adopted on July 20, 2024,
valid from July 22, 2024
Introduction
This Code of Business Conduct for Suppliers of the Media Bot group of companies (hereinafter referred to as the "Code") contains the principles of work that all contractors, including consultants, agents, distributors, and other persons working for the company (or with the company) belonging to the group, undertake to adhere to Media Bot companies (hereinafter referred to as "suppliers"). Failure by suppliers to comply with these principles within the framework of our joint work may result in the inability to continue business relations with the Media Bot. In addition, all suppliers must familiarize their employees and subcontractors who will interact with the Media Bot with this Code.
The media bot adheres to the highest standards of business ethics. Therefore, this Code must be considered in inseparable connection with The rules of business and corporate ethics of the Media Bot Group of companies and The principles of the Media Bot, which the Media Bot undertakes to follow in order to be a reliable and conscientious partner for its suppliers. It is important for us to build mutually beneficial relations based on the principles of openness and mutual respect. We want to share views and intentions with our partners, including the intention to benefit society and take care of the environment.
The main thing about the Code
1. What is the basis of the principles of business behavior of suppliers?
The principles are based on the Rules of business and corporate ethics of the Media Bot. We expect our suppliers to behave as responsibly as we do ourselves and our employees.
The Code and Rules are based on the principles set out in applicable legislation and in international documents: Universal declaration of human rights, Guiding principles of entrepreneurship UN human rights activities, ILO Conventions, Principles of Global UN treaties.
2. What to do if the principles of the Code do not comply with the applicable
legislation?
If the Code contains stricter requirements, we and our suppliers are guided by the provisions of the Code. And if the applicable legislation sets out stricter requirements, we focus on it.
We have made sure that this Code can serve as a universal guide in most cases, taking into account the requirements of applicable legislation.
3. Will the Media bot check compliance with the Code?
We trust our partners, who confirm that they share the principles of business conduct set out in the Code, and are happy to get acquainted with their public reports. At the same time, the Media Bot reserves the right to implement verification procedures.
For example, a media bot can initiate an audit. At the same time, the audit itself, its scope and other details will be agreed in advance with the supplier.
We will also respond to reports of violations and verify their authenticity.
4. How can I report violations of the Code?
Our Hotline is available 24/7 via the link.... You can track the status of your application and see the decision made by the number that will be assigned to the application when it is registered in the system.
Key principles
1. Honest and conscientious doing business
Competition
Our supplier strives to maintain an open, honest commercial environment and comply with applicable antitrust laws. It does not allow unfair competition, does not conclude agreements that may infringe on the capabilities of other market players, including agreements with some of them, on the division of the market according to territorial principle, volume or assortment of goods, according to the composition of buyers and sellers, to the detriment of others. Our supplier must not use any immoral business practices and must choose between personal gain and the interests of society to give preference to the interests of society.
Anti-corruption
Corruption is a crime in all countries where the Media Bot is present. We strictly prohibit any form of corruption: bribes, bribes and other illegal payments to obtain or maintain advantages in business activities.
We choose contractors impartially: We take into account the competitiveness of the prices offered, the quality of goods or services and the reliability of future suppliers. We do not give or accept any illegal or inappropriate payments, gifts or services. We prohibit such actions, even if such payments are considered acceptable in certain regions of the Media Bot's presence. Our supplier should remember that local customs or practices do not justify committing a crime.
Our supplier, its affiliated companies, its employees, representatives and other persons involved in relations with the Media Bot should not offer, give, demand or accept money, valuable gifts, services or other payments in order to maintain business advantages or obtain a more favorable relationship.
If our supplier suspects that a violation of the provisions of this section has occurred or may occur, he is obliged to tell the Media Bot in writing about his suspicions. To do this, write to the following email:
Business gifts and hospitality signs
We expect that all gifts and hospitality that we receive from suppliers, and that our suppliers transmit and receive as part of a business relationship with a Media Bot, comply with the following principles:
· have a reasonable cost;
· does not create a conflict of interest;
· are legal;
· comply with local customs and business rules;
· do not make the recipient feel obligated;
· are not and do not give anyone a reason to consider them a bribe or commercial bribery;
· are not extorted by the recipient.
There are approval procedures in the Media Bot that we follow when giving or receiving gifts and hospitality tokens.
We categorically do not accept money and cash equivalents (certificates, e-money cards, etc.) from business partners, regardless of their nominal value.
More information about how gifts are accepted and given in the Media Bot, including limits, can be found in Rules of business and corporate ethics.
Conflict of interest
Our supplier, its affiliated companies, employees, representatives and other persons involved in relations with the Media Bot strive to avoid conflicts of interest in relation to the Media Bot.
By conflict of interest, we mean any circumstance that may cast doubt on the ability of the company's employees to act objectively in the interests of the employer and the transaction. Conflicts of interest include situations in which our supplier, its affiliates, employees, representatives, contractors and other persons involved in relations with the Media Bot:
· are close relatives of Media Bot employees who make decisions, participate in the conclusion or execution of contracts within the framework of relations with the supplier;
· are full-time Media Bot employees, work part-time or provide any services to Media Bot group companies;
· have a significant impact on the companies of the Media Bot group;
· are significantly influenced by the companies of the Media Bot group.
We also consider any situations in which the objectivity of making work decisions within the framework of interaction with a Media bot can be violated to be a conflict of interest.
If our supplier finds out about a possible conflict of interest situation, he is obliged to take measures to eliminate it and immediately notify the Media Bot about this situation in writing. To do this, write to the following email:
Money laundering
We expect our supplier to accurately document all business and commercial transactions and reflect them in accounting statements in accordance with applicable law. Moreover, our supplier should not participate in or facilitate money laundering.
Insider trading
Our supplier cannot use confidential information related to the Media Bot to participate in insider transactions. He undertakes not to share this information with other people who may use it to trade securities.
Privacy
Our supplier must consider confidential all business, technical, commercial and financial information about the Media Bot, its products, technologies and partners. The Supplier makes efforts to protect the confidential information of the Media Bot: it uses it only to fulfill obligations to the Media Bot, does not publish, transmit or disclose it to other persons without the permission of the Media Bot. In the process of working with the Media Bot, the supplier strives to prevent the misuse of confidential information of third parties, not to disclose or transfer it to the Media Bot without their permission.
Personal data protection
The media bot carefully protects the personal data of its users and others and treats them very carefully. Our supplier must comply with the legislation on personal data when collecting, storing, changing, using, transferring and other processing of personal data in the framework of cooperation with or in connection with a Media Bot. In particular, when processing personal data, our supplier must comply with the principles of legality, data security and confidentiality, fairness and transparency of processing, data minimization and data accuracy. It limits the purposes of processing and retention of personal data, as well as controls actions with data.
Intellectual property
The media bot respects the intellectual property rights of others and expects to be treated with respect for its intellectual property rights. Our supplier may not use the intellectual property of the Media Bot (including its software products, databases, proprietary solutions, trademarks, logos, documentation, etc.) without written permission. When working with a Media Bot, the supplier must not allow the misuse of third-party intellectual property.
Disclosure of information
We expect our supplier to adhere to the principle of transparency and strive to regularly inform stakeholders about the results of their work, including in the field of sustainable development. For example, in the format of public reporting. And if disclosure of information is not possible, then he will be ready to share data and materials at the request of the Media bot (in the case when there are no restrictions on the confidentiality of this information).
2. Respect for human rights and freedoms
Prohibition of child and forced labor
Our supplier does not use illegal child labor and employs only persons who have reached the legally permitted age for work.
Our supplier does not accept any forms and methods of forced labor and slavery, including but not limited to those defined in national legislation and applicable international documents (ILO Convention No. 29 On Forced and Compulsory Labour). The supplier strives to build relationships with employees based on the principles of voluntary agreements. He does not participate in or facilitate human trafficking, and also takes measures to exclude human trafficking within the framework of business relationships and facilitate the suppression of this activity by others.
Non-discrimination and support for diversity
The media bot considers discrimination in any form unacceptable, ensures equality of opportunity and recognizes the value of diversity. Our supplier must adhere to the same principles. He undertakes to comply with all applicable laws and strives to prevent discrimination in employment and in the course of work. It does not accept harassment and harassment on any basis, including nationality, gender, age, race, political or religious views, sexual orientation and other characteristics. Our supplier makes efforts to ensure equal opportunities for its employees and partners, encourages socio-cultural diversity and, if possible, strives to cooperate with enterprises of different sizes, with individual entrepreneurs and self-employed partners.
We believe that it is respect for each other and the desire for integration that contributes to the universal well-being and free comprehensive development of all members of society.
Prevention of harassment
Our supplier does not accept any form of sexual harassment — unwanted sexual acts against another person and strives to prevent such manifestations, if possible, if they appear in his field of vision.
Fair pay
Our supplier must comply with all applicable legal requirements regarding pay, benefits, payments and overtime pay. He strives to ensure timely and full fair pay, which guarantees a decent human existence for him and his family, and also strives to involve him in the work process so that he can approach his work with love and creative enthusiasm.
Respect for the right to rest
Our supplier must respect and ensure the legally enshrined right of its employees to rest. He undertakes to comply with the requirements of applicable legislation regarding working hours and overtime, as well as to measure the intensity of the work process and the fatigue of employees, their physical and mental condition.
Trade union freedoms
Our supplier recognizes and respects the right of its employees to freedom of association and collective bargaining. In addition, we strive to engage in dialogue with employees in every possible way.
Cooperative initiatives
Our supplier recognizes the natural desire of employees and/or partners for creative unification and the desire to take maximum responsibility for their lives, therefore, strive to support such initiatives in which people decide to unite in various forms of cooperation, either integration with other teams, or reorganization of production.
3. Ensuring occupational safety, health and safety
Organization of safe working conditions
Our supplier strives to provide working conditions that minimize health and safety risks. It maintains working equipment in good condition, conducts occupational safety training, informs employees about risk factors, responds to incidents and eliminates their consequences, maintains appropriate reporting and implements other measures to comply with legal requirements and improve working conditions.
4. Environmental responsibility
Compliance with environmental legislation
Our supplier must comply with applicable environmental laws, including with regard to hazardous materials, waste, and emissions of harmful substances into the air and water. Moreover, he should be guided by world experience and strive to adhere to stricter standards applied in world practice.
Rational use of resources
The media bot is attentive to its responsibilities in relation to environmental protection and strives to make rational use of natural resources. Our supplier shares the principles of rational consumption, tries to optimally use energy, water, raw materials and other resources and pays attention to the fight against climate change. And, as far as possible, prefers the use of such types of packaging materials that are less harmful to the environment.
Handling of hazardous materials
Our supplier should not use chemicals and materials dangerous to human health and the environment in technological processes, focusing on the lists of such substances fixed in applicable state standards and in agreements with the Media Bot. The supplier must ensure the proper handling, storage and disposal of hazardous materials, as well as the safety of employees and the environment.
Final provisions
We will regularly review the Provisions of the Code in order to integrate best practices and possible legislative changes into them.
Questions about the content of the Code can be sent to the following email address: