1       Introduction, Scope 

This document is the Code of Ethics for Business Partners of WSH Kft. (hereinafter: the Company), which contains the ethical standards, values and commitment of the Company towards its business partners, and serves as a guide (formulated as an expectation) for all our business partners to develop business and ethical conduct that the Company considers appropriate and should be followed. The Company is committed to legally compliant, ethical and transparent business partner relationships and business partner cooperation.

The basis for the Company’s favorable perception and business success is the trust of customers, manufacturers, external service providers and subcontractors in both the professional suitability/suitability of the products supplied and services provided, and the legally compliant and correct nature of the business cooperation. This applies equally to business relationships and human relations between the Company and its customers, as well as between the Company and all actors in the supply chain. The Company’s credibility is established and continuously strengthened by complying with legal requirements in all respects, by adhering to its commitment to fairness under all circumstances, and by achieving its goals only in an ethical manner. The Company carries out its business processes impartially, does not ask for or provide any undue advantages from anyone, and acts in good faith and does not do anything that would erode trust in the Company. The Company therefore recommends to its business partners and expects them to support the above-mentioned commitment, to join it and to identify with the Company’s ethical standards and values, and to follow them (both for themselves and for their value chains).

This Code sets out the expectations that the Company intends to enforce in relation to its business partners, following the ethical standards and values contained in its own Code of Ethics. With the provisions of this policy, the Company invites its business partners to take measures, depending on their number and organizational structure, the nature and complexity of their processes, their anti-corruption regulatory environment, and their exposure to corruption risk, in order to continuously ensure/maintain ethical business operations and conduct, as well as anti-corruption legal compliance.

The Company invites its esteemed business partners to immediately inform the Company about any corruption incident, unethical/irregular behavior or suspicion of any of these during business cooperation with the Company, by sending an e-mail to compliance@wsh.hu. It would be particularly useful for the Company if its business partners would share with it the results of their corruption investigations conducted in connection with the above-mentioned reports, in the event of their own involvement.

1.1      Personal Scope

The personal scope of this policy extends to the Company's employees who have any relationship with its business partners and who communicate with them in any way, as well as to natural persons acting on behalf of or for the benefit of the Company and in other legal relationships aimed at work, regardless of the type of legal relationship, who provide services to business partners.

1.2      Scope

The scope of this policy extends to all business partners of the Company, in particular including customers, manufacturers, external service providers, subcontractors and companies in which the Company has an ownership interest (hereinafter collectively referred to as: business partners), regardless of their activities, roles and geographical location in the business cooperation.

2       Core ethical values related to business partners

The Company's core ethical values that determine its business operations and the relationship with its business partners are as follows, from which the ethical norms and values recommended to and expected from business partners in accordance with Chapter 3 of these regulations have been derived:

  • compliance with legal and contractual requirements,
  • complete freedom from corruption and its appearance,
  • ethical, uninfluenced behavior,
  • responsibility and honesty,
  • honesty and integrity,
  • reliability and accountability,
  • respect for others, and care for business partners throughout the entire business value chain.

3       Ethical recommendations/expectations regarding business partners

The Company follows the ethical standards and values set out below in its cooperation with its business partners and, based on the principle of reciprocity, respectfully expects its business partners to follow/fulfill the same ethical standards and values as a supplement to or as part of the business partners' effective internal anti-corruption regulations.

3.1      Compliance with legal regulations and contractual requirements

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • compliance with legal and contractual requirements at all times, covering all details,
  • Identification, knowledge and application of laws and industry regulations, as well as internationally accepted methodological recommendations, necessary for law-abiding business conduct,
  • making all employees working on a given project aware of and enforcing validly undertaken project contractual obligations,
  • avoiding abuse of contractual rights (dominant power), refraining from their unfair application,
  • ensuring the necessary resources (including time) at all times to ensure full compliance with legal and contractual requirements and internal regulations, including this Business Partner Code of Ethics.

The legal framework for the application of the requirement of good faith and honesty in relation to ethical business conduct is contained, among others, in Act V of 2013 on the Civil Code.

3.2      Business relationships, public procurement transparency

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • good faith, trust, correctness, honesty, integrity, law-abiding behavior,
  • independence in decision-making,
  • environmentally friendly approach, application of sustainable solutions,
  • taking action against the enforcement of individual interests and the conduct and intention to obtain unilateral business advantage/profit in the implementation of business and professional processes,
  • ensuring the transparency, impartiality and legality of public procurement processes at all times,
  • applying tender notices that provide equal opportunities for all participants and ensuring the purity of the competition,
  • full compliance with legal requirements (regarding public procurement),
  • avoiding and prohibiting any unauthorized influence on tenderers and reviewers,
  • honest, fair, and impartial participation in public procurement processes, taking into account the interests of the public good and society,
  • in line with the directive on cost-effectiveness and efficient use of public funds to be enforced during public procurement, always starting from the most favorable market prices (with the same technical content) when setting the sales prices applied during public procurement processes and avoiding unfair business profit margins avoidance,
  • avoidance of coordination with competitors with the aim of reducing prices and/or reducing competition, prohibition of concluding cartel-type agreements, exclusion of any restriction of competition, prohibition of violation of competition rules and/or any form of unlawful influence on the public procurement procedure,
  • "single" participation in the same public procurement procedure in line with what is described in public procurement legislation,
  • eligibility for public procurement participation or exemption from the exclusion grounds specified in public procurement legislation must be proven by evidence issued by legal or authorized independent parties,
  • any restriction on the publicity of data in accordance with the principles of public procurement legislation, in particular related to the purity and publicity of competition.

3.3      Fair competition and business cooperation

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • compliance with competition and consumer protection legislation, as well as the rules of ethical and fair business competition,
  • sale/performance of distributed products and provided services based on their quality, suitability, compliance with IT professional requirements and competitive goods,
  • independent formation of sales prices, prohibition of their coordination with competitors and avoidance of prohibited cooperation with them,
  • avoidance of manifestations and actions that restrict competition, damage the favorable opinion of business partners and the credibility of competitors, avoidance and prohibition of offering and requesting of acceleration and/or illegal payments and/or favors,
  • avoidance of participation in illegal agreements aimed at excluding predetermined competitors,
  • compliance with all trade restrictions, sanctions, prohibitions, embargoes, etc. ordered by organizations authorized by law,
  • prevention of behavior that restricts fair competition by available legal means,
  • tisztességes versenyt korlátozó magatartás megakadályozása a rendelkezésre álló legális eszközökkel,
  • avoiding unjustified, bad faith and/or unlawful withholding or delay of legitimate payments, taking action against “chain debts” that may appear in the business value chain,
  • treating manufacturers and external service providers (subcontractors) equally (as equals), providing customers with detailed and accurate information about the products and/or services we manufacture and/or distribute, covering all their essential characteristics.

3.4      Anti-corruption

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • condemning and preventing all forms of corruption,
  • introducing an anti-corruption management system and, where possible, involving business partners in it,
  • avoiding and prohibiting the direct or indirect offering, promising, giving, requesting or accepting of any unfair advantage or benefit (facilitation payment, bank transfer, cash or its substitute (e.g. voucher, gift, travel, accommodation, service, etc.), credit line, discount or personal advantage) both for the purpose of obtaining business and in order to accelerate normal processes,
  • avoiding and prohibiting influence peddling (to unfairly influence a decision-maker) and creating the appearance of doing so,
  • avoiding and prohibiting any form of corruption, in particular initiating, accepting or allowing another to accept a bribe, whether for the purpose of obtaining business or in order to obtain other economic advantage,
  • for benefits obtained in the course of business activities the clear verification of the relevant authorization even afterwards,
  • disregarding the personal interests of our employees, making decisions free from external circumstances (e.g. promises or threats providing an unauthorized advantage, etc.),
  • avoiding and prohibiting encouragement and influence regarding corrupt behavior and its appearance,
  • immediately informing the Company's management and the relevant business partner in the event of a request for unethical, corrupt, illegal or immoral behavior or activity.

3.5      Freud prevention

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • fraud, false cost accounting, forgery or unauthorized alteration of documents, false entry of data in financial or other records/reports, misuse of IT equipment and their unauthorized use for private purposes, theft or damage to equipment or fraudulent behavior (e.g. aimed at cheating, stealing, deceiving or lying) is prohibited and typically sanctioned by legal means.

3.6      Gift-giving, hospitality, donation

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • avoiding all situations and behaviors that create the appearance of exceptional treatment given, received or requested in exchange for personal advantages, especially including business courtesies and favors (e.g. gifts, favors, meals, drinks, hospitality, entertainment or other benefits, etc.) from a person or economic operator with whom a business relationship exists or is planned to be established,
  • prohibition of giving and accepting business gifts, courtesies/favors that exceed the industry standard value limit, constitute unfair business incentives, violate the law, violate good taste and/or result in an embarrassing/uncomfortable situation,
  • giving and accepting occasional gifts or hospitality that are customary and in accordance with (reasonable) ethical principles commonly applied in the industry, if their value is less than 30,000 HUF/person, is occasional and does not serve to influence business decisions, or does not create the appearance of. The decision on the acceptability of business gifts of a value exceeding this is the responsibility of the executive, subject to the obligation of written authorization,
  • refusal of gifts, business courtesy/kindness of a value exceeding the above limit or, if received as a parcel, returning them or offering them for charitable (community) purposes,
  • support for public good, socially important and/or nationally significant causes according to an annual budget plan, as part of which the contributions, donations provided (and their settlement, accounting) comply with legal requirements and their individual value does not create the appearance that the Company requests/receives special treatment/consideration for itself or (some) of its employees in return,

3.7      Accounting, fair reporting and financial integrity

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • Maintaining company accounting, records, accounts and financial reports in accordance with the law, Accounting Policy and Chart of Accounts, in sufficient detail, truthful and recording all elements of transactions,
  • prohibiting all forms of money laundering,
  • cooperating only with legally operating business partners,
  • fair taxation and fulfilling the proportional burden of public charges, prohibiting all forms of tax evasion practices and settling false expense accounts,
  • precise compliance with accounting and financial (legal) rules, proper documentation and recording of economic events,
  • publishing complete, truthful, accurate and current financial statements certified by an independent audit conducted by an authorized service provider,
  • prohibiting unfairly influencing, misleading and/or manipulating an audit or any accounting control.

3.8      Decent employment and working conditions

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • creating/maintaining equality in the workplace, as well as ensuring remuneration that ensures a lawful and fair living,
  • prohibiting work performed by discriminated or disadvantaged workers (e.g. child, slave, forced, compulsory, etc. labor),
  • prohibiting all forms of unfair, illegal and/or unethical employment that serves to exploit labor and avoid or fail to pay taxes and public charges,
  • prohibiting the use of undeclared or "grey" work, withholding wages or tying wages to conditions beyond work.

3.9      Conflict of interest

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • avoiding unfair influence in our business and professional decisions, based on objective and fair consideration,
  • avoiding conflict of interest situations where personal interests harm or potentially harm the interests of business companies and organizations,
  • reporting conflict of interest situations and eliminating them based on management's discretion or recording them after management's approval.

3.10   Avoiding discrimination and harassment

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • ensuring equal opportunities in employment,
  • prohibiting discrimination, inappropriate (rough) treatment and all forms of harassment,
  • prohibiting discrimination based on any characteristics that are irrelevant to the assessment of professional and work performance (e.g. marital status, gender, age, national/social/ethnic affiliation, skin color, religious/political/sexual orientation, disability, membership of interest groups, property/birth status, etc.),
  • prohibiting any discriminatory behavior, defamation, harassment, intimidation or coercion of unauthorized advantage, and preventing it with all legal means at its disposal,
  • adhering to forms of behavior based on mutual respect in both oral and written (electronic) communication,
  • avoiding all forms of behavior that others may consider violent, humiliating, intimidating or offensive,
  • employees must only use professional and employment based on their work performance and support for their promotion.

3.11   Confidentiality, information security, trade secrets and intellectual property protection

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • commitment to ensuring the completeness, integrity, confidentiality and regulated accessibility of data/information,
  • application of technical and security measures specified in IT security and information security regulations and verification of compliance with them,
  • confidential management of data protected by law (personal data, bank secrets, business secrets, national classified data, foreign classified data, etc.), project data, business secrets, data regarding business partners that are not accessible from public data sources,
  • prohibition of trading in securities whose current or future value/price has been obtained during and/or as a result of cooperation with business partners, and prohibition of sharing this information with others,
  • regulated designation of employees carrying out communication with regard to internal data protection and confidential data management regulations, prohibition of communication by unauthorized persons,
  • respect for intellectual property, illegal or unethical use of intellectual products, business secrets or protected/confidential prohibition of obtaining information,
  • prohibition of unauthorized use, copying, distribution or modification of protected intellectual property,
  • compliance with and monitoring of (legal) rules regarding data protection, confidential management and respect for intellectual property.

3.12  Data protection, protection of personal data

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • respect for personal rights,
  • processing of their personal data for a purpose, in accordance with legal requirements and only to the extent necessary,
  • compliance with data protection laws and internal data protection regulations, with particular regard to following the procedures detailed therein that ensure the lawfulness of data management and processing,
  • informing data subjects about the processing of their personal data before it begins,
  • preserving the confidentiality, completeness, integrity and accessibility of personal and confidential data, preventing their unauthorized access, mishandling and/or loss, and making them accessible to unauthorized persons.

3.13   Quality requirements

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • providing high-quality IT products and services in accordance with contractual specifications,
  • operating processes that meet internal quality/quality management requirements in accordance with legal and regulatory requirements,
  • establishing and maintaining a system of authorizations/tasks/responsibilities/boundaries,
  • providing the highest level of IT product quality and service security available at a given cost level,
  • implementing product delivery and service delivery tasks on time and in good quality, in accordance with contractual specifications, fulfilling warranty and guarantee obligations,
  • measuring, monitoring and developing work and service performance.

3.14   Health, safety and environmental protection

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • creating and maintaining a clean, healthy and safe working environment,
  • reducing the impact of business and professional processes on the natural and built environment to the lowest possible level,
  • minimizing the amount of natural resources and energy sources used in processes, as well as the amount of harmful substances and waste generated,
  • fully complying with and enforcing occupational health, safety and environmental protection regulations.

3.15   Sustainability

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • completing processes without jeopardizing the opportunities of future generations or wasting their resources,
  • taking into account economic, social, environmental and occupational health factors when preparing business and professional decisions.

3.16   Human rights

In this area, the Company provides and expects the following from its business partners throughout the entire business value chain:

  • respect for human rights and preservation of human dignity,
  • prohibition of facilitating, committing and supporting human rights violations.

4          Handling potential violations

If the Company or one of its business partners seriously or continuously violates the ethical standards and values set out in this Business Partner Code of Ethics during business cooperation with the Company, the Company reserves the right to conduct an ethics investigation in order to uncover the violation and its circumstances and to request the support/cooperation of the given business partner for this purpose, and to take the necessary measures to eliminate the irregularity. In the absence of business partner cooperation or in the event of violations confirmed by the ethics investigation with evidence, the managing director decides on the implementation of the necessary measures, including taking mandatory measures prescribed by law, involving a competent body and/or terminating the contractual relationship with the business partner.

The Company does not tolerate corruption in any form, and therefore does not consider cooperation with business partners that are demonstrably involved in corruption to be continued.

The Company undertakes to demonstrate maximum openness towards its business partners with regard to anti-corruption activities and to share with them its general experiences of corruption incidents and ethical violations that may affect the Company. Based on the principle of reciprocity, the Company requests its business partners to share similar information. At the same time, the Company requests the cooperation of business partners in providing the data necessary for the determination of business partner corruption risks within the framework of its anti-corruption management system, including the presentation of a certificate issued by an independent party certifying the business partner’s anti-corruption compliance.

If the involvement or suspicion of the involvement of the business partner or a person acting on its behalf arises, it is the responsibility of the business partner to investigate it. The Company offers its cooperation to its business partners in the event that the involvement or suspicion of the Company or a person acting on its behalf arises in an ethics investigation that may be conducted by the business partners.

The Company makes this Business Partner Code of Ethics available to its business partners on the website https://www.wsh.hu.