CODE OF ETHICS

To meet all customer requirements and modern times, we promote a professional approach, reliability, ability to provide a comprehensive range of services and responsibility.

The main intention of REAL TRADE PRAHA a.s. (hereinafter referred to as the “Company”) is the domestic and foreign procurement of high-quality military technology – in this field we provide military vehicles, weapons and weapon systems throughout the world. A characteristic feature of foreign trade in military material is, in particular, the ability to secure supplies of individual pieces of technology, such as weapons, large-calibre weaponry, ammunition, bombs, missiles, tank technology, toxicology equipment, aircraft, helicopters and spare parts for the aforementioned technology as well as complex deliveries in relatively large quantities in the required quality, including sets of spare parts to ensure maintenance and repairs of the technology.

Specific services are provided by REAL TRADE PRAHA a.s. also for museums and collectors of military technology, to whom it supplies military equipment that is disabled, in full compliance with the legal regulations of individual countries.

The result of the responsible approach of the company is adoption of an internal compact system of rules, procedures and regulations, the purpose of which is the compliance of the required behaviour of employees and other persons with fundamental human rights, general ethical values, morals, legal rule and internationally recognized standards. The Code of Ethics is a part of the aforementioned system and as such it applies to all employees of the Company, including members of the Company’s bodies and external entities such as consultants, suppliers or agents representing the company (hereinafter the “Personnel”).

REAL TRADE PRAHA a.s. does not tolerate at all any acts of its Personnel that could be considered illegal, corruptive, unethical, unfair or immoral. The Company considers such conduct as reprehensible and unacceptable within the set image of behaviour and conduct.

BASIC ETHICAL AND MORAL VALUES, CORPORATE POLICY FUNDAMENTALS

All Personnel are obliged to comply with and respect the valid legal regulations of the Czech Republic, the Company’s internal standards, and the provisions of this Code of Ethics.
All Personnel are obliged to proceed with diligence and conscientiousness in performing their work for the Company, and to act in a manner complying with ethical rules, good morals, moral principles and legal provisions.
In performing their job obligations, all Personnel shall approach the business partners, external entities, public authorities, media, colleagues, subordinates and supervisors in honest and professional manner, with esteem, dignity and respect.
No one is entitled to provide false, incomplete or inaccurate information when communicating with third parties. Everyone only communicates clear, complete and accurate facts, and does not abuse anyone’s mistake.
Everyone is obliged to treat third parties with dignity and respect, in particular any form of discrimination or unequal treatment is strictly prohibited.
The Company provides training and education to support the professional development of the Personnel.
Managers are always obliged to properly present and observe the rules contained in the Company’s internal documents. The individual Personnel should become role models for their subordinates, with ethical, moral, legal, anti-corruption and decent behaviour being their main priority and advantage. Managers are responsible for the behaviour of their subordinates and the condition of the worksite, at least to the extent that they have the obligation to control the compliance with the Company’s rules.

CONFLICT OF INTERESTS AND PROHIBITION OF COMPETITION, COMPETITION RULES

Loyalty, openness and communication with the Company are the cornerstones on which the attitude of every member of Personnel should stand.
Personnel may engage in gainful activity in addition to their employment only on the condition that such activity does not interfere with the legitimate interests of the Company, and is performed in accordance with laws. In addition, a member of Personnel may only engage in a gainful activity in a competitive sector with the consent of the Company’s statutory body.
All Personnel are obliged to proceed in such a way to avoid situations where their personal or financial interests would conflict with the interests of the Company. Any potential benefit for the Personnel, persons close to the Personnel, or for close natural and legal persons with whom the personnel have personal, business or professional relationships is considered as a personal interest.
During the employment relationship with the Company, no member of Personnel is entitled to acquire or hold a direct or indirect major share in another company (at least 15%), with which the Company conducts or may conduct business, or which is a competitor, unless the aforementioned has been approved by the statutory body of the Company.
A conflict of interest also includes transfer or allowing transfer of any information and know-how that the Personnel have received in the course of their duties in the Company and that are capable of helping competitive activities of the others. Such conduct is considered as absolutely inadmissible and as a particularly serious breach of working duties.
Without the prior written consent of the statutory body of the Company, no member of Personnel is entitled to negotiate or conclude on behalf of the Company any contracts or business relationships with business entities that are managed, controlled or owned by members of their family or legal entities that are financially or personally connected with the relatives or a cohabitee of the member of Personnel.
The Company and all its Personnel shall comply with the economic competition rules, in particular they shall not perform any act that could be considered as an unfair competition; they always act fairly, professionally and transparently.

RELATIONS WITH THIRD PARTIES AND BRIBERY

The Company and its Personnel are obliged to act in a manner not contradicting the law, particularly in such a manner that their conduct may not by characterised as a corrupt conduct. Corrupt conduct is, for example, accepting or offering a bribe, negotiating an advantage or any material or intangible reward in connection with the Company’s business and performance of the Personnel’s activities. Corrupt conduct also means offering any reward, benefit or profit to a public authority that could result in a misrepresentation, or issuance of a decision by the public authority in favour of the Company.
Any illegal conduct or machinations in relation to public proceedings, public and private contracts and tenders, selection procedures, etc., such as lying, misleading, extortion, use of violence, fraudulent behaviour, etc., is prohibited.
The Company and its Personnel are obliged to always provide true, complete and full information, especially record all financial transactions in connection with the Company’s business in the bookkeeping so that a proper financial report may be elaborated for the competent governmental authorities.
All Personnel are obliged to carefully manage and handle the Company’s movable assets, including the entrusted assets, real estates, Company’s trade secret and intellectual property.
No member of Personnel is entitled to require or accept gifts, services, favours or benefits for themselves or for others, and is not authorized to provide any gifts, payments, rewards or services to a business partner of the Company, governmental body or any third party, except for such gifts of minimum nominal value, which represent promotional materials or promotional items or which mean a normal social courtesy not in conflict with the Company’s business rules.
The Company provides or may provide, where appropriate, monetary and in-kind donations for a certain purpose to finance science and education, research and development, culture, education, fire protection, youth support and protection, animal protection and their health, for social, medical, ecological, humanitarian, charitable, physical education, sports and political purposes etc.

CONFIDENTIALITY

The Company maintains information security, protection of trade secret and personal data.
The Company regularly assesses the risks relating to data and information protection, and takes measures that in their final consequence will prevent misuse, acquisition or dissemination of information by unauthorized persons. All Personnel are obliged to work with sensitive data and information in such a manner that there is no leakage or misuse.
All Personnel shall maintain the confidentiality of all facts learned in connection with performing the working duties, which have or may the nature of business secret, confidential information, personal data or are subject to confidentiality. Trade secret primarily means all business, production or technical information relating to the Company’s business that has actual or at least potential value. Confidential information includes, but is not limited to undisclosed information relating to the Company, its decisions, planning, financial transactions, inventions, development and technical schemes, technologies, designs, clients, customers, competitors, or any other information generally unknown in the industry that relates to the Company.
Every member of Personnel who processes or otherwise handles any personal data in performing their duties is obliged to act in accordance with the law and regulations of the European Union.

OCCUPATIONAL SAFETY AND ENVIRONMENTAL PROTECTION

The Company protects the health and life of the Personnel and property, maintains a healthy, safe and friendly working environment, and strives for its continuous improvement.
All Personnel are obliged to pay maximum attention and to devote to the surroundings such due care and diligence to help create a safe and healthy working environment, and to take all measures to revert any imminent damage if there is a risk of bodily injury or damage to property or environment. If the Personnel are not in a position to revert the danger, they shall immediately warn their supervisors or other authorized persons who are able to prevent or at least mitigate the damage.
All Personnel are obliged to follow all legal regulations, especially those concerning occupational safety, binding internal rules, procedures and policies of the Company, and to observe all occupational safety rules. At the same time, each member of Personnel is obliged to report to their supervisor or in accordance with this regulation, any violation of regulations concerning protection of health, property or environment, which such member of Personnel witnesses or learns of.
The Company is committed to minimize the negative effects of business activities on the surroundings and especially on the environment. The Company puts emphasis on achieving environmental sustainability and seeks innovative solutions supporting environmental protection. The Company organizes regular Personnel training and sets out the binding internal regulations to protect the environment at every level of the Company, focusing on all components of the environment. All the Company’s Personnel act in accordance with the idea of environmental protection

MONITORING THE COMPLIANCE WITH ETHICAL RULES AND REGULATIONS, AND THE POSSIBILITY OF SUBMITTING SUGGESTIONS TO THE COMPANY

The Company declares and consistently ensures that this Code of Ethics is always observed by all the Company’s Personnel. All Personnel are obliged to report any violations of any legal regulations, internal Company’s standards or rules to their supervisors, or to the Company.
With a view to the efforts to maintain the highest degree of transparency and the ability to flexibly respond to the current and existing situations, the Company establishes such possibilities for the Personnel and any third parties who would witness a violation of the aforementioned rules to inform the Company.

These possibilities particularly includes the Company’s communication channels:

Suggestion box (including anonymous filings),
Company’s e-mail – compliance@realtrade.cz,
In paper form as a postal shipment (including anonymously),
Competent supervisor.

ALL PERSONNEL NOTE THAT ANY ABUSE OF THE POSSIBILITY OF FILING A SUGGESTION OR FILING A GROUNDLESS OR BULLYING SUGGESTION IS CONSIDERED AS UNETHICAL AND IMMORAL ACT, FROM WHICH THE RESPECTIVE CONCLUSIONS SHALL BE DRAWN.

FINAL PROVISIONS

All Personnel note that a breach of the rules of the Code of Ethics is considered as an excess of the member of Personnel, and as such it will be considered as a breach of working obligations, and in justified cases it may be considered as a gross violation of working duties with consequences under the Labour Code. Any violation of the rules and regulations may constitute a reason for sanction or termination of the employment relationship.