Compliance program

Code of ethics

To meet all customer requirements and modern times, we promote a professional approach, reliability, ability to provide a comprehensive range of services and responsibility.

The main intention of RT GLOBAL (hereinafter referred to as the "Company") is the domestic and foreign procurement of high-quality military technology – in this field we provide military vehicles, weapons and weapon systems throughout the world. A characteristic feature of foreign trade in military material is, in particular, the ability to secure supplies of individual pieces of technology, such as weapons, large-calibre weaponry, ammunition, bombs, missiles, tank technology, toxicology equipment, aircraft, helicopters and spare parts for the aforementioned technology as well as complex deliveries in relatively large quantities in the required quality, including sets of spare parts to ensure maintenance and repairs of the technology.Specific services are provided by RT GLOBAL also for museums and collectors of military technology, to whom it supplies military equipment that is disabled, in full compliance with the legal regulations of individual countries.

The result of the responsible approach of the company is adoption of an internal compact system of rules, procedures and regulations, the purpose of which is the compliance of the required behaviour of employees and other persons with fundamental human rights, general ethical values, morals, legal rule and internationally recognized standards. The Code of Ethics is a part of the aforementioned system and as such it applies to all employees of the Company, including members of the Company's bodies and external entities such as consultants, suppliers or agents representing the company (hereinafter the "Personnel").

RT GLOBAL does not tolerate at all any acts of its Personnel that could be considered illegal, corruptive, unethical, unfair or immoral. The Company considers such conduct as reprehensible and unacceptable within the set image of behaviour and conduct. 


BASIC ETHICAL AND MORAL VALUES, CORPORATE POLICY FUNDAMENTALS

1. All Personnel are obliged to comply with and respect the valid legal regulations, the Company's internal standards, and the provisions of this Code of Ethics.
2. All Personnel are obliged to proceed with diligence and conscientiousness in performing their work for the Company, and to act in a manner complying with ethical rules, good morals, moral principles and legal provisions.
3. In performing their job obligations, all Personnel shall approach the business partners, external entities, public authorities, media, colleagues, subordinates and supervisors in honest and professional manner, with esteem, dignity and respect.
4. No one is entitled to provide false, incomplete or inaccurate information when communicating with third parties. Everyone only communicates clear, complete and accurate facts, and does not abuse anyone's mistake.
5. Everyone is obliged to treat third parties with dignity and respect, in particular any form of discrimination or unequal treatment is strictly prohibited.
6. The Company provides training and education to support the professional development of the Personnel.
7. Managers are always obliged to properly present and observe the rules contained in the Company's internal documents. The individual Personnel should become role models for their subordinates, with ethical, moral, legal, anti-corruption and decent behaviour being their main priority and advantage. Managers are responsible for the behaviour of their subordinates and the condition of the worksite, at least to the extent that they have the obligation to control the compliance with the Company's rules.

CONFLICT OF INTERESTS AND PROHIBITION OF COMPETITION, COMPETITION RULES

  1. Loyalty, openness and communication with the Company are the cornerstones on which the attitude of every member of Personnel should stand.
  2. Personnel may engage in gainful activity in addition to their employment only on the condition that such activity does not interfere with the legitimate interests of the Company, and is performed in accordance with laws. In addition, a member of Personnel may only engage in a gainful activity in a competitive sector with the consent of the Company's statutory body.
  3. All Personnel are obliged to proceed in such a way to avoid situations where their personal or financial interests would conflict with the interests of the Company. Any potential benefit for the Personnel, persons close to the Personnel, or for close natural and legal persons with whom the personnel have personal, business or professional relationships is considered as a personal interest.
  4. During the employment relationship with the Company, no member of Personnel is entitled to acquire or hold a direct or indirect major share in another company (at least 15%), with which the Company conducts or may conduct business, or which is a competitor, unless the aforementioned has been approved by the statutory body of the Company.
  5. A conflict of interest also includes transfer or allowing transfer of any information and know-how that the Personnel have received in the course of their duties in the Company and that are capable of helping competitive activities of the others. Such conduct is considered as absolutely inadmissible and as a particularly serious breach of working duties.
  6. Without the prior written consent of the statutory body of the Company, no member of Personnel is entitled to negotiate or conclude on behalf of the Company any contracts or business relationships with business entities that are managed, controlled or owned by members of their family or legal entities that are financially or personally connected with the relatives or a cohabitee of the member of Personnel.
  7. The Company and all its Personnel shall comply with the economic competition rules, in particular they shall not perform any act that could be considered as an unfair competition; they always act fairly, professionally and transparently.

 

RELATIONS WITH THIRD PARTIES AND BRIBERY

 

  1. The Company and its Personnel are obliged to act in a manner not contradicting the law, particularly in such a manner that their conduct may not by characterised as a corrupt conduct. Corrupt conduct is, for example, accepting or offering a bribe, negotiating an advantage or any material or intangible reward in connection with the Company's business and performance of the Personnel's activities. Corrupt conduct also means offering any reward, benefit or profit to a public authority that could result in a misrepresentation, or issuance of a decision by the public authority in favour of the Company.
  2. Any illegal conduct or machinations in relation to public proceedings, public and private contracts and tenders, selection procedures, etc., such as lying, misleading, extortion, use of violence, fraudulent behaviour, etc., is prohibited.
  3. The Company and its Personnel are obliged to always provide true, complete and full information, especially record all financial transactions in connection with the Company's business in the bookkeeping so that a proper financial report may be elaborated for the competent governmental authorities.
  4. All Personnel are obliged to carefully manage and handle the Company's movable assets, including the entrusted assets, real estates, Company's trade secret and intellectual property.
  5. No member of Personnel is entitled to require or accept gifts, services, favours or benefits for themselves or for others, and is not authorized to provide any gifts, payments, rewards or services to a business partner of the Company, governmental body or any third party, except for such gifts of minimum nominal value, which represent promotional materials or promotional items or which mean a normal social courtesy not in conflict with the Company's business rules.
  6. The Company provides or may provide, where appropriate, monetary and in-kind donations for a certain purpose to finance science and education, research and development, culture, education, fire protection, youth support and protection, animal protection and their health, for social, medical, ecological, humanitarian, charitable, physical education, sports and political purposes etc.

 

CONFIDENTIALITY

 

  1. The Company maintains information security, protection of trade secret and personal data.
  2. The Company regularly assesses the risks relating to data and information protection, and takes measures that in their final consequence will prevent misuse, acquisition or dissemination of information by unauthorized persons. All Personnel are obliged to work with sensitive data and information in such a manner that there is no leakage or misuse.
  3. All Personnel shall maintain the confidentiality of all facts learned in connection with performing the working duties, which have or may the nature of business secret, confidential information, personal data or are subject to confidentiality. Trade secret primarily means all business, production or technical information relating to the Company's business that has actual or at least potential value. Confidential information includes, but is not limited to undisclosed information relating to the Company, its decisions, planning, financial transactions, inventions, development and technical schemes, technologies, designs, clients, customers, competitors, or any other information generally unknown in the industry that relates to the Company.
  4. Every member of Personnel who processes or otherwise handles any personal data in performing their duties is obliged to act in accordance with the law and regulations of the European Union.

OCCUPATIONAL SAFETY AND ENVIRONMENTAL PROTECTION

  1. The Company protects the health and life of the Personnel and property, maintains a healthy, safe and friendly working environment, and strives for its continuous improvement.
  2. All Personnel are obliged to pay maximum attention and to devote to the surroundings such due care and diligence to help create a safe and healthy working environment, and to take all measures to revert any imminent damage if there is a risk of bodily injury or damage to property or environment. If the Personnel are not in a position to revert the danger, they shall immediately warn their supervisors or other authorized persons who are able to prevent or at least mitigate the damage.
  3. All Personnel are obliged to follow all legal regulations, especially those concerning occupational safety, binding internal rules, procedures and policies of the Company, and to observe all occupational safety rules. At the same time, each member of Personnel is obliged to report to their supervisor or in accordance with this regulation, any violation of regulations concerning protection of health, property or environment, which such member of Personnel witnesses or learns of.
  4. The Company is committed to minimize the negative effects of business activities on the surroundings and especially on the environment. The Company puts emphasis on achieving environmental sustainability and seeks innovative solutions supporting environmental protection. The Company organizes regular Personnel training and sets out the binding internal regulations to protect the environment at every level of the Company, focusing on all components of the environment. All the Company's Personnel act in accordance with the idea of environmental protection

 

MONITORING THE COMPLIANCE WITH ETHICAL RULES AND REGULATIONS, AND THE POSSIBILITY OF SUBMITTING SUGGESTIONS TO THE COMPANY


  1. The Company declares and consistently ensures that this Code of Ethics is always observed by all the Company's Personnel. All Personnel are obliged to report any violations of any legal regulations, internal Company's standards or rules to their supervisors, or to the Company.
  2. With a view to the efforts to maintain the highest degree of transparency and the ability to flexibly respond to the current and existing situations, the Company establishes such possibilities for the Personnel and any third parties who would witness a violation of the aforementioned rules to inform the Company.
These possibilities particularly includes the Company's communication channels:

  • Suggestion box (including anonymous filings),
  • Company's e-mail – compliance@realtrade.cz,
  • In paper form as a postal shipment (including anonymously),
  • Competent supervisor.

 

ALL PERSONNEL NOTE THAT ANY ABUSE OF THE POSSIBILITY OF FILING A SUGGESTION OR FILING A GROUNDLESS OR BULLYING SUGGESTION IS CONSIDERED AS UNETHICAL AND IMMORAL ACT, FROM WHICH THE RESPECTIVE CONCLUSIONS SHALL BE DRAWN.

FINAL PROVISIONS


All Personnel note that a breach of the rules of the Code of Ethics is considered as an excess of the member of Personnel, and as such it will be considered as a breach of working obligations, and in justified cases it may be considered as a gross violation of working duties with consequences under the Labour Code. Any violation of the rules and regulations may constitute a reason for sanction or termination of the employment relationship.

THE CODE OF ETHICS IS BINDING FOR ALL COMPANY'S PERSONNEL FROM THE MOMENT THEY HAVE BECOME OR SHOULD HAVE BECOME FAMILIARISED WITH IT.

Anti-Corruption Programme of RT GLOBAL

The main intention of RT GLOBAL (hereinafter referred to as the "Company") is the domestic and foreign procurement of high-quality military technology – in this field we provide military vehicles, weapons and weapon systems throughout the world. A characteristic feature of foreign trade in military material is, in particular, the ability to secure supplies of individual pieces of technology, such as weapons, large-calibre weaponry, ammunition, bombs, missiles, tank technology, toxicology equipment, aircraft, helicopters and spare parts for the aforementioned technology as well as complex deliveries in relatively large quantity in the required quality, including sets of spare parts to ensure maintenance and repairs of the technology.
Specific services are provided by RT GLOBAL also for museums and collectors of military technology, to whom it supplies military equipment that is disabled, in full compliance with the legal regulations of individual countries.
The result of the responsible approach of the company is adoption of an internal compact system of rules, procedures and regulations, the purpose of which is the compliance of the required behaviour of employees and other persons with fundamental human rights, general ethical values, morals, legal rule and internationally recognized standards. The Anti-Corruption Programme is a part of the aforementioned system and as such it applies to all employees of the Company, including members of the Company's bodies and external entities such as consultants, suppliers or agents representing the company (hereinafter the "Personnel").
RT GLOBAL does not tolerate at all any acts of its Personnel that could be considered illegal, corruptive, unethical, unfair or immoral. The Company considers such conduct as reprehensible and unacceptable within the set image of behaviour and conduct.

Why do we implement the Anti-Corruption Programme and what do we want to achieve?

The company strongly and clearly opposes any influence of corrupt behaviour on the decision of its own and of its Personnel. Corruption is not welcome in our Company; on the contrary, it is condemned and there are consequences associated with it, which may lead to termination of further cooperation or operation.

WE SAY NO TO CORRUPTION!

This Anti-Corruption Programme sets out the basic principles and policy of the Company, and it also determines the Company's opinion concerning the corrupt behaviour of its Personnel. The aim of the Programme is to identify and implement such institutes and processes in the Company that will effectively and actively help fight corruption, will control compliance with the Anti-Corruption Programme and opinions in the Company, and will also identify new and current risks to be responded operationally and flexibly.
In our work, we want to achieve in particular such conduct of our Personnel, which will be fully in compliance with the Programme, and particularly with the idea of the global standard set out in the field of defence and weapons by Transparency International. In our internal regulations we implement such rules to ensure in particular:

• Creating a stable environment rejecting corrupt practices – implementing the rules and principles of combating, detecting and condemning corruption through the entire comprehensive internal system of company regulations,
• A strong personal commitment of specific persons – our senior staff are selected with regard to their personal qualities and taking into account their attitude to corruption and ethical and moral behaviour,
• Setting up effective processes for identification and elimination of risks – the Company implements in its system the processes aimed at regular assessing the up-to-date character, effectiveness and efficiency of the implemented Anti-Corruption Programme, such as regular Compliance Team meetings, internal audits, Programme compliance checks, etc. which are immediately evaluated and, based on the results, corrective measures are subsequently taken as a response,
• Creating and setting up effective systems for detecting and punishing possible corrupt practices – the Company defines versatile possibilities of whistleblowing corrupt practices that anyone witnesses,

Our Company generally considers any conduct that is contrary to ethical and moral values as a corrupt conduct, when at the same time there is an abuse of an advantage or possibility of either party to gain an unjustified benefit. Corrupt conduct particularly includes for example accepting or offering a bribe, negotiating an advantage or any material and intangible remuneration in connection with the Company's business and performance of the Personnel's work activities. Corrupt conduct also means offering any reward, benefit or profit to a public authority that could result in a misrepresentation, or issuance of a decision by the public authority in favour of the Company.
In addition to the aforementioned, the Company hereby declares and represents that the conduct of the Personnel, which directly or indirectly supports the corrupt practices of co-workers and other persons, is equally reprehensible and is considered as corrupt. We also consider as a support any conduct when a member of Personnel knows about the corruption, but does not report it and does not prevent it.

How do we inform our Personnel about the defined Anti-Corruption Programme and our mindset?

The topics of our Company's anti-corruption policy are, among other things, included in the initial training of the Personnel within the information about the approved compliance programme. Moreover, the Company includes the education concerning corruption and corruption intolerance in a separate training programme dedicated to compliance programme focused on gifts and bribery, with the respective information being available on the Company's notice boards, or in brochures or flyers.
The Anti-Corruption Programme, the Company's Code of Ethics, the Code of Conduct in relationships with external entities and contacts for whistleblowing are available on the Company's website, and compliance with such documents is required and enforced by the Company from its employees.

How can you inform us about unethical, immoral or corrupt behaviour of our Personnel you have witnessed?

In order to combat the corruption that the Company proclaims and requires, the Personnel as well as any third parties who witnessed undesired conduct, have the opportunity to notify the Company's management using one of the following methods:

• Electronically by email – compliance@realtrade.cz,
• In writing to a box (anonymous) – the box is installed near the entrance of the Company's establishment,
• Orally by contacting managing staff in meetings,
• By regular mail, etc.

The following information should not be missing in order to process each whistleblowing and ensure operative possibilities of response more quickly:

• Name of the person who committed an act of corruption, or at least the position, date and time when the act took place,
• A detailed description of the act of corruption,
• Evidence of possible corruption, if available (names of witnesses, photographs, records, etc.),
• Any other relevant information specific to the respective situation,
• Name of the whistleblower, unless the whistleblowing is anonymous

The Company does not tolerate any retaliation against the person who is a whistleblower.
Any whistleblowing may also be made anonymously, or with the request to maintain the whistleblower's anonymity.
The Company absolutely condemns false or perjured accusations or whistleblowing that have been made with the intent to make damage or cause a harm to a third party. Such conduct is considered unethical and will be treated as such.

What measures and institutes are we taking to prevent corrupt practices?

The basic principle of the Personnel's behaviour, which the Company seeks and supports on the side of its employees, is an active, honest and conscientious attitude to the rules, laws, regulations and internal regulations of the Company. As a part of prevention of occurrence of undesirable situations, the Company adopts measures consisting in compliance with laws and good practices, measures in the area of concluding contracts, measures in the area of managing the Company's assets, administration measures, measures in the area of hiring new employees and measures in the area of training.
In particular, the Company has implemented the following specific measures in its internal regulations as a part of the aforementioned:

1. The obligation of employees to strictly comply with regulations and internal documentation, in particular the Code of Ethics and the Code of Conduct in relations with external entities, has been established,
2. An effective and well functioning control system is in place, the sense and purpose of which is to clarify and reveal activities with a potential to be corruptive,
3. The obligation to verify business partners carefully and diligently has been established, Code of Conduct for business partners has been defined,
4. The obligation has been established to perform random inspections of the Personnel and worksites, systematic inspections and collect questionnaires completed by the Personnel, regular internal audits focused on the results of corrective measures taken and possible risks,
5. The obligation of managers to take a motivating and model attitude towards their subordinates has been established, and where corruption is revealed, consistent investigations, evaluation and adoption of measures or sanctions shall be performed

All Personnel of the Company, and particularly those in managerial positions, shall actively promote and adhere to the Anti-Corruption Programme. All Personnel are obliged to comply with the aforementioned rules reflected in the individual measures, are obliged to comply with all laws and legally binding procedures, as well as the technical and similar conditions. Each manager acts in a motivating manner in dealing with their subordinates, puts emphasis on performance of their obligation in an honest and conscientious manner, emphasizes and enforces the importance of protecting the property, goodwill, reputation and prestige of the Company, puts emphasis on the importance of adhering to ethical principles in all work activities, and puts emphasis on revealing, investigating and resolving all cases of suspected corruption.

How the Company assess the functioning of the Anti-Corruption Programme?

The task of internal auditors in evaluation of the compliance programme taking place at least once a year is also to assess the effectiveness and proper functioning of the Anti-Corruption Programme. Areas with a high risk of corruption are regularly investigated to assess whether there are facts indicating existence of corrupt practices.
If the result of the internal audit or regular inspections requires a change in or modification of the current state of affairs, it shall be implemented immediately, operatively and actively. Incorporating correct and effective corrective measures will lead to reduction or revealing possible unjustified anti-corruption actions in the future.
The evaluation of effectiveness of the Anti-Corruption Programme is focused on fulfilment of its individual parts, both qualitatively and quantitatively, on effectiveness of the fulfilment, and on implementation of possible corrective measures.