Code of Ethics and Professional Conduct

EISA Limited, Ukraine, (hereinafter ‘EISA’ or ‘we’) has always been committed to promoting honest and ethical business conduct by all its employees, directors, managers, and agents (hereinafter collectively referred to as ‘Representatives’) and in complying with the laws that govern the conduct of its business worldwide. As a matter of principle we believe that complying with a specific code of ethics is a fundamental asset which builds firm relationships with our Representatives and all the parties EISA collaborates with. This commitment is stipulated in the present business Code of Ethics and Professional Conduct (hereinafter the ‘Code’). The Code defines corporate values and ethical standards for EISA and is based on generally accepted principles, norms of Ukrainian and international law and implements European best practices.

Adherence to clear and transparent rules of conduct set forth in the Code protects the impeccable business reputation of EISA and our Representatives, provides favorable working conditions, and shapes the relationship between employees. The Code is developed on the basis of generally accepted principles and norms of the legislation of Ukraine, international law and internal normative documents of EISA and extends to all Representatives regardless of the positions held and the duties performed. The Code does not provide any employment rights and does not guarantee employment for any period.

The objectives of the Code are:

  • establishing corporate standards of business ethics for EISA and regulation of the activities of all Representatives in difficult ethical situations.
  • orienting all Representatives to understanding, support and adherence to common principles of business ethics;
  • creating a friendly environment based on respect for each individual and creating conditions for their development.

  1. Reporting of Illegal or Unethical Behavior

    Representatives are required to report to their respective managers, any observed illegal or unethical behavior. This includes the cooperation in internal investigations of misconduct. We undertake to take all necessary action in order to protect any individual who has proceeded to such reporting in good faith from any possible retaliation. Any illegal or unethical behavior may be reported on an anonymous basis to the following email address: compliance@eisa.com.ua. All communications will be considered and investigated and treated confidentially to the extent reasonably possible.


  2. Legal Compliance

    We comply with all Ukrainian laws and regulations and Representatives are strictly required to do the same. It is the personal responsibility of each Representative to adhere to the standards and restrictions imposed by the applicable laws, rules and regulations, and with emphasis on relevant legislation relating to accounting and auditing matters. Any Representative who in uncertain whether a situation potentially violates any applicable law, rule, or regulation should contact their respective manager in order to obtain approval to consult legal counsel.


  3. Fair business conduct

    We conduct our business in a fair and ethical manner, in full support of the interests of our customers and conforming to accepted professional standards of conduct. Representatives must have honest, ethical and fair relationships with customers, suppliers, competitors and other Representatives, and no Representative should take dishonest advantage through manipulation, concealment, misuse of privileged information, distortion of facts, etc.


  4. Corruption and bribery

    EISA maintains a zero tolerance policy towards bribery. Representatives are prohibited from involving or using business partners, clients, or other persons to take actions that contradict the principles and requirements of this Code or the norms of the anti-corruption legislation of Ukraine. It is not allowed to give and receive gifts and invitations to/from business partners, customers, and other third parties that do not meet the requirements of the law, can be interpreted as payment for specific services or influence the objectivity of the decision-making process.


  5. Fairness at Work and No Discrimination policy

    EISA opposes any form of harassment, bullying or other conduct that may be perceived as degrading, and is vehemently against any discrimination, treatment or action that is contrary to the principles of tolerance. Gender, age, social status, nationality, sexual orientation, ethnic origin, religious and political beliefs, marital status and health cannot be grounds for discrimination and restriction of professional activity. EISA provides equal opportunities for the development and growth of its staff regardless of the above factors and strives to provide a comfortable working environment for all Representatives.


  6. Health and Safety

    EISA takes all necessary measures in order to provide its Representatives with a safe and healthy work environment. Each Representative in turn, is required to follow all applicable safety and health rules, regulations and laws and by reporting accidents, injuries and unsafe equipment, practices or conditions.


  7. Drugs and alcohol

    Possession or use of any substance prohibited by law is not tolerated in the workplace, during the execution of our agency services or in any other context while representing EISA. Consumption of alcohol in the workplace is not allowed. Outside of the workplace and in the framework of business meetings, alcohol consumption is allowed when it is objectively acceptable, and in such cases it must be consumed in moderate amounts and in accordance with local customs and applicable laws.


  8. Confidential Information & Data Protection

    Our cooperation with business partners and clients is carried out in accordance with the rules of information protection, including the protection of personal data, confidentiality and trade secrets. We always ensure full compliance with laws and regulations regarding the protection of confidential information, and all Representatives are required to adhere to the highest standards regarding such protection.


  9. Protection of the Environment

    EISA and all Representatives always strive to contribute to the continuous improvement of environmental protection. EISA applies a zero-tolerance policy to any violation of local or national environmental norms, regulations or laws.


  10. Documents

    All documents of EISA, including those formalizing relations with customers, business partners, government authorities, competitors and employees of EISA, are developed and approved taking into account the provisions of this Code.


  11. Relationships between employees

    The relationship between the employees of EISA, regardless of the position or field of activity, is based on the principles of mutual respect and mutual assistance, openness and goodwill, teamwork and a focus on cooperation. Any form of disparaging or offensive attitude towards each other is unacceptable.


  12. Relationships between managers and subordinates

    The relationship between managers and subordinates is based on the principles of openness of management in relation to employees, with managers providing equal opportunities to all their subordinates to fulfill their duties, supporting the initiative of subordinates, understanding the specifics of their work and sharing responsibility for the results, ensuring impartiality and fair assessment of the results of the work of subordinates.
    The relationship between subordinates and managers is based on the principles of respect, discipline and observance of subordination, the conscientious performance of both their direct job duties and other management tasks that are not described in job descriptions, but directly related to the scope and specifics of the activities of EISA.


  13. Use of resources of EISA

    Employees are obliged to treat property and other resources provided by EISA as carefully as possible and use them exclusively for business purposes.