Ombrulla's Commitment to Ethical Business

This CODE OF ETHICS AND BUSINESS CONDUCT of Ombrulla serves as our ethical commitment and as a guide to proper business conduct for all of our stakeholders. We, at Ombrulla, are committed to doing business legally, ethically, and in a transparent manner.

This document applies to all staff who work for the Ombrulla (including officers, directors, managers, team leaders, employees, temporary, agency, interim, subcontractor, or consultant staff), and also includes other organisations that do business with us. Ombrulla expects its staff to be impartial and honest in all affairs relating to their job. All staff bear a responsibility in general to be of good faith and do nothing to destroy the trust necessary for employment.

The success of our business is based on the trust we earn from our employees, customers, and shareholders. We gain credibility by adhering to our commitment to fairness and reaching our goals solely through ethical conduct. All staff are expected to adhere to this code in their professional as well as personal conduct and treat everyone with respect, honesty, and fairness.

Ombrulla is open to any questions at any time and will not allow punishment or retaliation against anyone for reporting a misconduct in good faith.Managers and leaders have a higher responsibility for demonstrating, also through their actions, the importance of this code. Managers and leaders are responsible for promptly addressing every raised ethical question or concern. Employees must cooperate in investigations of potential or alleged misconduct.

Non-compliance with this code is considered misconduct that could warrant disciplinary action, including termination of employment or other contract in deserving cases.We are committed to making efforts to apply our values and norms also throughout the entire value chain of our own suppliers, subcontractors, service providers, and business partners.

At Ombrulla, our core values form the foundation of everything we do. We are driven by honesty and integrity, ensuring that trust is at the heart of our relationships. We believe in respect for others, fostering a culture where responsibility, accountability, and reliability are paramount. We uphold the highest standards by adhering to the law, striving to create a trustworthy environment for all.

At Ombrulla, ethical decision-making is at the heart of every action we take. We are committed to making choices that align with our core values of honesty, integrity, and responsibility. By fostering a culture of respect and accountability, we ensure that every decision benefits our clients, employees, and society while adhering to legal and moral standards.We strive to make decisions that respect our clients, employees, and the wider community, while upholding the highest legal and ethical standards.

At Ombrulla, our commitment to integrity starts with adherence to laws, rules, and regulations. We ensure compliance with all legal requirements and commercial practices relevant to lawful business operations. This includes abiding by the GDPR for data protection, ISO standards for quality management, and any other industry-specific regulations. We are dedicated to honouring every valid and binding contractual agreement and do not misuse our rights. Our staff is required to follow all applicable laws and regulations, including our internal Code of Conduct, to guarantee compliant and ethical operations at all times.

We are committed to meeting current requirements without compromising the needs of future generations. To this end, we combine economic, environmental, and social factors in our operation and our business decisions.

We are committed to respecting the human dignity and rights of each individual and community whom we interact with during the course of work. We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect, and care and uphold human rights.

We are committed to respecting the human dignity and rights of each individual and community whom we interact with during the course of work. We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect, and care and uphold human rights.

We provide equal opportunity in employment, and we do not tolerate any discrimination, harassment, or any type of abuse. No direct or indirect discrimination shall take place based on any professionally non-relevant trait or circumstance, like gender, marital status, age, national or social or ethnic origin, colour, religion and political opinion, disability, sexual orientation, employee representation, property, birth, or other status. Any kind of discriminatory behaviour, harassment, bullying, or victimisation is prohibited. 

All staff are expected to follow the highest standards of conduct in all verbal and written communication based on mutual respect and must refrain from any form of harassment, slander, or any behaviour that could be taken as offensive, intimidating, humiliating, malicious, or insulting.

We provide clean, safe, and healthy work conditions, and we are dedicated to maintaining a healthy environment. We are committed to minimising the impact on the natural environment of our operations. We make efforts to reduce the use of finite resources, like energy or water, and the harmful emissions, like waste.All staff must follow and comply with every relevant health, safety, and environmental protection law, regulation, and rule at all times.

Our relationships with business partners are built upon trust and mutual benefits compliant with competition law. We are dedicated to ethical and fair competition, as we sell products and services based on their quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities, nor will we engage in or assist in unlawful boycotts of particular customers. We commit to complying with all applicable trade controls, restrictions, sanctions, and import-export embargoes.We do not allow any violence of the fairness of any tendering process in any way. We refrain from damaging competition and the reputation of any business partners and any behaviour that harms a competitor's credibility. 

We do not hold back maliciously, unlawfully, or unduly payments towards our partners, and we do not allow such practices in our supply chain. We fight the unethical practice of “debt chain.” Our staff is responsible for ensuring fair business during their job and adhering to every competition, consumer protection, and fair marketing rule. Customers and business partners shall be treated fairly and equally, products and services shall be displayed in a manner that is fair and accurate (fair marketing and advertising), and that discloses all relevant information.

We firmly condemn and do not tolerate all forms of corruption. It is prohibited directly or indirectly offering, promising, giving, asking, soliciting, or accepting any unfair advantage or benefit in order to obtain, retain, or facilitate in any way the business. An unfair advantage or benefit may include cash, any cash equivalent (e.g., voucher), gift, credit, discount, travel, personal advantage, accommodation, or services.

We do not permit facilitation (or “grease”) payments to government officials or private businesses in order to secure or speed up routine actions. Corruption also covers the misuse of function or position as well, when someone makes that false appearance that s/he improperly influences a decision maker. Corruption for either to obtain or retain business or to obtain or retain an advantage in the conduct of business is considered gross misconduct. Similarly, accepting or allowing another person to accept a bribe is considered gross misconduct. Our staff has to account for all benefits received in the course of doing business and must not give or receive bribes or otherwise act corruptly.

We shall avoid any actions that create a perception that favourable treatment was sought, received, or given in exchange for personal benefits.Business courtesies or benefits include gifts, gratuities, meals, refreshments, entertainment, or other advantages from persons or companies with whom we do or may do business. We will neither give nor accept such benefits that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation, or policies or would cause embarrassment. Our staff may never use personal funds or resources to do something that cannot be done with our resources.

We may accept and offer occasional gifts and hospitality that are customary and conform to reasonable ethical practices of the market, provided that they are not inappropriately excessive, not frequent, and do not reflect a pattern of frequent acceptance, which does not create the appearance of an attempt to influence business decisions. Only trivial gifts with low value can be accepted. All other gifts must be politely refused or, if received through post, returned to the donor. If return is not possible, it shall be offered for charity or community purposes. It is the responsibility of the person offering, providing, receiving, or accepting the gift to decide whether the gift is appropriate.

We are responsible for the security, protection, and economic use of company resources. Our resources, including time, material, equipment, and information, are provided for legitimate business use only. Occasional personal use is permissible as long as it is lawful and does not affect job performance or disrupt workplace morale.All staff are obliged to follow appropriate security measures, and they should treat company property, whether material or intangible, with respect and shouldn’t misuse company assets or use them carelessly.

We are committed to business information confidentiality, integrity, and accessibility, we implement proper technical security measures for this, and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers, business partners if disclosed to unauthorised parties. All staff must handle any such information as secret. 

It also covers that, no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have an impact on the securities. Every rule ensuring information security must be followed at all times.

We respect the property rights of others. We will not acquire or seek to acquire trade secrets or other proprietary or confidential information by improper means. We will not engage in unauthorised use, copying, distribution, or alteration of software or other protected intellectual property.

Our books, records, accounts, and financial statements must be maintained in appropriate detail and must truly and properly reflect our transactions. We condemn all forms of money laundering, so we are committed to doing business with partners involved in legitimate business activities with funds derived from legitimate sources. We commit ourselves to fair taxation and to avoid all tax evasion practices, including failing to issue receipts or accounting for fake expense invoices.

All staff must follow accounting procedures, ensure that business transactions are recorded and documented appropriately, and make certain that all disclosures made in financial reports are full, honest, accurate, timely, and understandable. All staff must not improperly influence, manipulate, or mislead any audit.

Fraud—the act or intent to cheat, steal, deceive, or lie—is both unethical and, in most cases, criminal. Fraud in every form (including, e.g., submitting false expense reports; forging or altering financial documents or certifications; misappropriation of assets or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

Our decisions shall be based on objective and fair assessments, avoiding the possibility of any improper influence. A "conflict of interest" exists when an employee's personal interest (that can be linked to e.g., friends, family, or customer, competitor, supplier, contractor entity, as well) interferes or potentially interferes with the best interests of Ombrulla. Determining whether a conflict of interest exists is not always easy to do; thus, anyone with a conflict of interest question should seek advice from management.

If co-workers become involved in personal relations with each other, the onus is on the senior employee concerned to bring this to the attention of his or her manager to confirm that there is no conflict of interest, nor will a conflict of interest arise.

We respect people's privacy, and we acknowledge customers, employees, and other natural persons' need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to complying with all personal data protection laws. We only acquire and keep personal information that is necessary, and we give proper information on these activities to data owners.

We implement proper security measures to assure confidentiality, integrity, and availability of personal information.Our staff must observe the legal requirements, apply compliant practices, and follow related procedures to ensure the legality of personal data handling and processing activities.

If you have any questions or concerns regarding the Code, its requirements, or the way it is being applied or applies, please consult with our Legal Department: