CODE OF CONDUCT

The Code of Conduct aims to promote the development of business ethics, establish understandable standards of value, inspire, and support all employees in their actions and draw a clear line between good and bad behaviour The Code of Conduct contains the guidelines, values and principles that provide the framework for our actions. The main goal of the Code of Ethics is that every employee contributes to the achievement of the Company’s strategic goals through his or her behaviour and actions. In our work, we face not only professional but also ethical and moral issues. We must deal with them by regulations and standards, as well as with the principles of business ethics.

This document applies to all employees working for INTECTIV (including managers, directors, executives, team leaders, employees, temporary staff, agency staff, substitute staff, subcontractors, or consultants) and includes other organisations that do business with us.

2.1 MISSION

For 40 years, the company’s commitment to product quality, a healthy environment and continuous improvement have been at the heart of its strategy. We keep up with the ever-increasing demands by advancing in quality and reliable customer support for our products.

With our innovative solutions, we set new standards, push the boundaries of what is possible and thus promote the progress of the electronic and electrical industry in domestic and foreign markets. With our knowledge, flexibility, efficiency, and investment in development, we are striving to become a market leader in Europe, specialising in the production of prototype and multilayer printed circuit boards.

2.2 VISION

We will continue to be a leading, quality provider of printed circuit boards with efficient, innovative, and comprehensive solutions in the PCB manufacturing field. We will ensure a fair return for our owners while developing and maintaining a stimulating and good working environment for our employees.

2.3 VALUES:

EXCELLENCE AND QUALITY

We ensure high-quality printed circuit boards, while complying with European and global quality standards, adding professional performance in the manufacturing process itself while respecting the highest environmental, safety and IT standards.

INNOVATION AND ADAPTABILITY

We are committed to innovation in processes, combined with a high degree of knowledge in our employees and adaptability to the market and our customers.

TEAMWORK AND TRUST

We encourage teamwork on projects, interpersonal collaboration between employees and cooperation between departments in production. We treat all employees equally and with respect and encourage open and honest communication.

SAFETY AND HEALTH

Employee safety and health is the highest priority and responsibility of everyone in the company, as well as the company’s management.

ETHICS AND FAIRNESS

We conduct our management and business to the highest ethical and moral standards.

COLLABORATION

We encourage collaboration between employees, owners, partners, suppliers, customers, and the local and wider environment.

Ethical behaviour is decision-making based on values. Certain key questions can help us identify situations that may be unethical, inappropriate, or illegal.

Let us ask ourselves:

• Is what I am doing legal?
• Does it reflect our company values and ethics?
• Is it in line with the company’s code and rules/policies?
• Does it respect the rights of others?
• How would it look if it appeared on the front pages of newspapers?
• Am I loyal to my family, my company and myself?
• Is it right for me to do this?
• What would I tell my child to do?
• Has anyone asked me to misrepresent information or to deviate from normal procedure?

If we answer yes to these questions, we are on the right track and we are acting according to the company’s ethical standards. Otherwise, we are harming society and ourselves.

Business and personal reputation is the result of the work of all employees. And it is important to maintain, nurture, and encourage the reputation every day. Therefore, the guidelines in this Code of Conduct should be to make the right judgements about our decisions, actions, and behaviours.

4.1 COMPLIANCE WITH LAWS AND REGULATIONS

Our commitment to integrity starts with compliance with laws, rules, and regulations. We understand and respect legal requirements and legitimate business practices.

We are committed to honouring all valid and binding contractual agreements we enter and not abusing our rights.

4.2 SUSTAINABILITY: PEOPLE + PROFIT + PLANET

We are committed to meeting the demands of the present without compromising the needs of future generations. That is why we combine economic, environmental, and social factors in our operations and business decisions.

4.3 HUMAN RIGHTS

We are committed to respecting the human dignity and rights of every individual and community with whom we interact or engage in our business. We do not cause or contribute to human rights violations in any way. Our colleagues treat everyone with dignity, respect and care and uphold human rights.

We work with respect for human rights and freedoms in our recruitment and our dealings with our  employees – whether they are our superiors or our subordinates.

4.4 EMPLOYEES PERFORM THEIR WORK CONSCIENTIOUSLY AND RESPONSIBLY

Employees must act in the best interests of the company, which means that they must act in the company’s long-term interests.

Employees must perform their duties efficiently, professionally, and diligently, in compliance with applicable laws and the Company’s internal regulations. Employees also demonstrate their loyalty to the Company by consistently fulfilling their obligations and by accepting additional work and tasks when necessary. Employees also have a duty and an obligation to participate in education, training, and seminar to keep their job or to improve their job skills under the employment contract.

Employees take personal responsibility for their work. Their daily professional work enables the  company to operate successfully, ensuring safeguarded jobs and creating new ones. Every manager sets an example for employees by his or her behaviour.

The manager informs his/her colleagues about the content of the Code and is there to help them when they approach him/her. Every communication within and outside the company is a mirror of our behaviour and society.

4.5 FAIR LABOUR PRACTICES AND WORKING CONDITIONS

We are committed to promoting equality and fair employment in our recruitment practices and to a pay policy that complies with applicable laws. We are strictly against the employment or contracting of child labour or slave labour or any form of forced labour or enslavement.

We condemn all forms of illegal, unfair, and unethical labour practices that exploit labour, destroy social security, or serve as tax evasion, including undeclared work or the “shadow” economy and withholding of payments.

Our employees act with integrity and treat their colleagues and others with respect at work.

4.6 DISCRIMINATION AND HARASSMENT

We guarantee equal treatment in employment and do not tolerate discrimination or harassment or abuse of any kind. We do not tolerate any direct or indirect discrimination based on any professionally irrelevant characteristic or circumstance, such as gender, marital status, age, national or social or ethnic origin, colour, religion and political opinion, disability, sexual orientation, worker representation, wealth, or another status. All types of discriminatory behaviour, harassment, bullying, or mistreatment are prohibited.

Every staff member should observe the highest standards of conduct based on mutual respect in all oral and written communications, and all staff members should avoid all forms of harassment, defamation or any behaviour that could be aggressive, intimidating, humiliating, malicious or offensive.

4.7 HEALTH, SAFETY AND ENVIRONMENT

We ensure clean, safe, and healthy working conditions and are committed to maintaining a healthy environment. We are committed to reducing the impact of our operations on the natural environment as far as possible.

We strive to reduce the use of scarce resources such as energy or water, and harmful emissions such as those from waste. All employees must always observe and comply with all relevant laws, regulations, and rules to protect health, safety, and the environment.

The company implements several health promotion measures in the workplace. We do not tolerate behaviour in the workplace that creates a work environment that is unproductive, discouraging, or offensive. We also consider working under the influence of alcohol and intoxicating substances to be unacceptable behaviour.

4.8 PROHIBITION OF BRIBERY AND CORRUPTION

The company does not tolerate any form of corruption in its operations. In addition to the giving and receiving of bribes, corrupt acts include any other conduct which seeks or attempts to obtain an advantage or benefit for oneself or a third party by abusing one’s authority or position in a manner inconsistent with one’s responsibilities.

To ensure the integrity of the company, we comply with the provisions of the Integrity and Prevention of Corruption Act.

4.9 WE DO NOT GIVE OR ACCEPT INAPPROPRIATE GIFTS

No employee of the Company shall, in consideration of the performance of his/her work or his/her position in the company, solicit or accept any gift or benefit for himself/herself or for his/her family, close relatives, friends, persons governed by public or private law, which may appear to affect the impartiality with which he/she carries out his/her duties.

4.10 SAFETY, SECURITY AND PROPER USE OF COMPANY ASSETS

We are responsible for the safety, security, and economic use of company assets. Our assets, including time, materials, equipment, and information aimed solely for legitimate business use.

Occasional personal use is permitted only if it is lawful, does not interfere with work performance and does not disturb morale in the workplace. Every employee should observe appropriate security measures and treat company property, tangible or intangible, with respect and not misuse or neglect company assets.

4.11 DATA PROTECTION AND INTEGRITY

Trade secrets, confidential information, and personal and internal company data are valuable assets. Protecting it, which includes keeping it secret, plays a key role in the growth and competitiveness of the company.

The data and information obtained by employees or other persons in the course of their work for the company are confidential (“sensitive data”) and must not be disclosed or made accessible to third parties.

Information is confidential if it is marked as such, even if it is not marked as such, but significant harm would result if it were to come to the knowledge of an unauthorised person.

Sensitive data include:

Personal data – any data relating to an individual, regardless of the form.

Trade secret – information of particular importance to a company in achieving its economic and other advantages. Trade secrets are information concerning the economic activity, strategic or economic or property, financial, market or personnel situation of the company or its business and information about business partners or customers. They are of such a nature that their disclosure could harm the interests of the company or its business reputation. We are bound by the obligation of professional secrecy even after the termination of the contract of employment.

4.12 PRIVACY, PERSONAL DATA PROTECTION

We respect people’s privacy and recognise the need for customers, employees, and other individuals to be able to trust that their data is processed appropriately and for legitimate business purposes. We are committed to complying with all data protection laws. We only obtain and retain personal data that is necessary, and we provide relevant information to data owners about these activities. We implement appropriate security measures to ensure the confidentiality, integrity, and availability of personal data.

4.13 INFORMATION SECURITY MANAGEMENT

Information security management ensures smooth and secure operations, which everyone contributes to by handling information responsibly. We protect information from unauthorised access. We ensure its confidentiality, integrity, and availability. We comply with the requirements of the Information Security Policy and align information security with business needs.

4.14 CONFLICT OF INTEREST

Our decisions must be based on objective and fair assessments and must be free from any undue influence. A “conflict of interest” exists when a particular employee’s interest (which may be associated with e.g., friends, family or also a customer, competitor, supplier, or contractor entity) conflicts or potentially conflicts with the best interests of the company. Determining whether a conflict of interest exists is not always straightforward, so anyone with questions about a conflict of interest should consult management.

Conflicts of interest can arise:

• If the person (you or a member of your immediate family) is employed by or has a business relationship with an actual or
• potential customer, competitor, supplier, or contractor.
• In the employment or control of family members or closely related persons.
• If the person is a board member of another company or organisation.
• If the person owns or has a substantial interest in the business of a customer, competitor, supplier, or contractor.
• If the person has a personal interest, a financial interest, or a potential personal benefit in any business of the company.
• If personal relationships develop between staff members, the senior staff member concerned must bring this to the attention of his/her manager to confirm that no conflict of interest exists and that no such conflict will arise.

4.15 RESPONSIBLE ATTITUDE TOWARDS CUSTOMERS, SUPPLIERS AND PARTNERS

We develop good relationships with our customers, suppliers, and clients, and we work hard to foster them. Trust and mutual respect are the cornerstones of our relationships. We respect good business practices and the satisfaction of our counterparties.

Honesty, integrity, professionalism, and respect for good business practices are fundamental principles that we must all uphold. We must create a level playing field for all business partners and respect agreed contractual terms.

4.16 A RESPONSIBLE ATTITUDE TOWARDS THE COMPANY’S SHAREHOLDERS

The company’s management acts in a professional, comprehensive, and timely manner to comply with the owner’s requirements, guidelines, and recommendations, and to communicate their content to employees. Through reliable performance and the implementation of the sustainability guidelines, we ensure that the Company adds value to all stakeholders in the immediate and wider environment.

4.17 ATTITUDE TOWARDS OFFICIALS CUSTOMERS, SUPPLIERS AND PARTNERS

We communicate with officials at all levels with respectful transparency.

5.1 IMPLEMENTATION OF THE CODE

Violations of the provisions of this code that are also violations of applicable law or the company’s bylaws shall constitute a breach of employment obligations and may give rise to disciplinary, compensatory, criminal, or other liability under applicable law and the company’s bylaws.

5.2 REPORTING BREACHES OF THE PRINCIPLES OF ETHICAL CONDUCT AND OTHER IRREGULARITIES IN THE COMPANY

Every employee should be alert to unethical behaviour and, if observed, report it to the Company Director, the Head of the Department (who must bring it to the attention of the Company Director or Human Resources) or to the Human Resources Department.

You can also submit an anonymous application by email to kadrovska@intectiv.si.

5.3 CODE PUBLICATION

The Code of Conduct was issued on the 13th of April 2022 by the Managing Director. He has informed the owners of the Code of Conduct and has forwarded it to the owners. The Code of Conduct is available on the company’s website www.intectiv.si and the Smart Arena app.

All new employees of the company are familiarised with the code in the Smart Arena app.