INTRODUCTION

This Code was developed by the group of companies «AVRORA» (hereinafter – – – – – Company») in order to define the basic principles of interaction between the Company and its business partners (hereinafter – – – – Partner»).
The Company's mission is to improve people's everyday lives by making products for the home and soul more accessible. We achieve our mission by constantly searching for the best offers from partners, dynamically working on optimizing internal processes, updating and expanding the assortment, analyzing the current demand for products, price segment, seasonality, preferences and wishes of our customers.

The Code is based on the Company's corporate values:

#be_open_to_the_new

We – a team that always finds unconventional solutions and new opportunities to become even better every day. Openness to change – the door to the future.

#lead_in_efficiency

Our success is based on continuous improvement of all processes and cost reduction, thanks to the implementation of LEAN.

#interact_for_dreams

Unity is our main strength, because success – is not the work of one person. The most important thing is that we respect each other's dreams and work together to help achieve them.

#create_your_world

Each person has personal dreams and ambitions. Our Company provides everyone with the opportunity to use their imagination, creativity and talents to change the world for the better.

#take_responsibility_get_opportunity

Taking responsibility – is the desire to do more and better, because you want special achievements. We create a fair environment and receive opportunities for growth and development.

#give_kindly_freely

We have kind hearts that are able to give love and make the world a better place by doing good deeds without expecting a reward.

Our goal is to cooperate only with those who share our values and principles, which are the basis of this Code. In order to ensure this in real life, the Company voluntarily undertakes the obligation to support our partners, including provide consultations, conduct trainings, help implement LEAN management, promote their projects and growth. 

WHO CAN BECOME OUR PARTNER?

Our partner can be anyone who:

1. has an impeccable business reputation,
2. maintains the highest level of customer orientation and flexibility,
3. provides favorable conditions,
4. develops its own business in compliance with the quality standards of the relevant industry,
5. conducts business ethically and is ready to provide mutual guarantees regarding joint counteraction to fraud and corruption, avoids any attempts to improperly influence employees, partners related to the AURORA group of companies, their  actions or decisions by transferring improper benefits or material assets,
6. shares the principles and values specified in this Code,
7. does not allow any manifestations of unfair competition, as well as violations of the rules of business conduct,
8. shows respect and restraint in relations with the Company, complies with applicable legislation, including rules on working conditions and safety, environmental standards, fair competition, prevention of corruption, and ensuring transparency in operations through a continuous accounting system. 

HOW TO BECOME OUR PARTNER?

• Go to the link: https://corporate.avrora.ua/for-partners/
• Leave your application on the website by selecting a potential industry cooperation.

PARTNERS SELECTION PROCEDURE

After submitting the application, it is checked in accordance with the Company's internal regulations and policies. 
In any case, we will provide feedback.

PRINCIPLES OF INTERACTION WITH PARTNERS

• Rational use of natural resources and ecology

We hope that everyone will make their contribution to environmental protection:  optimize the consumption of raw materials and energy, reduce the use of natural resources; reduce emissions in the process of designing, manufacturing, distributing, using and disposing of their products, and minimize waste generation. Effective management of our shared natural resources, as well as methods of disposing of toxic waste and pollutants, are important targets in achieving this goal.  

• Interaction with public officials and prevention of corruption

We expect partners to cooperate with public authorities in accordance with the requirements of applicable law. In cases provided for by law, partners are obliged to immediately notify the relevant authorities of violations committed by an employee or partner.

• Compliance of documentation and reporting with current legislation

The partner's financial reporting and accounting documentation must comply with the norms and standards established by law. All accounting documentation must be complete and accurate; accounting documents must be clear, understandable and correctly reflect economic activity in accounting systems. 

• Support for Ukrainian manufacturers

The global economy is becoming increasingly interconnected, so our company strives to build its own business ecosystem, creating additional opportunities that change the business climate and increase business excellence and competitiveness of Ukrainian businesses. Joint growth with our partners — this is our priority.

• Compliance of the quality of goods and services with established standards

We give preference to partners who can ensure the supply of goods and services of the highest quality. 
Our Company works with partners who, upon request, provide all necessary documentation and allow representatives of the Company to enter their production facilities in order to conduct an audit and verify compliance with high standards of quality and business ethics.

• Prevention of bribery and corruption

The Company and its partners must comply with laws on combating corruption, money laundering, providing or receiving illegal benefits, fraud, legalization of criminal proceeds, financing of terrorism, including international anti-corruption standards and principles, preventing conflicts of interest specified in the Law of Ukraine "On Prevention corruption». 

• Risk Assessment

The Code establishes the need to assess the risk of interactions with potential or current counterparties. If there are serious reasonable grounds to believe that continuing interaction with a partner may harm the Company's reputation, this may serve as a basis for reviewing or terminating the relationship. Negative media mentions of a partner may also be considered a serious violation of these standards and may be grounds for termination of partnership relations.

• Sanctions Lists

The company and its partners are not on the following sanctions lists: NSDC (National Security and Defense Council of Ukraine) Sanctions, US Treasury Department Sanctions List (OFAC), Canada Sanctions List, EU Sanctions List, Australia Consolidated Sanctions List, UK Sanctions List, Japan Sanctions List against the Russian Federation in connection with events in Ukraine, US Department of Commerce Bureau of Industry and Security (BIS) Sanctions List, are not on the Unified State Register of Persons Who Committed Corruption or Corruption-Related Offenses, do not carry out any payment and/or trade transactions with countries and/or entities subject to restrictions and/or economic sanctions.
A Partner shall promptly notify the Company, to the extent permitted by law, of any claims, actions, prosecutions, proceedings or investigations into sanctions against his Company and key individuals.

• Tax Compliance

Business Partners shall not engage in or encourage others to engage in any conduct that may constitute fraudulent tax evasion or neglect to engage in such conduct. You are responsible for understanding and complying with any tax requirements and obligations applicable to your business with respect to any funds received from the Company. 

• Money Laundering

Business partners must not enter into any agreements with the aim of obtaining the proceeds of criminal activity and must oppose all forms of money laundering and take measures to prevent any activity directly or indirectly related to money laundering.

• Promoting objective decision-making by employees

The Company recognizes that it is common practice to offer business hospitality and occasional gifts to business partners. However, if they are offered frequently or are of high value, this may create the appearance of a conflict of interest or a bribe, or may actually be one. It is important that such gifts do not influence business decisions or create the impression that they may influence relationships and decisions.
Gifts and business hospitality are inappropriate if partners intend to create an obligation or interfere with objective decision-making. Partners may not directly or indirectly offer gifts, hospitality, or other benefits to our representatives or employees with the aim of influencing their decisions.
According to company policy, if we receive any value equivalent to more than 800 hryvnias, it is mandatory to transfer it to the company's balance sheet. In the future, such values are directed to charity.

• Corporate social responsibility

We try to contribute to making the world a better place by using our company's resources as efficiently as possible. We expect our partners to systematically approach issues of management in the field of social responsibility, contributing to the formation of a corporate culture that unites society.
The company encourages the active participation of employees and business partners in improving the quality of life of society, actively supporting and encouraging voluntary participation in such social activities.

• Ensuring compliance with human rights and preventing forced labor

We require that business partners respect and comply with human rights as set out in the UN Universal Declaration of Human Rights, do not allow violations of human rights, respect personal dignity, privacy and the rights of each person. Partners must not allow any unacceptable behavior or inappropriate treatment in society. This list includes: moral cruelty, physical violence, mistreatment of people with disabilities, modern slavery or sexual harassment, etc. 
Our Company has joined the UN Global Compact in Ukraine and has committed to taking its principles into account in its strategy, culture and daily activities, as well as to contribute to the achievement of the Sustainable Development Goals, among which the following are prioritized:

1. Goal 1. End poverty
2. Goal 5. Gender equality
3. Goal 7. Affordable and clean energy
4. Goal 8. Decent work and economic growth.
5. Goal 12. Responsible consumption and production.
6. Goal 17. Partnership for sustainable development.

We must ensure the above goals and ask our partners to be followers of our commitment.

• Workplace Safety and Health

We require business partners to care for the health of their employees and guarantee safe working conditions in accordance with international standards and applicable legislation. Health and safety requirements shall also apply to persons under the control of the partners, including employees and contractors working on the partner's premises. Partners shall:

1. take reasonable care for the health and safety of their employees and the safety of others who may be affected by their actions or inactions;
2. cooperate to ensure that the obligations and requirements relating to occupational health and safety are met;
3. follow occupational health and safety instructions and rules, including instructions on the safe use of equipment;
4. ensure that adequate attention is paid to occupational health and safety at all times and that they are personally responsible for the consequences of their own actions and inactions;
5. report promptly any problems, related to the safety of the working environment and health, including any potential risk, hazard or equipment malfunction, even in cases where it seems minor or trivial;
6. provide personnel with living conditions and amenities, including housing for employees if necessary, that are safe and meet the basic needs of employees;
7. adhere to the principle of conducting a barrier-free business and guarantee its support.

• Protection of confidential information and personal data

The company requires its partners to guarantee the protection of confidential information, personal data and other information, the dissemination of which could harm the company, its employees, partners, customers and consumers. Collect, process, use, transfer and store the specified information or data for the intended purpose within the framework of conducting business, in accordance with the requirements of the law and relevant international standards. 

• Adaptability

In our time, business reflects the need for companies to change and adapt to changes in the internal and external environment. This principle is becoming increasingly important in the context of rapid technological development, changes in consumer preferences, market competition and other factors.

• Observance of working hours and respect for personal space 

Partners must adhere to the established working hours of the Company (on weekdays from 08:00 to 17:00) and respect the personal time of its employees. Contacting company representatives outside of working hours, including telephone calls, personal visits or other forms of communication, is possible only in exceptional cases and by prior arrangement.  
Mutual respect for each other's time contributes to effective cooperation and maintaining productivity. 
The company, in turn, provides timely feedback within working hours and provides mechanisms for rapid communication in case of urgent issues. 
Violation of this principle may be considered a violation of the Code, which may be grounds for termination of cooperation. 

• Unacceptability of moral pressure and manipulation 

The company categorically does not accept any forms of moral pressure, manipulation or threats against its employees. Any attempts to influence the company's decisions, in particular through blackmail, ultimatums or demands to revise the essential terms of the contract on terms that are disadvantageous to the company, are considered unacceptable. 
If such actions are detected, the company reserves the right to: 

• Initiate an investigation; 
• Revise the terms of cooperation or refuse such cooperation with the partner.

In turn, the Company strives for a constructive dialogue with partners. All changes in the terms of the contract must occur exclusively by mutual consent of the parties based on the principle of partnership. 

EMERGENCY PREPAREDNESS

We pay special attention to preparedness for managing risks associated with emergencies and developing effective measures to ensure safety. We require our business partners to adhere to preparedness and response plans for such situations, health-related incidents, and other foreseeable force majeure circumstances.

MONITORING, AUDIT AND COMPLIANCE

The Company shall conduct periodic assessments of partners to verify their compliance with our internal policies.  This may involve collecting information by completing a questionnaire with additional information, on-site audits, interviewing the partner's subcontractors, checking provided product samples, production business processes, etc. 

The Company expects business partners to report suspected non-compliance with these standards set forth in this Code or other serious situations affecting its essential interests by e-mail: [email protected] or to the confidential line "Trust with confidence" by phone. 0 800 330 651. 
We respect everyone's right to anonymity, so you have the right to leave a message without indicating your name. We guarantee that we will immediately begin an internal investigation into these messages.
By familiarizing yourself with this Code, the partner confirms his/her obligation to comply with the above requirements when fulfilling contractual obligations.

In the event of a partner's failure to comply with this Code, the Company has the right to unilaterally terminate the legal relationship in accordance with the agreements concluded with the partner (in the event of unilateral termination of the agreements, the Company undertakes to pay for the goods already delivered or services provided).