ETHICAL CODE

Ethical code

Ethical code

1. The importance of ethics

we believe that managing the Company’s operations with fairness, transparency, proper business conduct, mutual respect, good faith and assimilating these values ​​will lead the Company to realize its vision, business success, impetus, image and good name. Compliance with norms required by the Code of Conduct by members of the Board of Directors, managers and employees of the Company will contribute to a good and effective work environment and success in business operations. Management, the employees and each employee will work jointly to maintain a Code of Business Conduct in the company.

2. Code of Conduct as a framework for business conduct rules
The purpose of the Code of Business Conduct is to express and reinforce the company’s commitment to proper and value-based behavior. The Code of Conduct provides a framework for company policy regarding behavior as reflected in the collective agreements that apply in doing so, the disciplinary regulations, company procedures and human resources provisions, which are updated from time to time (“Company Procedures”). In addition, the Code of Conduct complies with the Company’s procedures and the social and business behaviors required by law. In the event of a conflict, the provisions of the Law shall prevail.

3. Applicability
The Code of Conduct adopted by the Company’s Board of Directors applies to all managers, employees and consultants of the company and its wholly owned subsidiaries. We expect everyone to act in the name of the Company, to act in an ethical and fair manner in accordance with the Company’s Code of Conduct and procedures.

4. Mutual respect
We will treat each other with respect, fairness and courtesy while respecting the differences that exist between people. We will refrain from any act or omission that may harm or harass others, as well as any discrimination on grounds of religion, race, sex, sexual orientation, disability or any other background that expresses differences between people. We will respectfully treat customers, suppliers, contractors and other third parties with whom we are engaged, including their employees.

5. Collaboration with the Union
We maintain a collective labor relation with the the Company’s and IMI Systems Ltd. Workers Union and believe in mutual cooperation in all matters related to the Company’s Workers system and the conditions of employment. We have an open dialogue with employee representatives. The labor agreements and human resources provisions in the company are the result of the dialogue and cooperation.

6. Rules of conduct at work
The rules of conduct at work and the duties of the employee are set out in Chapter 1 of the Disciplinary Rules, applicable of labor agreements at the Company and its Procedures. We are committed to accepting them and acting on them.

7. Privacy
We believe in the human right to privacy and we respect the privacy of every employee, supplier and every individual with regard to his or her personal data, salary, personal condition, health and any information contained in the Company’s computer system. We will secure the information and guide those responsible for it to keep its privacy. We will act in accordance with the Privacy Protection Laws and regulations and use the databases in accordance with the Company’s procedures.

8. Conflict of Interest
We will act in the best interests of the Company and avoid any conflict of interest. We will avoid an employment that may raise concerns about conflicts of interest, subordinate relationships or work relationships due to the proximity of another employee. Company employees and managers are prohibited from receiving gifts and / or favors from customers and suppliers.

9. Protection of Company Assets and Good Name
We remember that each of us represents the company and will do everything possible to maintain the good reputation of the Company. We will protect the Company’s assets, both physical assets and intellectual property, including trade secrets, patents, trade names, copyrights, business information, knowledge and documentation. Our use of these assets will be for work purposes and not for personal use.

10. Prohibition of Political Activity
We believe in the freedom of opinion of every person. The Company opposes political activity during company hours. In the course of the work, we will separate our work from our political position and support.

11. Compliance with the Law
The company is a public company whose shares are traded on the Tel Aviv Stock Exchange, which operates in accordance with the laws of the state of Israel. We are required to comply with applicable law, regulations and guidelines in the country. The Company’s General counsel should be consulted in any question or doubt.

12. Business Conduct and Fairness to Customers and Suppliers
The Company maintains close relationships with customers and suppliers based on mutual respect. We treat honestly and fairly with suppliers, customers, competitors and anyone with whom the company conducts business with.
The Code of Business Conduct applies to all managers and employees of the company and they are required to act fairly and ethically when conducting operations and negotiating on behalf of the Company, in compliance with legal and contractual obligations. obligations shall be in accordance with the Signatory Powers Procedure as approved by the Company’s Board of Directors.
The Company is committed to fair competition, inter alia, by preventing unreasonable restrictions on freedom of trade and respecting the laws of the relevant countries, including its international trade and import norms.
The Company will ensure that its financial statements reflect its operations and business activities in a timely, clear, accurate, and consistent manner in accordance with applicable accounting principles and law. The Company will provide all required reports in accordance with its obligations under law, its contractual obligations and in accordance with the business standards to which it is committed

13. Safety and Environment
We will comply with rules regarding safety and hygiene at work, while strictly adhering to all laws and regulations of the State of Israel and the environment in which we operate, so that the work environment is as safe and secure as possible and free of dangers.
Therefore, the Company operates a professional and skilled system of safety management, occupational hygiene and the environment, and works to assimilate this commitment to prevent environmental pollution and to ensure continuous improvement of the environmental quality of the plant.

14. Quality Assurance
We will maintain a relationship built on trust with customers and suppliers and will work to fulfill our commitments in good faith and we will maintain the good reputation and prestige of the Company. The Company’s products have a reputation for its high quality, we will maintain that reputation. Every employee will maintain quality, control and reporting of any defect regarding the Company’s products.

15. Data Security
The use of the Company’s information will be for business purposes only, by authorization. As an industrial company that some of its products are for military market, the use and dissemination of information will be according to the security classification of the information and in accordance with the security guidelines and any applicable law and regulations. During our work in the Company and after we have completed our work, we are committed to safeguarding the information and protecting confidential information that came to us during our work from our military and civilian customers, in accordance with all laws and company procedures.

16. Anti-Bribery
The Company give a supreme importance to prevent corruption of any kind, including accepting and / or providing bribes or benefits to any individual or body, including foreign public servants and / or customers and / or suppliers. Giving and receiving bribes, including to a foreign employee, customers or suppliers – is prohibited by law. 

A “foreign public servant” for this purpose is a foreign national employee and anyone who holds public office in the foreign country, including employees of government companies and public bodies and including employees of international organizations.
All employees of the Company and all its representatives are prohibited from securing, offering or giving bribes or benefits to a foreign public, customer or supplier as well as receiving bribes from any person or body, in Israel and abroad.
The Company has taken and is taking various measures to prevent bribery of foreign public employees, including in accordance with its Compliance Program. The Company is conducting training led by a Compliance Officer.
As Compliance Officer, Mr. Julian Cohen, Director of R&D, was appointed.
In case of question or doubt regarding this issue and in case of fear of conduct contrary to the prohibition on bribes and benefits to foreign public servants, please contact the Compliance Officer according to the following details:  Julian.Cohen@Ashot.co.il, 08-6721354.

17. Address for Inquiries
The Code of Conduct will be published and distributed to the Company’s employees and customers, both on the Company’s website and on the internal computer network.
Compliance with ethical code standards also requires reporting of any concerns about behavior in violation of ethical code and company practices. In case of doubt, question or complaint regarding ethical conduct or concern for violation by any of the Company’s employees or managers, please contact the Company’s Ombudsman – Ms. Shoshi Weinstein according the following details: shoshi.vainshtain@ashot.co.il, 08-6721502.

18. Handling Inquiries
The Ombudsman will examine the complaints, examine them, summarize the findings of the examination and forward the recommendations to the Company’s CEO and the Audit Committee, which will submit the findings of the examination to the complainant in accordance with the law.

19. Protecting the Complainant and His\Hers Confidentiality
We will protect employees who have filed a complaint against the company or any other employee or manager of the company in accordance with the law.
Any question, concern or complaint that will be received at the Ombudsman from the Complaints will be treated confidentially while maintaining the confidentiality of the complainant’s identity. The company will protect any complainant who filed a complaint in good faith, even if it turned out to be incorrect.