Partner Code of Conduct

Partner Code of Conduct is a set of guidelines that outlines the ethical and legal standards that Akciju sabiedriba “ELKO Grupa” and its subsidiaries (hereinafter also referred to as “ELKO Group” or “ELKO”) expect from their business partners. The code is designed to promote honest and ethical conduct and ensure compliance with all applicable laws, rules and regulations in areas of labor practices, human rights, environmental protection, and anti-corruption measures.

In accordance with this Partner Code of Conduct, everyone associated with ELKO Group must comply with the standards set out in this code.

General Conditions

Partner Code of Conduct applies to all ELKO Group suppliers, distributors, wholesalers, resellers, sales agents and other business partners.

By signing this document, you confirm that you, as a cooperation partner of ELKO Group concern:
  • will work in accordance with the requirements set out in the Partner Code of Conduct;
  • agree to inform your employees, agents, representatives, subcontractors or other involved third parties of the aforementioned standards of the Partner Code of Conduct and to do your best to ensure that said persons and parties observe and comply with these standards;
  • allow ELKO Group or an independent auditor, in accordance with the agreement between ELKO Group and you as a cooperation partner, if there is reason to believe that the Partner Code of Conduct has been violated, to check compliance with the Partner Code of Conduct by implementing appropriate measures, such as audit, assessment, inspection, investigation and/or review measures. ELKO Group will provide prior written notice of the application of such measures unless there is an immediate threat and will implement such measures in a manner that will not affect your normal course of business. Both ELKO Group and you, as a cooperation partner, will pay your expenses related to such events.
As a partner, you acknowledge that adherence to the Partner Code of Conduct is critical to ELKO Group. Failure to comply with them will be considered a serious violation, as a result of which ELKO Group may review your suitability as a cooperation partner at the level of the entire ELKO Group concern.

ELKO Group itself is and expects its cooperation partners to be committed to responsible business and adhere to a number of international declarations, conventions and guidelines on human rights, labor rights and conditions, environmental responsibility and anti-corruption. These include:
  • The United Nations’ Universal Declaration of Human Rights
  • The Core Conventions of the International Labor Organization
  • The OECD Guidelines for Multinational Enterprises
  • The UN Guiding Principles on Business and Human Rights
  • The United Nations Global Compact Principles
  • Children’s Rights and Business Principles


Upholding human rights to all employees.

Aligned with the UN Guiding Principles on Business and Human Rights, Partner commits to respect human rights within its business operations. All employees shall be treated with respect and dignity and are entitled to fundamental human rights. In relation therewith, subject to applicable national laws and regulations which may require higher standards than those set forth below (in which case such standard shall apply):
Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not permitted.
Our internal policies and workplace practices are fully compliant with national and international labor laws that strictly prohibit child and forced labor.

Working hours
Working hours are not to exceed the maximum set by local law. All overtime must be voluntary.

Wages and Benefits
According to law (minimum wages, overtime, benefits requested by law). Outsourced labor in accordance with the law.

Provide all employees a living wage sufficient to meet the basic needs of employees and to provide some discretionary income, and when applicable, salary shall be based on criteria set by collective bargaining agreements.

To have a strict nondiscrimination policy established within the hiring process as well as everyday work situations. Everyone should be treated equally regardless of race, sex, gender identification, sexual orientation, national origin, native language, religion, age, disability, marital status, citizenship, genetic information, pregnancy, or any other characteristic protected by law.

Freedom of association
Recognize employees’ right to form freely and to join, or not to join, trade unions or similar employee representative organizations and to collective bargaining.

Not penalize, persecute, discriminate or harass employees when they join a trade union or act as employee representatives.

Maintain an effective and confidential grievance mechanism that facilitates open communication between management and workers, addresses concerns early, openly, and on an informed basis, and encourages employees to use grievance mechanisms without fear of punishment or retribution.

Health and Safety

Aligned with international Occupational Health and Safety standards, Partner commits to provide and maintain a safe and healthy workplace for its employees, visitors, contractors and any subcontractors working on its behalf. In relation therewith, subject to applicable national laws and regulations which may require higher standards than those set forth below (in which case such standard shall apply).

Health and safety hazards
Address workplace hazards and risks through sufficient and relevant control measures such as appropriate personal protective equipment, as well as prevention and protection devices.

Ensure that employees, visitors, contractors and any subcontractors working on Partner’s behalf have access without any charge to these safety measures and that they are sufficiently trained in how to use them.

Emergency training and awareness
Be able to identify and respond to potential emergency situations by having in place adequate and appropriate measures.

Regularly train employees on emergency planning responsiveness.

Workplace conditions
Aligned with international Occupational Health and Safety standards, Partner commits to provide and maintain a safe and healthy workplace for its employees, visitors, contractors and any subcontractors working on its behalf.


All required environmental permits (e.g. discharge monitoring), approvals, and registrations are to be obtained, maintained, and kept current, and their operational and reporting requirements are to be followed.
Chemicals, waste, and other materials posing a hazard to humans or the environment are to be identified, labeled and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal.
Participants shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
Partners shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assure that they are sourced in a way consistent with the Organization for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework.


Intellectual property rights are to be respected, transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and supplier information is to be safeguarded.
Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Participants are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
Determination towards fair operating practices includes but is not solely limited to upholding fair business, advertising and competition standards.
No form of extortion and bribery, including improper offers for payments to or from individuals performing work for ELKO Group, shall be tolerated. ELKO Group expects Partners to adhere to the highest standard of moral and ethical conduct, to respect local laws and not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

This document is valid as of 14th November 2023.
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