I. Introduction

General Policy and Procedures

The good name and reputation of the Company is the product of the conduct, dedication,
integrity, and abilities of our employees. All companies, including ours, depend on their reputations.

Hymeri Kleemann expects all of its employees to share its commitment to high ethical, legal and moral standards and to avoid any activities, which could involve the Company or its employees in any unethical, improper or unlawful act.

As used in this Code, the term “employee” shall refer to all employees, officers and directors of the Company. The term “Company” shall refer to Hymeri Kleemann.

The purpose of this code of ethics is to:

  • Demonstrate the company’s commitment to the highest standards of ethical behavior;
  • Encourage proper ethical conduct and sanction misconduct within the company;
  • Develop an ethical culture based on such standards and conduct, led by the Company’s shareholders, directors and management, and followed by all employees.

In order to foster the confidence of its shareholders, employees, investors and the general public, this code of ethics goes beyond the legal and regulatory framework prevalent in our country today, and embraces both national and internationally recognized principles and practices.

Careful study of this Code will provide you, as part of Hymeri Kleemann with a better understanding of the Company’s expectations and of your own obligations.

Compliance with this Code is mandatory and it is the duty of all employees to familiarize themselves with the Code, as well as the legal standards and policies applicable to their assigned duties and to conduct themselves accordingly.

The Code is not intended, however, to be an exclusive set of guidelines or policies for governing the conduct of employees. The Company has adopted and may amend other corporate policies, procedures, personnel manuals, or employee handbooks. Moreover, no Code or set of policies can ever be totally comprehensive or serve as a substitute for the good judgment, common sense and proper, ethical and legal conduct we expect of all employees.

As an employee of Hymeri Kleemann , you acknowledge and agree that you have reviewed and understand this Code of Business Conduct and Ethics; that compliance therewith is a requirement of your continued employment; that you agree to comply with this Code of Business Conduct and Ethics; and, that a violation of this Code of Business Conduct and Ethics is grounds for discipline up to and including discharge.

The Code is a statement of policies for individual and business conduct and does not, in any
way, constitute an employment contract or an assurance of continued employment.

This code of ethics is reviewed and updated on periodical basis and published internally through official emails, hard copies, as well as on the company’s internet site.

In all internal and external relationships, the company demonstrates its commitment to Hymeri Kleemann Values:

Our Values
Customer Focus Team Work Our People are our Strength Growth Loyalty and Commitment
Our Beliefs
We care for our customers safety We respect each other We trust our employees and business partners We work hard together to grow the company We are loyal and committed to our Company and customers
We offer quality products and service as per our client’s needs We support and protect each other and work as a team enthusiastically We care for our people, we celebrate and have fun We are committed to reach our objectives We protect company resources by always thinking and acting like owners
We are fast and responsive We share knowledge, issues and good practices We proactively develop ourselves, and support development of team members Through our growth we take care of the environment We take responsibility for our obligations
We are responsible & we always keep our promises We always have friendly, open and constructive communication We strive to be innovative Our successful growth will enable us to be more socially responsible We are accountable for our promises and actions

The Company’s Ethical Principles

The company is committed to act ethically in all aspects of its business. The Company’s ethical standards are based on the following principles:

  • Honesty;
  • Integrity;
  • Fairness;
  • Proffesionalism;
  • Humanity

Similarly, Hymeri Kleemann expects the same in its relationships with all those with whom it does business.

The Company’s ethical standards focus on the following areas: employees, customers, relations with its business partners, government, society and the wider community. These ethical standards shall also apply to all business areas of Hymeri Kleemann both within and outside of Kosovo/Albania.

All of Hymeri Kleemann’s ethical standards are based on:

  • Respecting the rule of law, Kosovo/Albania laws and regulations, and showing respect for human rights;
  • Managing the company’s financial and operational performance to maximize the long-term value for its shareholders;
  • Conducting business with integrity and fairness, renouncing bribery and corruption or similar unacceptable business practices, and not giving or accepting gifts and entertainment unless they fall under business custom, are immaterial and infrequent;
  • Creating mutual advantage in all the company’s relationships to build and foster trust;
  • Demonstrating respect for the community the company operates in, as well as for the natural environment.

Monitoring of the Code of Ethics and Conducts

The respective Supervisors, the Quality Manager and the General Manager of Hymeri Kleemann are responsible overseeing and should enforce the compliance with all applicable laws, the Code, and all other Company policies.

The responsibility of the Supervisors, the Quality Manager and the General Manager of Hymeri Kleemann for the overseeing and the enforcement of this Code, in no way diminishes the responsibilities of all employees to comply with all applicable laws and all Company policies, nor does it diminish every Manager’s responsibility to ensure that the employees under his or her supervision comply with all applicable laws and Company policies.

Anyone with questions or doubts about the application of the Code or who is aware of or
suspects a violation of the Code should consult with the respective Supervisor, or the Quality Manager or CEO of Hymeri Kleemann.

Supervisors have leadership responsibilities that include the following: creating a culture of high ethical standards and commitment to compliance, maintaining a work environment that encourages employees to
raise concerns, promptly addressing employee concerns, and reporting suspected violations of
the Code.

II. Equal Opportunity Employer

Respecting One Another

The way we treat each other and our work environment affects the way we do our jobs. All employees want and deserve a work place where they are respected and appreciated. Everyone who works for the Company must contribute to the creation and maintenance of such an environment, and supervisors and managers have a special responsibility to foster a workplace that supports honesty, integrity, respect and trust.

Employee Privacy

Hymeri Kleemann respects the privacy and dignity of all individuals. The Company collects and maintains personal information that relates to your employment and your career and special care is taken to limit access to personal information to Company personnel with a need to know such information for a legitimate purpose.

Employees should not search for or retrieve items from another employee’s workspace without prior approval of that employee or management. Similarly, you should not use communication or information systems to obtain access to information directed to or created by others without the prior approval of management .

Personal items, messages, or information that you consider to be private should not be placed or kept in telephone systems, computer or electronic mail systems, office systems, offices, work spaces, desks, credenzas, or file cabinets.

Equal Opportunity Employer

Hymeri Kleemann provides equal opportunity for employment on the basis of ability and aptitude and will not discriminate on the basis of race, color, religion, sex, etc.

Sexual and Other Forms of Harassment

Hymeri Kleemann policy strictly prohibits any form of harassment in the workplace, including sexual harassment. The Company will take prompt and appropriate action to prevent and, where necessary, discipline behavior that violates this policy.

III. Compliance with Laws and Ethical Business Conduct

The activities of Hymeri Kleemann must always be in compliance with all applicable laws, statutes and regulations.

Employees occupy positions of trust and confidence. In discharging their responsibilities, each
employee has a duty to serve the Company, in good faith, in a manner that he or she reasonably believes to be in the best interests of the Company.

Employees also have duties of candor, care and loyalty to the Company. These duties include, but are not limited to:

  • The duty to protect the company property
  • The duty to use correctly and honestly the financial assets of the company
  • The duty to make a reasonable inquiry where the circumstances requires such inquiry
  • The duty to disclose all material information relevant to corporate decisions from which that person may derive, directly or indirectly, a personal or other benefit;
  • The duty to avoid and disclose any activities which could create, or appear to create, a conflict of interest,
  • The duty to avoid and disclose any activities which could create, or appear to create, a problem of whatever kind for the Company
  • The duty to act on a high standard and ethical manner with loyalty and integrity

IV. Relations with its Business Partners

The Company believes that a long-term relationship with its business partners (suppliers, clients, contractors, architechts, engineers, stakeholders, etc.) founded on respect, trust, honesty and fairness is vital to its success.

The company will respect the sanctity of contracts and business relations.

  • Contractual negotiations shall be conducted on the basis of mutual advantage.
  • Business relations shall be based on high performance standards, delivering in a timely and qualitative manner, qualitative products and services, prompt settlement of obligations.
  • In case of a commercial dispute, the Company will strive to negotiate and compromise in good faith in order to reach an amicable solution.
  • The company is committed to complying fully with the respektive law on anti-money laundering and only conducts business with reputable suppliers, business customers and other partners who are involved in legitimate business activities.

V. Confidentiality of Information

The protection of the Company’s confidential and proprietary information is of critical importance to the Company’s business and its ability to compete within the industry.

By virtue of their service to, or employment by, the Company employees will have access to confidential and proprietary Information of the Company including, without limitation, financial and actuarial information and projections, computer records and programs, contracts, customer files and lists, technical information, product information, technical development, property of Hymeri Kleemann strategies, marketing plans, personnel information, policies, strategies and other proprietary information, confidential or other non-public information regarding other companies or confidential policy or contract holder information (collectively referred to as “Confidential Information”).

All Confidential Information is the sole property of Hymeri Kleemann. The Company and all employees have ethical and legal responsibilities to maintain and protect the confidentiality of all Confidential Information.

Failure to adequately protect this information may have an adverse economic impact on the Company, and any misuse or disclosure of Confidential Information may result in violation of applicable Laws.Violations could expose the Company and/or the person involved to severe criminal or civil liability.

It is a violation of this Code for any employee, both during and after your service or employment with the Company, directly or indirectly, to use or disclose outside the Company any Confidential Information, regardless of any derived benefit, to any entity or person (including a person within the Company who does not have a need to know such Confidential Information) unless approved by your supervisor or in accordance with the procedures set forth herein.

Further, all employees must promptly deliver to the Company upon their resignation or
termination of their relationship with the Company, or at any other time as the Company may so request, all materials and all copies of materials (including computer disks) containing or evidencing Confidential Information or any materials derived from or based upon such information.

Confidentiality Agreements are commonly used when the Company needs to disclose
confidential information to suppliers, consultants, joint venture participants, or others. Such Agreements are agreed upon and signed by the General Manager of Hymeri Kleemann or other persons authorized by GM

You may not disclose your previous employer’s confidential information to the Company.

VI. Conflicts of Interest

General

Employees shall avoid employment or business activities that interfere with their duties to the Company divide their loyalty, or create or appear to create a conflict of interest, unless such employment or activities are fully disclosed to the General Manager ofHymeri Kleemann and approved in writing.

It is not possible to provide a precise, comprehensive definition of a conflict of interest. However, one factor that is common to all conflict of interest situations is the possibility that a person’s actions or decisions may be affected or have the appearance of being affected because of an actual or potential divergence between the interests of the Company and some other interest, including that person’s own personal interests. Conflicts of interest also arise when an employee, officer or director, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Company. Loans to, or guarantees of obligations of, such persons are of special concern. A particular activity or situation may be found to involve a conflict of interest even though it does not result in any financial loss to the Company and irrespective of the motivations of the person involved.

Outside Employment

The Employees of Hymeri Kleemann are expected to dedicate great energy and contribution to the company and balance the work, health and family. As such Hymeri Kleemann does not permit other employement outside the Hymeri Kleemann.

In very special occasions this might be done only with the written approval of the General Manager of Hymeri Kleemann.

Improper Personal Benefits from the Company

Conflicts of interest arise when an employee, officer or director, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Company. You may not accept any benefits from the Company that have not been duly authorized and approved pursuant to Company policy and procedure, including any Company phones and cars or financial assets for your personal benefits.

Family Members Working In The Industry

You may find yourself in a situation where your spouse or significant other, your children, parents, or in-laws, or someone else with whom you have a close familial relationship is a competitor, supplier or client of the Company or is employed by one. Such situations are not prohibited, but they call for extra sensitivity to security, confidentiality and conflicts of interest.

VII. Public Appereance

As a staff of Hymeri Kleemann, you are the ambassador of the image of the company. Hymeri Kleemann considers Company Image as very important for the success of the business. As such, the Company policy is that every employee on the company should maintain a high personal and professional image. This includes but it is not limited to:

Dress Code on the Site

Hymeri Kleemann supplies all staff on the site with appropriate clothes branded with the Hymeri Kleemann logo. These clothes are to be kept on by the employees all the time during the working hours.

If in any case the Hymeri Kleemann will not supply in time the branded uniforms, meaning that the staff should use own clothes, these clothes should be suitable to the Company image, should not contain messages and/or graphics. In all the case the dress should be clean and neat.

Dress Code for the office employees

Hymeri Kleemann requires by its employees on the office to apply a business or casual business attire during the working hours. Extra attention should be applied when formal meetings with clients are scheduled.

Personal appearance

Hymeri Kleemann requires by the staff in any level of the Company to apply the norms of the professional appearance, in every moment, regardless the justification in specific situations.

Public Appearance

Hymeri Kleemann requires that each employee apply a professional behavior and communication among each other, third parties and in public. This includes but it is not limited in professional communication face to face, on the phone, email. Professional behavior on public and non public, not engaging on unethical and unprofessional conflicts with clients or other individuals, respecting of the traffic regulation, speed limits, traffic lights when are driving a Company car.

Hymeri Kleemann requires by all staff to apply maximal respect, care and attention when carrying Company logo on uniforms, cars, etc.

Failure to respect the above policies wills results on penalties up to and including termination.

VIII. Receipt of Gifts, Favors, or other Gratuities and Remuneration

Employees must not accept entertainment, gifts or favors that could influence, or would appear to influence, business decisions in favor of any person or organization with which the Hymeri Kleemann has or is likely to have business dealings.

In order to avoid the appearance of impropriety, it is Hymeri Kleemann policy that no employee, or any member of his or her immediate family, may solicit or accept from any outside individual or business that does, or is seeking to do, business with or competes with the Company any gift of cash (or equivalent), unless approved by the General Manager of Hymeri Kleemann . Unsolicited gifts and business courtesies, including meals and entertainment, are permissible if they are customary and commonly accepted business courtesies; not excessive in value; and given and accepted without an express or implied understanding that you are in any way obligated by your acceptance of the gift, or that the gift is a reward for any particular business decision already

IX. Use of the Company Funds or Other Resources

The Company’s funds, assets, services of the Company personnel, and other resources of the Company (collectively, “Resources”) are to be utilized solely for the benefit of the Company and only for legitimate business purposes. The Company’s policy is to prohibit the use of such Resources for any purpose other than for the benefit of Hymeri Kleemann .

Employees, officers and directors should protect the Company’s assets and ensure their efficient use.

An employee who has access to Company funds must follow the prescribed procedures for recording, handling and protecting money as detailed in the Company’s manuals or other written policy documentation.

Where an employee’s position requires spending of Company funds or incurring any personal expenses later to be reimbursed by the Company, it is the individual’s responsibility to use good judgment on the Company’s behalf and to ensure that good value is received for every expenditure. Company funds should only be used for Company purposes and must not be used for personal benefit.

Personal Use of the Company Funds or other Resources

Without the prior permission of the General Manager of Hymeri Kleemann , no employee shall appropriate or authorize any other person or entity to appropriate for their use any Company Resources.

Misappropriation of any Company Resources is theft and, in addition to subjecting a person to possible criminal and civil penalties, may result in immediate dismissal or other disciplinary action.

Payments and Gifts

The Company’s Resources shall not be directly or indirectly used for any unlawful or unethical purpose.

Giving or receiving any payment or gift in the nature of a bribe, gratuity, or kickback is absolutely prohibited.

X. Corporate Records

Record Keeping

Accurate and complete record keeping is essential to the corporate well being of Hymeri Kleemann and to enable it to comply with legal and regulatory requirements, to manage the affairs of the Company, and to provide the best possible service to its clients.

The Company adheres to a strict policy of maintaining complete and accurate books and records including, but not limited to, services, repairs, change of parts and components, problem identification, offers, expense reports, expense invoices, contracts, financial reports and other business or corporate records.

The Company’s books and records must reflect, in an accurate and timely manner, all business transactions.

In order to protect the privacy of Hymeri Kleemann officers and employees and comply with state law, employees must ensure that all records containing personal data about officers, employees, are kept confidential and only disclosed to authorized parties/individuals.

Record Retention

Hymeri Kleemann retains all Company records for a undefined period of time. The desctruction of old records will be approved in writing by the General Manager of Hymeri Kleemann creating also a committee for this purpose.

The retention of the financial records will be done as per the requirement of the Albanian law.

XI. Approval of Expenses

No payment by or on behalf of Hymeri Kleemann shall be approved, made or reimbursed if any part of the payment is used for a purpose not in compliance with the Code. All proper and valid requests for reimbursement by employees shall be made in accordance with procedures the Company may from time to time adopt.

XII. Disciplinary Action and Violations of the Code

You shall promptly disclose any acts or transactions known to you that may be in violation of the Code. However, failure to report any such acts or transactions shall be grounds for disciplinary action up to and including discharge. Any person who violates the Code, or permits a subordinate to do so, shall be subject to disciplinary action up to and including discharge.

XIII. Application/Waivers

All directors, officers and other employees of Hymeri Kleemann, as well as individuals working as independent contractors, whether regular or temporary, full or part time, are subject to this Code.

The Company will waive application of the policies set forth in this Code only where circumstances warrant granting a waiver, and only with the written approval of the General Manager of Hymeri Kleemann

XIV. Discipline for Violations

Hymeri Kleemann intends to use every reasonable effort to prevent the occurrence of conduct not in compliance with its Code and to halt any such conduct that may occur as soon as reasonably possible after its discovery.

Subject to applicable law and agreements, Company personnel who violate this Code and other Company policies and procedures may be subject to disciplinary action, up to and including discharge.

XVI. Acknowledgment form

I have received and read the Code of Business Conduct and Ethics, of Hymeri Kleemann and I understand its contents. I agree to comply fully with the standards, policies and procedures contained in the Code and the Company’s related policies and procedures.

I understand that I have an obligation to report to the Corporate Compliance Officer/CEO any suspected violations of the Code that I am aware of.

I acknowledge that the Code is a statement of policies for business conduct and does not, in any way, constitute an employment contract or an assurance of continue employment.

XV. Reminder

Ultimate responsibility to ensure that we as Hymeri Kleemann comply with the many laws, regulations and ethical standards affecting our business rests with each of us. You must become familiar with and conduct yourself strictly in compliance with those laws, regulations and standards and the Company’s policies and guidelines pertaining to them.