3E Group Code of Ethics
The purpose of the Code of Ethics is to define the standards of ethical conduct, entitlements and obligations of the employees and other contractors of the 3E Group (hereinafter referred to as the 3E Group or the Company(s)), which contribute to the preservation of the professional and institutional integrity of the Companies, to the strengthening of workplace relations and standards, and to the creation of an atmosphere supporting high quality professional work. The Code of Ethics is also intended to provide guidance on issues that are not covered by normative rules but are necessary for the proper operation of the Company and the performance of its daily tasks.
In the long term, the 3E Group can only meet the challenges of a competitive market if the requirements of moral responsibility are applied at both individual and company level. The Group’s reputation can be preserved through integrity in business conduct and full compliance with the law.
I. Scope of the Code of Ethics
This Code of Ethics applies to all employees of the 3E Group (3E International Kft., 3E Construction Management Kft., 3E BIM Kft., Investech Hungary Kft.) and to all employees in other employment relationships. The Code must be complied with in the course of employment and in the course of external and internal relations related thereto, and in addition, in accordance with the provisions of the Labour Code on general requirements of conduct, also in the course of conduct outside working hours, if it is likely to jeopardise the reputation of the 3E Group, its legitimate economic interests or the purpose of the employment relationship.
II. Practical application of the Code of Ethics
Persons covered by the Code must pay close attention to the legal requirements relating to their professional practice.
Even in the absence of legal provisions, socially acceptable rules, generally accepted standards of behaviour, common sense and professionalism must be applied, and the consequences of behaviour and actions must be considered.
III. Basic ethical standards
For activities not covered by legal requirements, the following ethical and moral standards apply.
- Quality and safety
The Company is committed to providing a quality engineering service, and the work we do corresponds to:
- professional requirements,
- contractual obligations,
- relevant industry legislation and regulations;
and in the course of the work we do
- comply with safety requirements, injury and disease prevention regulations,
- use a high-quality and extensive knowledge base.
Our aim is to provide high quality engineering services for construction projects, using state-of-the-art technical and technological equipment, in accordance with the quality management system in force.
- Fair competition
We value fair and open competition and comply with all relevant antitrust and competition laws. We do not engage in practices that are contrary to fair competition or that provide an improper competitive advantage. This includes any agreements, whether formal or informal, written or oral, to fix prices, to bid or set terms or conditions of bids or contracts, to allocate territories or markets, to boycott certain suppliers or customers, or to prevent another company from entering a market.
We will comply with EU and national competition and antitrust rules, avoid unlawful agreements by taking into account:
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- we refrain from fixing prices or other commercial terms,
- we do not limit production,
- we do not divide the market with competitors,
- we do not disclose strategic information about the company.
Our Group also refrains from abusing its dominant position:
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- does not set unreasonably high prices, abusing consumer demand,
- does not set irrationally low prices to drive competitors out of the market,
- does not discriminate among customers,
- does not impose certain commercial conditions on its business partners.
We strive for a fair and stable cooperation with our partners, based on mutual interests, and we wish to provide our products and services at a reliable and high level.
- Anti-corruption policies
3.1. Bribery
Bribery under the Criminal Code (soliciting an unlawful advantage in connection with an activity for or on behalf of a business organisation) or accepting a bribe (accepting an unlawful advantage or a promise to do so) is prohibited.
The 3E Group rejects all forms of corruption. All employees are expected to think and act in this way and to comply with the following guidelines in the course of their work:
3.2. Material assets
It is forbidden to offer or give anything of value to a person who is able to influence a matter or transaction in order to induce that person to breach his or her duties, to perform his or her tasks in a biased manner or to give an unlawful advantage to another person. It is also forbidden to accept anything from anyone in return for the employee’s breach of duty, the dishonest performance of his or her duties or the provision of an improper advantage to others.
3.3. Hospitality
The provision or acceptance of business hospitality in excess of the usual level is not permitted.
3.4. Gift
Care must be taken when giving or receiving gifts to or from a public official, municipal official, business partner or private individual. The gift given should be of a nominal amount and should be branded with the company logo, and the gift received should be reported to the supervisor.
- Treatment of employees
In its dealings with its employees, the Companies strive for fair, legal and honest relations. Companies expect the same conduct from its employees.
The assessment of employees (in matters relating to the employment relationship, wage or bonus setting, promotion, etc.) must be based solely on the work done and its value to the company, on the employee’s performance.
- Sustainability
Companies are managed in accordance with the principle of sustainability, i.e. they operate in a way that takes into account not only profit but also other considerations, such as social and the environmental aspects. We strive to reduce our energy consumption and emissions.
In the spirit of the above, the company’s management pays special attention to the harmonisation of economic performance, environmental protection and social responsibility, and expects its employees to apply sustainability principles in their activities.
In the exercise of his profession, the engineer should consider the reasonable protection of the built and natural environment as his most important task.
- Prohibition of discrimination and violence
The 3E Group strives to provide a working environment in which all individuals are treated equally, with dignity and respect, free from discrimination on the basis of age, religion, disability, race, colour, ethnicity, national origin, gender identity, sexual orientation or any other characteristic protected by law. Discrimination or harassment based on any of the above or any other category is strictly prohibited.
All employees have an equal chance to develop their talents and to advance within the organisation. The Companies will treat colleagues and applicants for employment with fairness, equity, without prejudice or bias.
All employment decisions, including those relating to recruitment, selection, recruitment, training, assignment, promotion, transfer and termination, must be based on professional competence and merit.
We respect the requirement of equal treatment in the employment relationship, in particular in relation to remuneration.
We do not tolerate any form of physical violence, verbal abuse, intimidation, humiliation or harassment.
- Conflict of interest
All internal stakeholders representing the Group or the Company have a duty to consider what is best for the Group or the Company when making business decisions; personal preference should not be taken into account. Conflicts of personal and corporate interest must be avoided.
This includes external activities or interests that may negatively affect work performance or the ability to make unbiased business decisions.
Conflicts of interest are:
- actual conflicts (the personal interests of the employee or other person in the employment relationship are in actual conflict with the interests of the Group or the Company),
- potential conflicts (the employee or other person in an employment relationship is or may be in a situation that could give rise to a conflict),
- perceived or apparent conflicts (a worker or other person in an employment relationship is in a situation that may be or appear to be a conflict, even if the conflict does not actually exist).
Incompatibility can also be caused by maintaining relationships, including spousal and other relationships.
Group employees are required to report the establishment and/or maintenance of a relationship (to their line manager and HR):
- where the relationship is between workers who are subordinate to each other, this may be a reason for the employer to terminate the subordinate relationship between the workers concerned by transfer or reorganisation
- if the members of the couple are employees or employees who work for or represent an external partner of the Group or are in a managerial position at a competing employer, the Management Board shall examine the situation and decide whether and how to resolve the conflict of interest.
- Public authorities and press relations
The 3E Group strives for consistent communication. To this end, and to ensure that the information shared about the 3E Group is accurate and complete, only designated persons are allowed to communicate with public authorities, external partners and members of the press. No person other than the designated managers may make public statements on behalf of the 3E Group or any of its members unless authorised to do so.
- Our business partners
Fair business conduct towards our business partners contributes to our business success. The consideration paid to business partners must be proportionate to the service provided, and payments must be duly justified, approved, recorded and disbursed by bank transfer in accordance with the contract in force. Documenting contractual obligations ensures compliance with business and ethical standards.
- Protection of ownership interests
All employees of the Companies have a fundamental duty to act within the framework of legal, ethical rules and standards to:
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- increase the profitability of the business,
- strengthen the long-term competitiveness of the business.
The company expects its employees to:
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- protect and effectively use the assets of the business,
- strive to make efficient use of working time, complete the tasks assigned to them as quickly as possible, and comply with quality, hygiene, health and safety and other regulations in force,
- strive for sensible savings,
- the assets of the business are not used for private purposes.
- Confidential information, data management
11.1. Confidential information
Persons covered by the Code of Ethics are obliged to treat as confidential any data or information relating to the activities of the 3E Group, whether relating to employees, subcontractors, customers or business partners of the Group, of which they become aware in the course of their work.
Confidential information may not be disclosed to third parties without the authorisation of the Management Board, i.e. the directors and managers as defined in the respective organisation chart. To maintain the security of confidential information, data security and information technology policies must be followed, such as those relating to passwords, mobile devices, data backup, network and computer access, and remote access. Employees are responsible for the secure storage, transmission and destruction of data in accordance with these policies. 3E Group proprietary materials may not be saved on a personal computer or device, personal email accounts may not be used to transmit 3E Group related accounts, confidential company information.
11.2. Confidential information concerning employees
The company will not collect, store or use information about its employees that is unlawful or unethical. The company will only collect, store or use information about its employees that is required by law or that is relevant to the effective operation of the company and does not conflict with the foregoing.
Employees’ personal data is considered confidential information and may only be used by authorised staff for official purposes. Any unauthorised access or use of employee data by others is prohibited and may result in legal action.
11.3. Data management, electronic data management
Information and data relating to the company, whether printed, electronically stored or oral, are the property of the company.
The employee must ensure the secure storage of data processed in connection with his/her job.
Upon termination of employment, the employee must provide the Company’s representative with all data and information previously held by him/her in relation to the company when the job is transferred.
Internet access provided by the 3E Group may be used by employees for work purposes in the interest of the 3E Group.
IV. Reporting ethical problems, questions and comments
Compliance with this Code is a management and individual responsibility. Violations of applicable laws or the published Code of Ethics and Business Conduct may result in a warning or, in the worst case, dismissal, depending on the seriousness of the violation.
The above measures apply to any manager who directs, approves or, if discovered, fails to take prompt action to remedy such acts.
If an employee has any ethical doubts, questions or comments about the assessment of a particular situation, he or she should contact his or her line manager, the Managing Director of the Company concerned or the Human Resources Manager. Reported cases will be investigated by the Management, with the involvement of the relevant department and Human Resources, and an investigation procedure will be initiated to clarify them.
The employee should not suffer any detriment as a result of reporting in good faith. If any employee becomes aware that he or she has been disadvantaged as a result of making an ethics report, he or she should inform the Executive Director, who will investigate the report and take the necessary action.
This Code of Ethics is effective from the date of signature, at which time the previously issued Code of Ethics will expire.
Budapest, 2023.01.02.