Translation from Bulgarian





I. Preamble


The Code of Ethics of Aquachim JSC (hereinafter 'the Company’) sets out the principles of conduct of the Company in respect of its employees, external associates and the external environment. Furthermore, it defines the desired principles of conduct of its employees and third parties who are associates of the Company on the grounds of a freelance contract (hereinafter ‘external associates’). In all its operations the Company complies with all the core values and business approaches established by best practices.


 In all its operations the Company complies with all the core values and business approaches established by best practices.


The Company is aware of its commitments to all entities it contacts: the employees, customers, external associates, suppliers, competitors and the public.


The Company's reputation and trust of all interested parties are some of its most important benefits. Their preservation is one of the main tasks of the Company.


In all its operations, the Company requires from its employees and external associates to comply with the ethical standards described in this Code. The compliance with the ethical standards is constantly being monitored.


The Company respects the good tone and the rules of business competition. Fiscal year-end closing of the Company is true, accurate and timely.


II. Principles of Conduct for Business Contacts


1.The employees and external associates working in the Company under employment contract or freelance contract must perform their duties in good faith, in accordance with the legal provisions of the Republic of Bulgaria

2. The employees of the company shall be guided by the internal standards of the Company.

3. The employees and external associates shall represent the Company in a duly manner and

in good faith:

-   The employees and external associates shall always act In a manner which is not detrimental to the Company and its goodwill;

-   The employees and external associates shall preserve the assets of the Company and use them only for the business operations of the Company;

-    The employees and external associates shall not allow their personal interests to prevail over the interests of the Company;

-   The employees and external associates shall not engage in fraudulent activities and complicity to fraudulent activities.

4. Corruption practices of any kind are unacceptable. The employees and external associates shall not accept or instigate the giving of any unregulated tangible or intangible benefits related to the performance of their duties for the operations of the Company. Also, they shall not provide similar benefits to customers or others, which might result in a feeling or expectation for personal commitment. No secret or unregistered payments shall be allowed to associates, customers or external persons and organizations. There shall be no unauthorized contacts with institutions, opinion leaders and patient organizations. All Company activities related to training and product marketing shall be held in the absence of conditions for informal social contacts. Events of scientific purpose shall be promoted, without allowing the funding of parties who are not scientifically interested. Any information regarding corruption practices shall be immediately reported to the management.

5. Any information obtained by the employees or external associates of the Company in relation to their work duties within the Company shall not be used for personal benefits or for purposes other than those for which it was intended. This obligation shall remain in effect after the end of their employment or contractual relationship with the Company. Their actions must conform to the Bulgarian legislation, in particular the Personal Data Protection Act. Upon any communication with third parties they shall act with utmost caution and shall not communicate anything that could lead to violations of this Code.


 III. Relations between the Company and the Employees


1. Relations with the employees shall be based on respect and the dignity of each person.

2. The Company shall appoint and promote employees based on their qualifications for the particular job without any racial, religious or national origin discrimination, irrespective of skin colour, gender or age.

3. The Company shall aim to provide work appropriate for the employees through responsible selection and shall provide them with accurate information regarding the opportunities for their professional perspective and career development.

4. The Company shall carry out a fair staff organization policy and remuneration policy according to the contribution of individual employees for the achievement of the objectives of the Company.

5.  The method of remuneration shall reflect both the contributions of individual employees and the achievements of their respective departments/sectors.

6.  The company encourage its employees at all levels in developing their skills relevant to    their work, shall assist them in that regard and shall take care of their professional development.

7. The Company shall not tolerate any sexual, physical, psychological or any other kind of harassment of the employees.


IV. Principles of Conduct of the trade Network in Working with Customers of the Company and With Third Parties


1. When working with customers and debtors, the employees and external associates shall behave in a manner that is consistent with the legislation in force.

2. The emplyees and external associates shall use a polite, honest and unprejudiced approach to all customers. They shall negotiate without any preconceptions derived from personal motives.

3. The employees and external associates shall provide the customers with complete, true, undistorted and clear information related to the products offered by the Company.

In performance of their duties, the employees and external associates are required:

-          Not to use any obscene, profane or rude language;

-          To present themselves when telephoning a customer or a debtor;

-          Not to record any phone calls with customers or debtors, without the prior consent of the other party.


V. Relations with Competitors


  1. The Company enters the competitive race purposely but honestly, without using any unlawful or unethical approaches.
  2. The Company shall not harm the reputation of its competitors either directly or indirectly.
  3. The Company, its employees and associates shall not seek to obtain secret information about the competitors in an unfair manner.


VI. Compliance with Standards


  1. Compliance with the Code of Ethics of the Company is compulsory upon the performance of the operations of the Company.
  2. The Executive Director of the Company shall supervise the investigation of all complaints regarding violations of the Code of Ethics and shall ensure, where necessary, that the relevant disciplinary actions in accordance with the applicable labour low provisions are taken.
  3. The consequences of any violations of the Code of Ethics by external associates are specified in the relevant contracts between the Company and the specific external associate and also derive from the relevant legal provisions regarding compensation of damages.
  4. The Code of Ethics shall enter into effect on the date of its approval by the Board of Directors of Aquachim JSC.
  5. For the employees of Aquachim JSC, this Code shall enter into effect on the date when they have familiarized themselves with it.
  6. For the external associates of the Company, is shall enter into effect on the date when the respective external associate has familiarized himself/herself with the contents of this Code of Ethics.