Company Policies

Company Policies

Table of Contents:

  1. Equality, Diversity and Iclusion Policy
  2. Health, Safety and Environment Policy
  3. Political Engagement Policy
  4. Anti-Corruption and Bribery Policy
  5. Anti-money laundering Policy
  6. Competition Law Policy

EQUITY, DIVERSITY AND INCLUSION POLICY


SCOPE AND APPLICATION

Aluminij Industries (hereinafter “Aluminij” or “we”) has the responsibility of approving the Equity, Diversity and Inclusion Policy for all employees and companies under M.T. Abraham Group, that are engaged with the mutual goal of creating a work environment that fosters Equity, Diversity, and Inclusion.

People are the most important asset of Aluminij, for this reason the difference and plurality of people, equality of opportunities, non-discrimination and inclusion in the workplace are priority and strategic factors in the organization.

Aluminij maintains a strong will to promote equity, diversity, and inclusion, through inclusive leadership as a lever change and business sustainability.

A truly diverse and inclusive culture is crucial to helping us grow our business and attract, develop, and retain talent.

This policy focuses on creating a climate which allows diversity in all of the following areas: gender, age, sexual orientation, culture, race, religion, thought, education, talent, social condition, individual quality, work style, disability, special needs or any other circumstance of employees; and, at the same time, rejecting any type of discrimination for said reasons which may prevent the growth of Aluminij or that affects selection, retention, development and well-being of its employees.

Equity, diversity, and inclusion is a business and commercial imperative in Aluminij, and a diverse workforce strengthens our culture and our ability to deliver our business objectives. We expect and need our workforce to perform at their best and we strive to create a culture that embraces different perspectives to drive the business forward. This policy sets out our approach to equity, diversity, and inclusion.

Aluminij is committed to Equity, Diversity and Inclusion through the socially responsible, integrating, inclusive and transversal management of its human team, based on the variety of different cultures, backgrounds, knowledge, skills and experiences to develop the full potential of the organization, providing equal opportunities to promote equity in the workplace, non-discrimination, direct or indirect, on the basis of sex, age, race, religion, sexual orientation, thought, education, social condition, culture, work style, talent, individual quality or special needs such as illness, disability, accident or family situation, and inclusion to provide fair opportunities of work for people with disabilities, older people or people from vulnerable situations.

POLICY BREACHES

All of our employees, and companies under M.T. Abraham Group are responsible for ensuring that we meet our commitments.

All Aluminij’s employees have a responsibility to treat others with dignity and respect at all times.

We expect our employees and contractors to speak openly and raise concerns about possible breaches of the Code of Conduct and this policy.

Aluminij has zero tolerance for retaliation against anyone who speaks openly about conduct they believe is unethical, illegal, or not in line with our Code of Conduct and policies, even if the concern isn’t substantiated, as long as they have not knowingly made a false report.

Any employee found to have exhibited any inappropriate conduct or behavior against others may be subject to disciplinary action.

Any questions regarding this Equity, Diversity and Inclusion Policy may be directed to the Human Resources team at Aluminij.

POLICY REVIEW

This Policy shall be reviewed from time.


HEALTH, SAFETY AND ENVIRONMENT POLICY


APPLICABILITY AND PURPOSE

Aluminij Industries (hereinafter „Aluminij“ or „we“) top priority is the health and safety of our employees, contractors and others who may be impacted by our operations. We are committed to providing a healthy and safe workplace for all employees as well as safe products and services for customers.

Our concept focuses on prevention, with health and safety being integrated into all of our activities in order to create a safe working environment.

This policy applies to all employees, directors, and also to all other contractors that are under Aluminij direct supervision and they are all required to follow all safety instructions.

They are also responsible for taking reasonable care for their own health and safety and that of others who may be affected by what they do or do not do.

Health, Safety and Environment policy is the fundamental elements of Aluminij approch to health and safety and environment.

Business unit managers are responsible for the health and safety of their employees, and for compliance with policies and relevant regulation/legislation. They are also responsible for providing safe work equipment, methods of work, and the necessary training to all employees, addressing specific training needs as required.

All individuals that enter into premisises of Aluminij have a obligation to work in a safe and healthy manner and to look out for one another. Our workforce must report any unsafe acts or conditions to management who will follow up and rectify.

If an employee experiences a work-related injury or illness, they should seek medical assistance as quickly as possible from a competent person and then report the matter to human resources or a senior member of staff immediately.

Aluminij puts a significant focus on environmental protection and recognition in the local communities and business partners through its business operations.

Environmental policy is grounded on the law legislation, and we care about environmental protection thus regularly monitor air, water, soil, vegetation and conduct adequately a waste management system which is in direct correlation with health and protection of the community and its flora and fauna. We educate every new employer in our company about environment policy through our internal education.

Aluminij is committed to:

  1. Providing and maintaining a safe place of work, with safe means of entry and exit,
  2. Providing and maintaining safe plant, safe equipment and safe systems of work,
  3. Providing and maintaining a safe and healthy working environment, by identifying and mitigating or eliminating workplace hazards and reducing occupational health & safety risks,
  4. The control of the health and safety risks arising from work activities,
  5. Providing and maintaining the necessary information, instruction, training and supervision to protect safety and health at work.

POLICY BREACHES

Non-compliance with this Policy may result in disciplinary action.

Any questions about possible health and safety hazards, laws, or policies governing the workplace at any facility, should be brought to the timely attention of facilities management, human resources, or a senior member of staff.

POLICY REVIEW

This policy will be reviewed from time.

Together we can achieve a safe and pleasant work environment.


POLITICAL ENGAGEMENT POLICY


APPLICATION

This Policy applies to Aluminij Industries (hereinafter “Aluminij” or “we”) and all employees, and officers.

ENGAGING IN THE POLITICAL PROCESS

Aluminij has a policy in place which prohibits donations being made that would:

  • improperly influence legislation or regulation,
  • promote political views or ideologies, and
  • fund political causes.

Aluminij does not favour or supports any political party, group or individual.

We do not get involved in political activities or have any political links.

Aluminij may engage in public policy discussions where relevant to our business, employees, customers, suppliers, end users and the communities in which we operate. Any such engagement must be approved in advance by the Chief Executive Officer.

PROHIBITED ACTIVITIES

Aluminij employees shall not:

  • use or associate their position with any political activity or in any manner through which any such association could be reasonably inferred, or
  • engage in campaigning for or promoting any political party or candidate in the workplace or seek to pressure or influence co-workers to vote for any particular political party or candidate.

POLICY BREACHES

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this Policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment

We expect our employees and contractors to speak openly and raise concerns about possible breaches
of this Policy.

POLICY REVIEW

This Policy shall be reviewed periodically.


ANTI CORRUPTION AND BRIBERY POLICY


SCOPE

This Policy applies to Aluminij Industries (hereinafter “Aluminij” or “we”) and all employees, and officers.

In addition, the Aluminij expects its agents, consultants, representatives, suppliers, vendors, contractors, advisors, business partners and any other person that performs services for or on behalf of the Company to comply with the principles contained in this Policy.

It is intended to minimize Aluminij’s risks related to bribery and corruption and to emphasize responsibilities under both the relevant anti-corruption laws and our policies. It also provides guidance on identifying potential risks, dealing with challenging situations and reporting when those situations violate or may lead to a violation of this Policy and Anti-Corruption Laws.

Corruption and bribery are illegal and unethical, and any violation of relevant anti-corruption laws can lead to severe civil and criminal penalties and reputational harm to Aluminij.

Aluminij has zero tolerance for corrupt activities of any kind. Bribes or other improper or unauthorized payments, or acts that create the appearance of promising, offering, giving, or authorizing such payments, are prohibited by this Policy.

Offering, promising, and authorizing the giving of money, or anything else of value, to a government official in order to secure an improper advantage is strictly prohibited.

The Company’s prohibition on bribery applies to all improper monetary or non-monetary, tangible or intangible bribes; payments of money; gifts or entertainment, discounts, loans and/or financing given on non-commercial terms, rebates or kickbacks in relation to services provided, including “facilitating” (or expediting) payments. Facilitating payments refer to small payments to government officials to expedite or facilitate non-discretionary actions or services, such as obtaining an ordinary license or business permit, processing government papers such as visas, customs clearance, providing telephone, power, or water service, or loading or unloading of cargo.

INDICATORS FOR SUSPICION OF CORRUPT ACTIVITIES

The following is a list of activities that may indicate the possible existence of corrupt practices and should be kept in mind by all those subject to this Policy:

  1. Unusually large commission payments,
  2. Cash payments, or payments made without a paper trail or without compliance with normal internal controls,
  3. Unusual bonuses for which there is little supporting documentation,
  4. Payments to be made through third party countries or to offshore accounts,
  5. Unexplained preferences for certain sub-contractors,
  6. Invoices rendered or paid in excess of contractual amounts.

This list is not exhaustive.

GIFTS AND ENTERTAINMENT
This Policy does not prohibit normal and appropriate hospitality (given or received) to or from third parties.

Gifts and entertainment are commonly offered as gestures of gratitude or tokens of appreciation. We allow these tokens and gestures when they are reasonable, proportional, made in good faith and in compliance with our Code of Business Conduct and Ethics and this Policy.

All employees should consult with their superior for further guidance on giving or accepting gifts or forms of entertainment or hospitality.

It is not acceptable for any employee to:

  1. give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Aluminij will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
  2. accept payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage;
  3. threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under this Policy; or
  4. engage in any activity that might lead to a breach of this Policy.

POLICY BREACHES

It is the responsibility of all employees to ensure compliance with this Policy. Any employee who witnesses a breach of this policy is obliged to promptly contact Aluminij’s Compliance Officer.

Aluminij’s employees that violate these laws can face severe disciplinary, civil and criminal penalties.

POLICY REVIEW

This Policy shall be updated from time.


ANTI-MONEY LAUNDERING POLICY


APPLICATION

Anti-money laundering (hereinafter „AML“) refers to the laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.

This Policy has been developed by Aluminij Industries (hereinafter “Aluminij” or “we”) to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its products. We do not assist, support, participate in or permit money laundering or terrorist financing.

Aluminij strongly upholds all laws relevant to preventing money laundering in all of the jurisdictions in which Aluminij operates.

This Policy applies to Aluminij and all employees, and officers. It provides information and guidance on how to recognize and deal with money laundering issues.

All Aluminij’s business partners are requested to follow the same principles and commitments regarding anti-money laundering and to adhere to the provisions of this Policy at all times while conducting business with Aluminij.

PROHIBITED ACTIVITIES

The following types of activities are prohibited under this Policy:

  1. the conversion or transfer of property (including money), knowing or suspecting that such property is derived from criminal or certain specified unlawful activity (“criminal property”), for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
  2. conducting a financial transaction which involves criminal property;
  3. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;
  4. the acquisition, possession or use of criminal property;
  5. promoting the carrying on of unlawful activity; and
  6. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

INDICATORS FOR SUSPICION OF MONEY LAUNDERING ACTIVITIES

The examples of possible indicators of suspicion for money laundering activity:

  1. transactions which have no apparent purpose, and which make no obvious economic sense;
  2. where the client/business partner refuses to provide the information requested without reasonable explanation;
  3. A client/business partner refuses to proceed with a transaction when asked for identification;
  4. where cash payment been offered by the business partners/clients;
  5. business activities that contradict core values;
  6. suspiciously close ties to government officials, previous allegations of corruption or unethical behavior or a lack of proportionality between the proposed work and fees;
  7. engage in any activity that might lead to a breach of this Policy.

The above is not intended to be an exhaustive list.

POLICY BREACHES

Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.
Any uncertainties as to whether a particular act constitutes money laundering, or any other queries, should be raised with Aluminij’s Compliance Officer.

Aluminij is committed to ensuring that no one suffers any detrimental treatment as a result of their good faith reporting of their suspicion under this Policy.

POLICY REVIEW

This Policy shall be updated from time.


COMPETITION LAW POLICY


INTRODUCTION
The maintenance of high ethical standards in adhering to national and international laws is one of the fundamental Aluminij Industries (hereandafter „ Aluminij“ or „we“) Principles.

Competition laws – also referred to as antitrust laws – are designed to protect competition. They prohibit business behaviour which has the objective or the effect of preventing, restricting or distorting competition. It is the belief of the management that even in the absence of such laws, the interest of the Aluminij, its employees and other are best served by the principles of free market economy and fair competition. For these reasons, it is the policy of the Aluminij to comply strictly, in all respects, with competition laws.

PURPOSE

As a company with worldwide business activities, Aluminij is subject to the competition and antitrust legislation in many jurisdictions. Although countryspecific legislation is different in application, the underlying principles of anticompetitive behaviour are similar and the guidelines provided below highlight these behaviours.

This Policy is designed to make both management and employees aware of the basic rules, and how these rules affect their business behaviour in making commercial decisions.

This Directive cannot cover all facts and circumstances that may encounter in business activities. Accordingly, it is strongly recommended and expected that in every case of doubt or in any instance where an employee has a question as to whether a particular course of action is appropriate or not, should contact the legal department for advice.

This Policy sets out Aluminij approach to ensuring that we fully comply with competition laws applicable to our business activities and that we appropriately manage associated risks.

We are committed to competing fairly across our global operations and do not engage in practices that restrict fair market competition.

We are aware that the greatest risks occur when dealing with competitors, in particular through commercial agreements, coordinating strategy or exchanging sensitive information.

Competition laws aim to protect consumers by promoting free, undistorted competition between companies, protecting independent decision making of market participants, and preventing the misuse of market power.

In certain circumstances, agreements with competitors may be considered permissible when their restrictions to competition are outweighed by efficiencies, eg improvements in technology or production. Examples of such arrangements are Joint technical or quality control standards or Joint research and development ventures.

When employees are proposing, or invited to participate in, any arrangement with competitors, they must inform and consult with their Legal Department immediately and before the event.

We do not discuss or share commercially sensitive information with our competitors unless there is a legitimate reason, as this can of itself be a hardcore breach of competition law. We do not share detailed current and future pricing, cost and volume information and future strategy and investment plans, as this type of information is particularly high risk.

We do not share high risk information with our competitors.

We must inform Legal if we receive, or are asked to share, this type of information with a competitor.

Particular risks arise when the supplier,customer or agent is also a competing producer. We must not enter into agencyor marketing agreements with competing producers without consulting Legal.

The obligation is on each employee to bring to the attention of the Legal Department as soon as an employee suspects that a transaction or activity may be viewed as anticompetitive promptly and before any action is taken on behalf of the Company, circumstances which may have anticompetitive implications.

POLICY BREACHES

We look out for certain clauses whichare considered hardcore breaches invertical agreements and which attract significant penalties.

Failure to address the risk of anti-competitive practices may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/or individuals.

POLICY REVIEW

This Policy shall be updated from time.