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Anti-corruption program TATRA

TATRA TRUCKS has decided to implement an anti-corruption program, whose goals are:

a) to minimize corruption risk in the business activities of TATRA TRUCKS,

b) work preventively against corruption risks inside the company while providing products and services for the company,

c) to set an example as a significant part of Czech industry on how to act in preventing corruption and unethical behaviour.

TATRA TRUCKS’ anti-corruption program consists of:

• the Code of Ethics of TATRA TRUCKS‘ employees with a special part dedicated to public contracts,
• the Ethics Line that can be used by anybody to report corruptive or unethical behaviour in regard to TATRA TRUCKS,
• a set of processes and measures designed to assess the corruption risks with respect to the company activities, groups of employees or specifics of individual markets where TATRA TRUCKS is present.

The anti-corruption program of TATRA TRUCKS is managed in cooperation with Czech branch of Transparency International and adheres to the requirements of the „Defence Companies Anti-Corruption Index“ project founded by the UK branch of Transparency International in the maximum extent possible.

TATRA TRUCK is the automotive company oriented at heavy duty high mobility trucks for construction, mining, or forestry. The minor part of the production is dedicated for the customers fro defense segment. Neverthless, to achieve maximum level of the anti corruption prevention has started as the first company in Czech Republic to work under the strčit compliance rules recommended by Transparency International and other non-gvernmental organizations for the area of defense programs.

TATRA TRUCKS’ CODE OF ETHICS

One of the key components of the TATRA TRUCKS‘ anti-corruption program is the Code of Ethics for the holding’s employees who are obliged to adhere to it. Some of its provisions also concern TATRA TRUCKS‘ partners, e.g. sales representatives and dealers. The TATRA TRUCKS‘ Code of Ethics is based on requirements of the UK-based Transparency International. The Codex includes:

• the ban of corruption
• the ban of conflicts of interest
• reporting of corruptive of unethical behaviour
• special duties of sales departments concerning fulfilling the anti-corruption program
• rules of sponsorship and donations to political parties and movements
• the commitment to spread the anti-corruption program beyond TATRA TRUCKS

TATRA TRUCKS‘ SPONSORING RULES

TATRA TRUCKS as a socially responsible company in the field of defence industry logically supports mainly non-profit activities in the regions of the member companies‘ residence. This can mean activities such as sport, cultural, educational or other events. Especially significant are educational events that support development of technical disciplines which bring major contributions to the national wealth of the Czech Republic, boost the national export potential and are chronically battling a lack of promising students.

The main rule in TATRA TRUCKS‘ sponsoring activities is that it must not be tied to any specific business opportunities in public nor private sector. Similarly, a sponsoring under the circumstances of conflict of interests is also forbidden. Sponsoring activities of TATRA TRUCKS are usually publicized either by a press release or by posting the information on the company‘s website or an internal magazine Tatrovak.

Support of Political Parties and Movements

The support of political parties and movements by TATRA TRUCKS must be transparent. This support must not be connected to any kind of business opportunity in public sector. TATRA TRUCKS strictly adheres to all legal obligations concerning any potential support of political parties.

GIFTS AND HOSPITALITY

TATRA TRUCKS is providing standard services for their partners in the context of building acceptable professional relationships including the possibility of covering the costs of accommodation during the partners’ stay and extending gifts and courtesies.

However, it is forbidden to provide a disproportionately luxurious accommodation, unethical and expensive entertainment of give gifts with a clearly unreasonable value. These actions are considered potentially corruptive in relation to TATRA TRUCKS‘ partners. Similarly, managers and employees of TATRA TRUCKS member companies, especially in their sales departments, are forbidden to accept such inappropriate services or luxurious gifts. In case such offers are extended by a partner, the employee is required to report this to their superior.

FACILITATION PAYMENTS

At some foreign markets, the state employees are allowed to legally require facilitation payments. I tis strictly forbidden for TATRA TRUCKS to provide these payments. The facilitation payments do not include business provisions for private sector partners, e.g. based on dealer agreements, licence agreements or sales representative contracts.

TATRA TRUCKS‘ INVOLVEMENT IN OFFSET PROGRAMS

While Czech legislation, in adherence to the European law, does not further enable Czech companies to participate in offset programs as a part of public contracts of Czech government and ministries, they can be required to fulfil offset programs when working in foreign environments. A typical requirement, even in democratic countries, can be the partial transfer of production, which can be perceived as a so-called direct offset. TATRA TRUCKS in cooperation with their foreign partners carries out the offset programs in strict accordance with national legislation, usually in order to fulfil the customer’s need to gain the capability of partial production and maintenance of the product. TATRA TRUCKS refuses and does not participate in offset programs whose aim is to submit contracts not coherent with their activities, which include a risk of corruption and could be abused in order to commit corruption. TATRA TRUCKS informs about the activities which can be perceived as direct offsets by standard means while communicating information about the original contract (the production transfer is possible only with the more significant and publicly controllable projects).

TATRA TRUCKS‘ ETHICAL LINE (ET-LINK)

To create a unified reporting channel for testimonies of unethical, corruptive, illegal, unsafe or environment-damaging behaviour, the TATRA TRUCKS has created the Ethics Line which can be used by anybody to report the above-mentioned problematic behaviour either in the form of

a) leaving a voice message at telephone number +420 733 678 454, or

b) sending a report to etlink@tatra.cz .

TATRA TRUCKS prefers that the reports are not anonymous as such reports themselves pose a risk of unethical behaviour and abuse of the Ethics Line. However, nobody can be forced to leave his name.

The receiver of all reports is the HR department of TATRA TRUCKS which in case the report has been submitted by e-mail acknowledges the message’s acceptance and informs the sender within 14 days about taken steps. After the report has been investigated, the sender is notified about the result.

TATRA TRUCKS declares that they value reasonable reports submitted to the Ethics Line. However, this does not apply to false reports with the aim to unjustly accuse another person or company. Such report itself is a breach of the Code of Ethics and TATRA TRUCKS‘ anti-corruption program with all associated consequences.