Compliance Policy of AMECO MMC

 

In accordance with Azerbaijani legislation, AMECO MMC (hereafter the "Company") has adopted the following Compliance Policy.

The Compliance Policy purpose is to promote honest, ethical conduct and to ensure compliance with laws, regulations, rules and professional standards.

Employees at all levels must carry out diligently, efficiently and to the best of their abilities the responsibilities entrusted to them. They must act with loyalty to the Company where the legitimate interest of the clients shall prevail, and must act honestly, independently, impartially, with discretion and without regard to self-interest.

 

1. SCOPE

 

This policy approved by the Executive Director of the Company and applies to all employees without restriction and all service providers acting for or on behalf of the Company (hereafter the "employees").

 

2. POLICY STATEMENT

 

I. Compliance Function

 

The Executive Director of the Company puts in place a Compliance function to monitor the implementation of the Compliance policy and to ensure that it is followed. The ways in which the Compliance function operates and the limits of its scope will develop over time depend on the status, organisation and risks inherent in the Company's activities.

 

The Compliance function shall act independently and in particular:

 

   a) Ensure compliance with all relevant laws, regulations, rules and professional standards;

 

   b) Assist senior management in ensuring the adherence to ethical rules;

 

   c) Identify and assess the compliance risks as described below;

 

   d) Assist senior management in the management and control of such risks;

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   e) Report directly to senior management on material issues and Inform and educate staff.

 

II. Compliance Risks

 

The Compliance policy is constituted of all measures, actions and options decided in order to limit risks to an acceptable level in pursue of the Company's objectives.

 

The main Compliance risks are identified as follow:

 

Risk of breach of ethical rules

 

This refers to the risk of breach of ethical rules by the Company or its employees.

 

Legal and regulatory risks

 

This refers to the risk of non-compliance with applicable laws, regulations, and professional practices. This include:

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Litigation risk: risk linked to the outcome of legal action

Contract/transaction risk: risk linked to misinterpretation or non-application of legal rules relevant to a contract or a transaction

Legislative risk: risk linked to changes in law and regulations.

 

Risk of sanctions

 

This consists of: risk of judiciary, administrative or disciplinary sanctions, as a result of non-compliance with laws, regulations, rules, norms and/or contractual agreements.

 

Reputation risk

 

This refers to: risk of damage due to the Company's diminished worthiness and impaired reputation, resulting from true or false adverse publicity, failures in business practices and failures to comply with current laws and regulations.

 

 

III. Compliance Principles

 

Employees are required to apply and respect the following principles:

 

Engage in and promote business and professional ethical conduct

 

Employees are required to carry out their professional duties in line with a "good citizen's behavior" and to respect the Company's ethics including the respect of all individuals.

The Company shall not seek advantage through illegal or unethical business practices. Indeed, all employees are expected to exhibit the Company 's shared value of integrity. The Company Management have ultimate responsibility for setting the direction and tone of the Company 's policies and practices in line with this shared value of integrity.

Employees shall carry out their responsibilities honestly, in good faith and with integrity, as well as behave with due care, competence, prudence and diligence, exercising their best independent judgment at all times.

 

Comply with laws, regulations, rules and professional standards:

 

The Company commits to keep the employees up to date on applicable laws, regulations, rules, professional standards and the Siemens Business Conduct Guidelines. To meet this requirement, the Compliance function will be in future in charge of organising adequate training on a regular basis.

Any violation of laws, regulations, rules or professional standards are to be reported immediately to the Compliance function, when it is finally established.

 

Avoid any conflicts of interest:

 

Employees are required to avoid any conflicting interest in the course of their work. Whenever they participate in or are involved in the Company's decision making relating to its business, employees shall act in the best interest of the Company only, without giving any preference to third parties on the basis of personal considerations.

The Executive Director of the Company ensures that a strict segregation of functions is respected and that the necessary measures are taken to safeguard the separation between own account transactions and those for third parties.

In order to avoid the unlawful transmission of inside information, employees are reminded of their obligation to respect "Chinese walls" as defined by the senior management. They shall conduct their business affairs in a manner that ensures their private or personal interests do not interfere with the interests of the Company including conflicts relative to personal, financial, or other gain.

 

Take all reasonable measures to protect confidentiality:

 

In the course of their function within the Company, employees often receive confidential information about the Company, its clients, its suppliers and shareholders. Employees must maintain the confidentiality of all information so entrusted to them within the safeguard defined by senior management, except when disclosure is authorized or required by law.

Confidential or proprietary information of the Company includes any non-public information the disclosure of which would be detrimental to the Company or its shareholders or useful to its competitors.

Employees who leave the Company are under the ongoing obligation to keep such information confidential.

 

Protect the Client's best interests:

 

Employees shall provide their services to meet the clients' best interests. The Company always owes its clients a duty of care, honesty and trust.

Employees shall be free of any influence, interest or relationship in respect of the clients' affairs, which impairs or risks to impair their professional judgment and objectivity.

In carrying out their responsibilities to the Company, employees shall act fairly with the Company's clients, service providers, suppliers, competitors and any other shareholders and shall avoid taking unfair advantage of anyone through manipulation, concealment, privileged information or any unfair dealing practice.

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We fully accept and support the Compliance System of Siemens Healthineers.