment.

Supplier Declarations

Suppliers declare that they:

  • comply with laws and regulations,
  • do not engage in bid rigging,
  • are authorized to supply goods,
  • will deliver quality products,
  • have adequate capacities,
  • will not subcontract work without written consent,
  • will maintain the highest standards of integrity.

Application of the Code

This Code applies to all suppliers, subcontractors, and related entities.

Compliance Monitoring

Suppliers must:

  • maintain accurate documentation,
  • allow access to records,
  • permit interviews with employees,
  • allow announced and unannounced visits,
  • respond promptly to PRO COMMERCE requests.

Secure Communication

Suppliers may confidentially report violations to:
gpsu@procommerce.si
PRO COMMERCE does not tolerate retaliation.

Sanctions

Violations may result in:

  • formal warnings,
  • termination of the contract without compensation,
  • other legal actions.