Principles of fair commercial practices

In relations with partners and suppliers of goods or services, ALTUM complies with the following principles:

• orders are placed and contracts with suppliers of goods or services are concluded on the basis of objective criteria and without giving any of them direct or indirect advantages
• if an employee involved in a transaction related to the purchase or delivery of goods or services for ALTUM’s needs knows that his or her spouse or close relative works for the supplier or is otherwise interested in the transaction, then the employee shall refrain from making a decision or voting on the purchase or delivery of the aforementioned goods or services to ALTUM
• an employee who is involved in a transaction related to the purchase or delivery of goods or services for ALTUM’s needs, or other similar transactions and who has a direct or indirect, financial or other interest that may give rise to a real or apparent conflict of interest with the interests of ALTUM, shall refrain from making decisions or voting on the purchase of the aforementioned goods or services for ALTUM

ALTUM cooperates with partners, suppliers, and other contractual partners who support fair cooperation and are committed to preventing corruption and fraud in their activities.

ALTUM contractual partners, including their subcontractors, are encouraged to organize their work and cooperate with ALTUM in the following ways:

• comply with fair competition rules and not create situations in which competitive advantages may arise for the partner itself or other natural and legal persons associated with the partner
• prevent conflicts of interest in mutual cooperation
• prevent fraudulent activities or misappropriation
• prevent the legalization of criminally obtained funds. Upon learning of such activities, ALTUM shall immediately terminate cooperation or contractual relations
• prevent corrupt practices, including respecting ALTUM’s restrictions on accepting gifts and not offering ALTUM employees material valuables as incentives or rewards
• comply with labor law requirements
• comply with legal requirements regarding the payment of taxes and similar charges
• operate in accordance with environmental and occupational safety regulations

ALTUM does not cooperate with contractual partners who have been found guilty of or subjected to coercive measures in relation to criminal offenses such as:

• establishing, leading, participating in, or being a member of a criminal organization, or an organized group that is part of such an organization, or other criminal formation, or participating in criminal offenses committed by such an organization
• terrorism, financing of terrorism, incitement to terrorism, terrorist threats, or recruitment and training of persons to commit terrorist acts
• human trafficking

ALTUM does not cooperate with contractual partners who are subject to international or national sanctions or sanctions imposed by a member state of the European Union or the North Atlantic Treaty Organization that significantly affect financial and capital market interests and may affect the performance of the cooperation agreement.

In order to promote fair, reliable, and successful cooperation, ALTUM encourages its contractual partners to provide confirmation of the terms and conditions of the cooperation agreement, confirming that:

• the price of the proposal submitted within the procurement procedure and the price during the performance of the contract include and will include all possible costs related to the performance of the service
• the contractual partner has the necessary professional, technical, and organizational capabilities, personnel, financial resources, equipment, and other physical infrastructure and resources necessary to fulfill the potential contractual obligations