Code of Conduct

ADOZ, s.r.o. (“the Company”) issues this Code of Conduct and commits to complying with it.

 
The Code applies to all employees, including managers, temporary and agency workers. We expect our suppliers and business partners to follow its principles as well (section 7). We comply with Czech and EU law; the Code is based on the UN Guiding Principles on Business and Human Rights, the ILO conventions, the OECD Guidelines and the Drive Sustainability Global Automotive Sustainability Guiding Principles.

1. Responsibilities

In this role, the Human Rights Officer is independent, is not bound by instructions and briefs the Managing Director on the risk position at least once a year.

2. Professional conduct

Employees work competently, honestly and impartially, without pursuing personal gain, and carry out their tasks properly and without undue delay. They treat colleagues, customers and partners decently and with respect, and give them true and complete information. They use Company property and resources economically, do not appropriate them, and report any damage to their superior immediately.

Employees behave courteously and politely: they greet people, express themselves properly, take care of their appearance and stay calm and factual even in difficult situations. Anyone dealing with an employee has the right to know their name and the department they work in.

3. Human rights and working conditions

We respect human rights and treat all people with dignity and fairness.

• Child labor and young workers: we do not employ anyone below the legal minimum working age. Young workers under 18 do not work overtime or at night, do not perform work that is hazardous for them, and their work does not interfere with their education.
• Wages and benefits: we pay at least the statutory minimum wage, on time and with all statutory supplements, compensations and paid leave. Remuneration follows industry practice and allows a decent standard of living.
• Working hours: we comply with the Czech Labour Code: regular working time of no more than 40 hours per week, overtime of no more than 8 hours per week on average, and an uninterrupted weekly rest of at least 35 hours. Overtime is exceptional; beyond the extent that may be ordered by law, it is possible only with the employee’s agreement. Total working time including overtime does not exceed 60 hours per week, and every employee has at least one day off in every seven days.
• Modern slavery: we reject any form of forced or compulsory labor and human trafficking.
• Ethical recruiting: we do not charge job applicants any fees, do not retain their documents, and every worker receives a written contract in a language they understand. We require the same from employment agencies.
• Freedom of association and collective bargaining: we respect employees’ right to join trade unions and to bargain collectively.
• Non-discrimination and harassment: we apply equal opportunities regardless of sex, nationality, ethnic origin, religion, age, disability, sexual orientation or any other characteristic. We do not tolerate harassment, bullying or degrading treatment.
• Women’s rights: women and men have equal rights and equal pay for equal work; we protect pregnant employees and parents.
• Diversity, equity and inclusion: we support a work environment where everyone can contribute and develop.
• Rights of minorities and indigenous peoples, land rights and security forces in the supply chain: throughout our supply chain we respect the rights of local communities, minorities and indigenous peoples, we do not take part in forced eviction or the unlawful taking of land, forests or water, and any security services we use must respect human rights.

4. Health and safety

We provide a safe workplace in compliance with the Czech Labour Code and Act No. 309/2006 Coll.; our goal is zero accidents. We assess risks regularly, and employees report hazards and near misses without fear of reprisal. In particular, we ensure:

• personal protective equipment based on risk assessment, with training in its use,
• machine safety: safety guards, regular inspections and operation by trained staff only,
• emergency preparedness: emergency and evacuation plans and first aid,
• incident and accident management: recording and investigating accidents and incidents, with corrective actions,
• workplace ergonomics and safe manual handling of loads,
• safe handling of chemical substances according to safety data sheets,
• fire protection: fire extinguishers, marked escape routes and regular inspections.

We keep the work environment calm and non-discriminatory, help reduce stress and prevent burnout, and ensure appropriate temperature, lighting, ventilation, hygiene and noise levels.

5. Business ethics

We do business honestly and in compliance with the law.

• Anti-corruption and anti-money laundering: we do not offer, give or accept bribes, gifts or benefits that could influence decisions; we do not favor relatives or acquaintances. We do not take part in money laundering. We give and accept gifts and hospitality only of customary and reasonable value and never in connection with a decision on an order; employees discuss any gift worth more than CZK 2,000 with their superior in advance. We do not make contributions to political parties or politicians on behalf of the Company; sponsorship and charitable donations are made transparently and with the approval of the Managing Director.
• Data protection and data security: we process personal data in accordance with the GDPR and keep confidential information secret, also after employment ends. Confidentiality does not apply to reporting suspected unlawful conduct (section 8). We protect our information systems against misuse.
• Financial responsibility (accurate records): we keep accounts and business records truthfully and completely.
• Disclosure of information: we disclose mandatory information truthfully and on time.
• Fair competition and anti-trust: we do not enter into price-fixing or market-sharing agreements and do not exchange sensitive information with competitors.
• Conflicts of interest: employees disclose any potential conflict between their personal interests and the interests of the Company to their superior in advance.
• Counterfeit parts: we buy from manufacturers and authorized distributors; suspected goods are quarantined and the customer is informed.
• Intellectual property: we respect patents, trademarks and the know-how of customers and suppliers.
• Export controls and economic sanctions: we comply with EU sanctions and export control rules; we do not trade in goods or with partners that we know to be subject to sanctions.
• Whistleblowing and protection against retaliation: violations can be reported, also anonymously (section 8); retaliation against a whistleblower is prohibited.

6. Environment

We are committed to complying with environmental legislation, continuously measuring our environmental performance and continuously improving it within our ISO 14001 environmental management system. We focus in particular on:

• climate and energy: reducing GHG emissions, energy efficiency, renewable energy and decarbonization
• water, air, soil and noise: water quality, consumption and management, air quality, prevention of soil contamination (soil quality) and limiting noise emissions,
• responsible chemical management: compliance with REACH, RoHS and the End-of-Life Vehicles Directive, and preference for PFAS-free materials,
• resources and waste: sustainable resources management, waste reduction, reuse and recycling,
• biodiversity and animal welfare: we do not knowingly buy commodities linked to deforestation (biodiversity, land use and deforestation) and we respect animal welfare.

7. Suppliers

We expect our suppliers and subcontractors to comply with the principles of sections 3–6 of this Code (human rights and working conditions, health and safety, business ethics and environmental protection) and to apply them as binding requirements to their own suppliers. The Code is published on our website and referenced in our purchase orders. For key suppliers, we verify compliance with these requirements through a simple self-assessment questionnaire. Serious violations may lead to the termination of cooperation.

For products containing tin, tantalum, tungsten, gold, cobalt or mica, we require our suppliers to ensure responsible sourcing of raw materials in line with the OECD Due Diligence Guidance.

8. Reporting violations (whistleblowing)

Suspected violations of this Code or the law may be reported by employees, suppliers and any other affected persons, also anonymously:

• by e-mail to adoz.wb@adoz.cz,
• by phone at +420 771 161 589,
• by post to the Company’s address, with the envelope marked “Neotvírat – k rukám pověřence pro lidská práva” (Do not open – for the Human Rights Officer),
• in person by appointment with the Designated Person.

Reports are handled impartially and independently by the Designated Person (Human Rights Officer). If the reporting person provides contact details, the Designated Person confirms receipt within 7 days and communicates the outcome of the assessment within 30 days (extendable twice by 30 days in complex cases). The identity of the reporting person is protected and any retaliation is prohibited. Details are set out in the internal regulation OP-ALL-006 Whistleblowing.

9. Training and final provisions

Every new employee is introduced to this Code during induction training and confirms their understanding by answering control questions. Employees are informed of any changes to the Code. Managers lead by example and help resolve ethical questions.

Compliance with this Code is a matter of professional honor for every employee. A breach of this Code may also constitute a breach of obligations arising from legal regulations relating to the work performed, under the Czech Labour Code. The Code is reviewed at least once a year.


This Code of Conduct enters into force on 1 January 2026.