Code of conduct

Our company values its reputation and steadily follows the highest standards of business ethics in all its activities, does business in an honest manner in accordance with the highest standards. The company’s activity is based on legitimate, effective and fair working practices, including but not limited to relations with government agencies and officials, relations with the company’s employees, keeping of accounts and payment of taxes, implementation and strict adherence to the laws of Ukraine.

Regardless of the price and complexity of the issue, we always conduct our business in a legal and ethical manner.

I. Compliance with Anti-Corruption Laws

Since the core activity of the company is the provision of services in the area of registration, certification, examination and conformity assessment of medical products of foreign partners in the state bodies of Ukraine, we hereby declare that all employees of the company conduct all kinds of business in a law-abiding and ethical manner, in compliance with the current national laws and regulatory requirements, including the U.S. Foreign Corrupt Practices Act (FCPA) of 1977 and the UK Bribery Act of 2010.

We hereby confirm that the company executives and key employees, their families, contractors and advisors:

• Are not elected or appointed officials, employees, agents or representatives of state bodies, institutions or companies owned or controlled by the state;
• Are not/have not served as political party officials;
• Are not candidates or elected to political office;
• Are not officials, agents or employees of organizations financed from the state budget or public international organizations;

We hereby confirm that the payments to the state bodies, institutions or companies owned or controlled by the state, are performed by a bank transfer on the basis of agreements and / or statutory rates. Such payments are solely payments related to the performance of works of registration, certification, examination and conformity assessment of medical products.

Group of Companies’ Code of Conduct:

(a) prohibits to make, promise or authorize the making of a corrupt payment or provide anything of value to any government official to induce him or her to make any governmental act or decision to help to obtain or retain business.

(b) prohibits to address to another company or person to engage them in one of the activities above;

(c) requires from contractors, advisors, agents, representatives of the company who act on behalf of Cratia to act as indicated in paragraphs (a) and (b).

If an employee or business partner (contractor, advisor, agent, representative) is uncertain as to the meaning or applicability of any set limits, restrictions or disclosure requirements with respect to his/her interactions with government officials, that person shall consult with his/her primary contact person  from Cratia prior to carrying out his/her activities.

Government Official Definition

(a) any officer or employee or (b) an individual who acts in an official capacity on behalf of:

• an entity listed in Schedule FCPA1,
• any other Ukrainian national, local, regional or municipal governmental organization, agency, commission, committee or institution, or
• a Ukrainian political party, Ukrainian government-owned corporation or  public international organization, or

(c) a Ukrainian political party itself

II. Observance of  Confidentiality and Independence

Cooperation with almost every Customer involves receiving information and documentation, which are or may be confidential. In this regard, the company has established strict rules concerning observance of confidentiality, and every employee, contractor, advisor and agent are to sign a Confidentiality Agreement (prior to employment or beginning of cooperation).

Cratia guarantees:

• adherence to strict confidentiality of the information received, non-disclosure of such information to any third party without the prior written consent from the Customer (Partner), and non-use of confidential information except for the purposes provided for by the cooperation and in the signed Agreements;
• storage of confidential information excluding access to it by third parties;
• access to confidential information only for the employees, contractors, advisors and agents who are instructed on how to work with the confidential information and signed the necessary documents on the observance of confidentiality.

We guarantee the independence of our company from the interests of third parties and companies. This means that the founder or executive employee of the company cannot be a natural or legal person having any business interests in relation to our partners’ products or products competing with the products of our partners. This requirement applies to the family members of legal persons.

To ensure transparent and independent activity, our company guarantees that it will not do business or be involved in the business of third parties in relation to sales, participation in tenders and other methods of marketing medical products.

Financing of the company’s activity, development, and profits of the company are derived solely from the provision of services to Customers, and the funds of the founders.

III. Compliance with the Current Legislation and Information Sharing

The core activity of the company, i.e., provision of services for registration, certification, examination and conformity assessment of medical products in the state bodies, as well as other activities, are based on correct and timely fulfilment of the requirements of the current Ukrainian and international legislation, the employees’ knowledge of all sector-specific legislation, standards and etc.

Cratia guarantees that:

• works and services are provided in strict compliance with the applicable Ukrainian legislation, as well as, where applicable, in compliance with the European and international law;
• execution of works and provision of services do not violate any national laws, acts or standards;
• employees of the company timely undergo training and education, and perform only the works for which they have confidence in the legitimacy and compliance with legislation.

IV. Fulfillment of Obligations

Fulfillment of obligations to the Customer and long-term cooperation are more important than a shirt-term profit. In any situation, the fulfillment of obligations to the Customer comes first, and the company assures that it will adopt an unprofitable solution that will ensure a legal and proper fulfillment of commitments.

V. Observance of the Free Competition Conditions

We hereby declare that we respect and follow the rules of free market competition and business ethics, including but not limited to:

• prohibition to enter into any agreements or arrangements with competitors to harmonize prices, profit levels, or other aspects of competition in respect to our works and services;
• prohibition of any unethical methods of competition, including but not limited to distribution of  unfair information, influence on state bodies, agencies and officials;