“Brand Computers” LLC Code of Ethics and Business Conduct

This Code of Ethics and Business Conduct of “Brand Computers” LLC serves as our ethical commitment and as a guide to proper business conduct for all of our stakeholders. We, at “Brand Computers” LLC are committed to doing business legally, ethically, and in a transparent manner.

This document applies to all staff who work for the “Brand Computers” LLC (including directors, team leaders, employees, interim, sub-contractor, or consultant staff), and also includes other organizations who do business with us.

“Brand Computers” LLC expects its staff to be impartial and honest in all affairs relating to their job. All staff bear responsibility in general, to be of good faith and do nothing to destroy the trust necessary for employment.

• We gain credibility by adhering to our commitment to fairness and reaching our goals solely through ethical conduct.
• We are committed to making efforts to apply our values and norms also throughout the entire value chain of our own suppliers, sub-contractors, service providers, and business partners.
• We are open to any question at any time and will not allow punishment or retaliation against anyone for reporting misconduct in good faith.

1. Antitrust and Competition

“Brand Computers” LLC complies with applicable antitrust and competition laws of the Republic of Armenia. They aim to protect competition that benefits consumers. Violations of antitrust and competition laws can lead to serious consequences, including heavy fines and imprisonment. You must strictly comply with antitrust and competition laws. It is forbidden to collude with competitors in order to:

1.1Set or control prices directly, through intermediaries or otherwise colluding with competitors;

1.2 Distribute bids in tenders for the purpose of awarding a contract to a specific competitor or reseller (i.e. Collude in tenders), including refraining from bidding and submitting non-competitive and bogus bids;

1.3 Boycott suppliers or customers;

1.4 To split or distribute markets or customers;

1.5 Restrict the production or sale of products or product lines. 

These types of collusion are contrary to the public interest policy and the rules of the “Brand Computers” LLC. Discussion of the above topics should be avoided not only within “Brand Computers” LLC, but also with representatives of other companies.

Also, avoid discussing forbidden topics with competitors such as prices, costs, revenues, profit margins, sales volumes, bids, and customer-specific quotes.

Certain ways of selling and negotiating with customers and suppliers can also lead to charges of violating antitrust or competition laws if they unfairly restrict or stop competition between your competitors or customers.

Examples of such illegal agreements:  artificial underpricing (below cost), exclusive dealer agreement, group or load sales, agreements with customers or suppliers for a minimum resale price, discrimination against competing customers.

2. Improper Payments, Money Laundering, and Economic Boycotts

“Brand Computers” LLC employees are prohibited from offering and paying bribes. You may not, directly or through intermediaries, receive, offer, promise, authorize, give appropriate instructions or pay/provide any bribes, kickbacks, money or any value for the purpose of illegally concluding a transaction or obtaining any other benefits. Penalties for individuals for violating these laws are severe and can include heavy fines and imprisonment. In addition to this, Brand Computers LLC prohibits all types of money laundering, which means concealing/diverting money obtained from crime and converting these funds into legal funds.

It is prohibited at “Brand Computers” LLC to transfer funds and other valuables directly or through intermediaries to government officials and government officials, their spouses, loved ones, children and other relatives, to influence the actions or decisions of a government official or government official, to reward him for actions or decisions made, or to provide an unfair advantage to “Brand Computers” LLC. Values include not only money, but also gifts, too expensive or inappropriate entertainment, payment for personal travel, for example, sightseeing, charitable donations, job offers. “Brand Computers” LLC also prohibits the payment of facilitation payments, that is, payments to government officials in order to expedite the performance of routine duties, including the processing and approval of applications and permits. Partners should not participate in economic boycotts not sanctioned by the government of the Republic of Armenia. 

3. Dealing with Government

“Brand Computers” LLC standards and applicable laws in dealing with government and government official are more stringent than those for dealing with employees of commercial companies. You must strictly comply with the laws, rules and regulations governing the execution of government contracts and the purchase of goods and services by government agencies in any country. Actions that are considered normal when dealing with nongovernment clients may be inappropriate and even illegal when dealing with government. When working with government agencies, including international public organizations, you must know and follow all rules regarding government contracts and interactions with government officials and government officials, including the following requirements:

3.1 During procurement and in other cases where there is reason believe that such information is non-public, you should not try, directly or through intermediaries, to obtain from any source information that is not available to the general public or is prohibited from dissemination that may affect purchases; internal government confidential information on pre-selection and source selection; any proprietary information of a competitor, including information about bids and offers. 

3.2 You must provide accurate billing information to government agencies and comply with all billing and payment laws.

3.3 You must not, directly or through intermediaries, provide or offer monetary awards, gifts, business courtesies, entertainment, loans, or any material value to government officials or government officials unless permitted by law. Suppliers are required to implement and comply with appropriate internal controls to ensure that they comply with all applicable laws and laws of the Republic of Armenia regarding the prohibition of offering valuables to government officials and government officials.

3.4 You must not provide, offer or solicit kickbacks, directly or through intermediaries, in order to secure favorable terms for yourself or another party.

It is forbidden to pay remuneration to any person or collude to pay remuneration (directly or through intermediaries) in order to obtain a government contract or influence the actions of government organizations. It is also prohibited to receive remuneration or take part in payment for recommendation programs, if we are talking about transactions in which government organizations or their representatives (including higher education institutions, public health institutions, and utilities) participate.

4. Lobbying of Government Officials

Lobbying is arry action aimed at changing laws, regulations, policies and rules. In some jurisdictions, the law refers to lobbying activities in the field of procurement and business development. Employees need to understand in rvhich cases, from the point ofview ofthe law, activities can be qualified as lobbying in specific jurisdictions, ard comply with applicable law.

You should also understand in what cases your activity from the point of view of the law can be qualified as lobbying and comply with the legislation of the Republic of Armenia. You should not lobby for the interests of “Brand Computers” LLC in the government.

5. Trade Compliance Laws and Regulations

Trade laws and regulations regulate the import, export, re-export and use of manufactured goods and technical data in different countries. Our commitment to integrity begins with complying with laws, rules and regulations. We understand and comply with the legal requirements and commercial practices of lawful business.

We are committed to adhere to every valid and binding contractual agreement that we conclude, and we do not abuse our rights.

6. Conflict of Interests

Our decisions shall be based on objective and fair assessments avoiding the possibility of any improper influence. A "conflict of interest" exists when an employee's personal interest (that can be linked to e.g. friends, family, or customer, competitor, supplier, contractor entity, as well) interferes or potentially interferes with the best interests of “Brand Computers” LLC. Determining whether a conflict of interest exists is not always easy to do, thus anyone with a conflict-of-interest question should seek advice from management.

Conflicts of interest could arise:

6.1Being employed (you or a close family member) by, or being in economic relation with an actual or potential customer, competitor, supplier or contractor. 

6.2 Hiring or supervising family members or closely related persons.

6.3 Serving as a board member for another company or organization.

6.4 Owning or having a substantial interest in a customer, competitor, supplier or contractor.

6.5 Having a personal interest, financial interest or potential personal gain in any company transaction.

If co-workers become involved in personal relations with each other, the onus is on the senior employee concerned to bring this to the attention of his or her manager to confirm that there is no conflict of interest, nor will a conflict of interest arise.

7. Anti-corruption

“Brand Computers” LLC firmly condemn and do not tolerate all forms of corruption.

7․1 It is prohibited directly or indirectly offering, promising, giving, asking, soliciting or accepting any unfair advantage or benefit, in order to obtain, retain or facilitate in any way the business. An unfair advantage or benefit may include cash, any cash equivalent, gift, credit, discount, travel, personal advantage, accommodation or services.

7․2 We do not permit facilitation payments to government officials or private business in order to secure or speed up routine actions. 

Corruption also covers the misuse of function or position as well, when someone makes that false appearance that s/he improperly influences a decision maker. Corruption for either to obtain or retain business, or to obtain or retain an advantage in the conduct of business is considered gross misconduct. Similarly accepting or allowing another person to accept a bribe is considered gross misconduct. Our staff has to account for all benefits received in the course of doing business and must to not give or receive bribes or otherwise act corruptly.

8. Privacy, personal data protection

“Brand Computers” LLC respect people’s privacy and we acknowledge customers, employees and other natural persons’ need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to comply with all personal data protection laws. We only acquire and keep personal information that is necessary and we give proper information on these activities to data owners. We implement proper security measures to assure confidentiality, integrity and availability of personal information.

Our staff must observe the legal requirements, apply compliant practices and follow related procedures to ensure legality of personal data handling and processing activities.

9. Discrimination and harassment

“Brand Computers” LLC provide equal opportunity in employment and we do not tolerate any discrimination or harassment or any type from abuse. No direct or indirect discrimination shall take place based on any professionally non-relevant trait or circumstance, like gender, marital status, age, national or social or ethnic origin, colour, religion and political opinion, disability, sexual orientation, employee representation, property, birth or other status. Any kind of discriminatory behaviour, harassment, bullying or victimization is prohibited. 

All staff is expected to follow the highest standards of conduct in all verbal and written communication based on mutual respect, and must refrain from any form of harassment, slander or any behaviour that could be taken as offensive, intimidating, humiliating, malicious or insulting.

10. Human rights

“Brand Computers” LLC are committed to respect human dignity and rights of each individual and community whom we interact with during the course of work.  We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect and care and uphold human rights.

11. Fair competition and business conduct

“Brand Computers” LLC relationships with business partners are built upon trust and mutual benefits compliant with competition law. We are dedicated to ethical and fair competition, as we sell products and services based on their quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities, nor will we engage or assist in unlawful boycotts of particular customers. We commit to comply with all applicable trade controls, restrictions, sanctions and import-export embargos.

11.1 We do not allow any violence of the fairness of any tendering process in any way.

11.2 We refrain from damaging competition and the reputation of any business partners and any behaviour that harms competitor’s creditability.

11.3 We do not hold back maliciously, unlawfully or unduly payments towards our partners.

Our staff is responsible for ensuring fair business during their job and adhere to every competition, consumer protection and fair marketing rule. Customers and business partners shall be treated fairly and equally, products and services shall be displayed in a manner that is fair and accurate (fair marketing and advertising), and that discloses all relevant information.

12. Health, Safety and Environment

“Brand Computers” LLC provide clean, safe and healthy work conditions and we are dedicated to maintaining a healthy environment. We are committed to minimise the impact on the natural environment of our operations. We make efforts to reduce the use of finite resources, like energy or water, and the harmful emissions, like waste.

All staff must follow and comply with every relevant health, safety and environmental protection laws, regulations and rules all times.