KUMSONG Trading Co. LTD principles of business conduct

Principles of business conduct

Relationships between employees of the Company, regardless of their position, and our partners and customers are based on the principles of:

• Honesty;
• Fair competition;
• Decency;
• Respect;
• Good faith;
• Sense of responsibility;
• Legality;
• Economic feasibility.

Fair competition

Antitrust and competition laws are enforced to promote fair competition and protect partners and customers from unfair business practices.

Fair competition is one of the fundamentals of an open market economy. Compliance with the competition law shall be a prerequisite and one of the Company’s basic principles.

Unfair competition covers any actions in a competition that are contrary to trade and other fair business practices. Unfair competition refers to acts by the operator which violate the provisions of the anti-fair competition law, undermine the lawful rights and interests of other operators and disrupt the social and economic order.

It is in our best interest to develop in a market that respects the highest standards of doing business. KUMSONG Trading Co. LTD is committed to treating all its current and potential partners fairly and creating equal conditions.

We always take into account the legal requirements of the countries of our counterparties with which we do business. Any manifestations of unfair competition or abuse of dominant position are prohibited in the activities of the Company, as the Company strictly complies with the antitrust laws of the applicable jurisdictions. The employees of the Company shall have no right to unreasonably criticise the products and services of competitors.

Trade compliance

We are aimed to ensure that all import and export transactions to be subject to conformance with the laws and regulations of the countries involved and where the Company operates.

In the context of trade compliance we take into account the assessment of risks posed by clients, customers, products, services, supply chain, intermediaries, counterparties, transactions, and geographic locations.

Our trade compliance comprises two general operating practices

• Customer due diligence and supplier vetting using sanctions lists or restricted or denied parties lists to ensure that the trade transaction is not destined for a sanctioned individual, company or country.
• Managing commodity-based import and export controls in a compliant manner across our group supply chain, in order to know and assess where the goods to be delivered, high-risk jurisdictions and end-users customers, terms of financial transactions, requirements of applicable legislation, taxation and customs regulations, export restrictions and sanctions regulations, contractual risks of title transfer and risks of loss and damages.

Zero tolerance of bribery, corruption or abuse of authority

The Company does not tolerate any form of bribery, corruption or abuse of position. We adhere to international principles on human rights, labour, environment and anti-corruption. We adhere to the principle that all enterprises must act against all forms of corruption, including extortion and bribery.

The Company recognises and adheres to the provisions of international anti-corruption laws, including the UN Convention against Corruption, the USA (US FCPA) and UK (UK Bribery Act) legislation, Framework for OFAC Compliance Commitments, OECD Anti-Bribery Convention, Criminal Code of Switzerland.

Relationships with customers, suppliers, and state bodies

Mutual trust and honesty are important to us in our business relationships with partners and suppliers. When choosing our partners and suppliers, we make sure that they work in accordance with our values and principles.

We must offer our customers understanding, respect and knowledge. We must always try to meet the customer’s needs in the best possible way subject to the business ethical principles. Similarly, we must treat suppliers impartially and fairly.

The Company shall interact with business partners (customers, suppliers, contractors, consultants) on the basis of long-term cooperation, mutual benefit, respect, trust, honesty and fairness.

We cooperate with reliable business partners engaged in legitimate activities. We fulfil our contractual obligations to business partners in good faith and demand the same from them. We resolve conflicts legally, seeking to find mutually acceptable compromises.

Confidentiality and data protection

Information security and IT security is one of our key priority and competencies. Well-known companies and corporations rely on our certified consulting services. Therefore, it is extremely important that we ourselves internally guarantee the highest level of security when processing Company data, as well as customer and employee data. This includes, but is not limited to, protection against unauthorized access, unauthorized or improper use, loss and premature destruction.

In addition to technical and organizational measures we use to protect data and information, each employee is personally responsible for handling all personal data of customers, employees and suppliers with care and confidence.

With a high sense of responsibility, we ensure that all internal rules to ensure an equally high level of data protection are consistently followed and regularly reviewed. It is important to us that everyone can learn about the category and amount of data we choose. We collect and process confidential data only with the consent of the data subject, if this is permitted by law or necessary to fulfill contractual obligations. In addition, we collect, process and use personal data only to the extent necessary, for the necessary period of time and only for the intended purposes. We respect the comprehensive rights of individuals whose data we collect, process and use.

All employees of the Company undertake to protect their company’s data and operational interests. Information from and about our company must be treated confidentially and will not be disclosed unnecessarily. We do not leave business documents, files or software open for viewing or open on computers for others when we are not at work or working in public places.