THE CODE OF ETHICS AND BUSINESS CONDUCT

THE CODE OF ETHICS AND BUSINESS CONDUCT of DATATRONIC Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság
…/07/2023

1. Introductory provisions

DATATRONIC Kereskedelmi és Szolgáltató Korlátolt Felelősségű Társaság (hereinafter: “Company”) is committed to operating legally, ethically and transparently.
While performing their job duties, the employees of our Company are always obligated to act legally and ethically, in the best interest of the Company. This Code of Ethics (“Code of Ethics”) sets out the basic guidelines but does not regulate in detail all forms of expected ethical behavior.

Our Company, as an Oracle Partner, adheres to and ensures that its resellers, employees, and agents adhere to the Oracle Partner Code of Ethics and Business Conduct.

This Code of Ethics is made available on the www.datatronic.hu website.

2. Compliance with legal regulations

Our company is aware of and adheres to legal regulations and commercial practices related to lawful business operations. We comply with all our valid contractual obligations and do not abuse our rights.
Our employees must at all times follow all applicable laws and legal regulations, including this Code of Ethics and the Oracle Partner Code of Ethics and Business Conduct. Our employees must ensure proper and lawful operation and perform their duties accurately and fairly.

3. Fair business conduct

Our company participates in business competition, during which it refrains from violating business competition, damaging the reputation of any of its business partners and any behavior that harms the credibility of its competitors.
Our Company takes special care to ensure that our commercial activities do not harm competition, in the framework of which we make independent pricing and sales decisions and do not cooperate or coordinate our operations with competitors in a prohibited manner; our employees may not negotiate prices or enter into any formal or informal agreement with any competitor regarding prices, discounts, business conditions or operation and the channels in which our Company competes, if such coordination or agreement is contrary to the applicable competition laws.
In addition, our Company’s employees are responsible for building a relationship of trust with consumers and business partners. Consumers and business partners will be treated fairly, taking into account the requirement of equal treatment.
Our company is committed to complying with all applicable trade regulations, restrictions, sanctions, and import-export embargoes.
In all cases, customers and business partners must be treated fairly and equally, products and services must be presented with fair and accurate information (fair marketing and advertising), and all relevant information must be shared.

4. Anti-corruption

Our company strongly opposes all forms of corruption.
Our company and its members, executive officers and employees will do their utmost to prevent bribery in the government and private sectors, regardless of the reason. Accordingly, they may not commit, allow, or authorize a third party to commit, any act that results in a violation of the laws applicable to the cleanliness of public life and anti-corruption regulations being in effect at all times. This obligation applies, in particular, to unlawful payments made to government officials, agents of government agencies, and close relatives thereof, or persons within their close circle of friends.

In view of its obligation to comply with anti-corruption rules, our Company does not use the amounts or other remuneration paid to it by a contracting party for illegal purposes, in particular, for purposes that violate anti-corruption laws, that is, it does not directly or indirectly (by using a proxy) give or promise an unlawful advantage (including, but not limited to, e.g. cash, discount, overpayment, subsidy, commission, etc.) to a person/body performing a public function or a private individual for the purpose of assisting the other contracting party or the person(s) acting on its behalf in obtaining or keeping a business.

Our company does not employ a subcontractor, consultant, agent or representative whose person, reputation and integrity has not been thoroughly examined by the Company in a documented manner, and does not employ a subcontractor, consultant, agent or representative who does not comply with anti-corruption laws and will immediately inform the relevant contracting party in case of non-compliance with anti-corruption laws.

The term “persons performing public functions” shall include the following persons:

the officer, official or employee of a government, or any ministry, body, authority thereof, or any organization supporting the activity thereof (legislative, administrative or judicial body); the officer, official or employee of a regional governmental body, local government; the officer, official or employee of international public organizations;
a person who, while acting in an official capacity or performing a public function, acts in the name or on behalf of a government or a ministry, a governmental body, an authority or any organization supporting the activity thereof, a regional governmental body or an international public organization;
officers of political parties (or the political parties themselves);
candidates for offices at a body performing public functions;
officers of international organizations (such as the United Nations or the World Bank);
persons who, as public officers, have functional powers but are actually not employed by the body performing the given public function;
consultants and special advisers of bodies/persons performing public functions; and
officers and employees of state-owned companies and institutions (including for-profit companies), including hospitals, health institutions and universities.

The term “public body” includes the following: central or regional/local, state, governmental (including decentralized, government-supervised bodies), municipal or international, legislative, administrative or judicial bodies.

Our employees are prohibited from accepting or giving any rewards (such as bribes, gifts and free services, discounts or returns) in any form and in any business relationship.
Gifts may only be given centrally with the approval of the management, and employees may not give individual gifts to business partners nor accept gifts, discounts or money or commissions offered by a business partner to obtain profit.

5. Confidentiality

In the course of fair business operations, it is of utmost importance for our Company to preserve trade secrets.
Our employees are obligated to treat as classified and confidential any information that has come to their attention while performing their job duties and is not generally known or accessible to the public.
Only those employees of ours shall have access to confidential information for whom access to and knowledge of such information is indispensable for the performance of their duties.
Our company fully complies with, and ensures that its employees and agents comply with, the provisions of Act LIV of 2018 on the Protection of Trade Secrets.
Our company respects the intellectual property of others and, accordingly, does not participate in the unauthorized use, copying, distribution or alteration of proprietary intellectual property.

6. Privacy

Our Company ensures the enforcement of the constitutional principles of data protection and the requirements of data security, and prevents unauthorized access to data, alteration and unauthorized disclosure or use of data, whether as a data controller or as a data processor, in order to ensure that the privacy of the natural persons concerned – including the employees of our Company – is maintained.

Our Company handles personal data confidentially, in accordance with the applicable legal regulations, and ensures the security thereof, takes the necessary technical and organizational measures and establishes the necessary procedural rules to enforce the relevant legal provisions and other recommendations.

The personal data processed by our Company can only be accessed by our own employees, agents and other contributors who, in order to fulfill their job duties or perform the tasks they are required to perform, need to know the processed data. Our company ensures that those authorized to access the data we process comply with the requirements of the applicable laws at all times.

7. Records, reporting, financial integrity

We maintain and prepare our books, records, invoices and financial reports in sufficient detail, truthfully and in a manner that adequately reflects our transactions.
We are committed to fair taxation and refrain from any tax avoidance practices, such as failure to provide receipts or invoices, or the recognition of false expense accounts.
Our company strongly opposes all forms of money laundering and only maintains business relationships with partners that carry out legitimate business activities financed from legitimate sources.
Our employees are obligated to follow the Company’s accounting procedures in order to ensure that all transactions are recorded and documented in accordance with the relevant rules.

8. Human rights

The Company respects the human dignity and rights of all persons with whom the Company and its employees interact at work, including the Company’s own employees, and does not in any way cause or contribute to human rights violations.
In the course of their activities, our employees are obligated to behave respectfully towards everyone, with proper attention, and show respect for human dignity.

9. Discrimination and harassment

Our company provides equal opportunities in all areas of employment and does not tolerate any unlawful discrimination or harassment. Direct and indirect discrimination based on race, color, gender, sexual orientation, age, disability, language, religion, affiliation, political or other opinion, ethnicity, social origin, financial status, birth or any other characteristic is prohibited.
Our employees are obligated to refrain from any form of discrimination.

10. Working conditions

Our company makes every effort to promote equality in its employment practices. We strongly oppose the employment or contracting of child workers and any form of forced or compulsory labor. Our company also condemns all forms of undeclared employment, which distorts competition and destroys the financial foundations of the social security and tax system.

11. Environmental and occupational safety

Our company provides a clean, safe and healthy working environment. Our company is committed to minimizing the environmental impact of its operations by reducing the use of non-renewable resources (e.g., energy and water) and emissions of pollutants and waste. Employees are obligated to contribute to minimizing harmful emissions to the environment.
Our employees are obligated to contribute to the maintenance of a healthy and safe workplace by complying with occupational safety rules.

12. Conflicts of Interest

Our company’s decisions are based on an objective and fair assessment of the situation, during which it avoids the possibility of influence. Our Company does not allow its managers, representatives or employees to use the assets, information, personal data of the Company for their own advantage, or to use their position to gain personal advantage or to compete with the Company.
We expect our employees to act at all times using their common sense and with the best interests of the Company in mind when performing their duties. A “conflict of interest” exists when an employee’s personal interests (or those potentially related to his/her acquaintances or family) do not coincide with the interests of the Company.