CODE OF CONDUCT

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MERCHANT CODE OF CONDUCT

 ATOZ SAVING LTD is committed to the values of partnership, integrity, and commitment in all it does. High standards of conduct are important in maintaining the trust and confidence of our clients, shareholders, others with whom we do business, and the communities in which we live and work. All vendors of ATOZ SAVING LTD are expected to conduct themselves with both personal and professional integrity.

In this Vendor Code of Conduct, the term “ATOZ” refers to ATOZ SAVING LTD and its affiliates. The term “Vendor,” “you” or “your” as used herein refers to ATOZ’S vendors, their subcontractors and their respective employees and contractors providing products or services to ATOZ.

1.     ANTI-BRIBERY AND ANTI-CORRUPTION

ATOZ does not tolerate corruption or bribery in any form, and we expect our vendors to fully comply with requirements of all applicable anti-corruption laws. Vendors will not directly or indirectly give, offer, or accept anything of value to obtain or retain business or favored treatment, to influence actions or to obtain an improper advantage for ATOZ, itself, or any third party. This includes any benefit, fee, commission, dividend, gift, cash, gratuity, services, consideration, or any inducements of any kind to any ATOZ representatives, officers, agents, or employees of ATOZ. Furthermore, vendors will ensure the same of any affiliates, retained agents, subcontractors, intermediaries, or workers. This prohibition extends not only to public officials, candidates for office, and workers of state-owned enterprises, but also to workers or officers of counter parties, clients/customers, vendors, any agent of the aforementioned parties, or any other person with whom the firm does or anticipates doing business.

2.     ANTI-COUNTERFEITING

ATOZ strives to warrant the highest quality, trustworthy products and expects the same from the Vendors. By selling with ATOZ, you agree that:

  • You shall not sell any products that are illegal for sale.
  • Selling of Counterfeit products is strictly prohibited.
  • You must provide records about the authenticity of your products if ATOZ requests that documentation.

Failure to abide by this policy may result in legal consequences.

3.     BOOKS AND RECORDS MANAGEMENT

ATOZ records include all documents and data, whether paper or electronic, that are produced or received in the course of doing ATOZ business. ATOZ has established certain record-keeping policies for document retention and destruction in order to comply with applicable laws and business requirements. You are expected to adhere to those controls and policies as communicated to you by ATOZ. You are prohibited from falsifying any record or account relating to the business of ATOZ, its clients, vendors, business partners, and employees. In addition, you must not conceal, destroy or alter any ATOZ records that are relevant to any pending, threatened or anticipated regulatory investigation or legal proceeding. Such records must be retained until the matter is finally determined and you are otherwise instructed by legal counsel for ATOZ. If you believe that any ATOZ records in your possession are, or may be, the subject of litigation, audit or investigation, you must notify and consult with a [email protected]. Failure to retain required ATOZ records may result in criminal and civil proceedings against you and ATOZ.

4.     BUSINESS COURTESIES AND PAYMENT FACILITATION

Avoid giving gifts or favors that might affect, or even appear to effect, the autonomous decision of ATOZ employees or agents.  Vendors should never feel grateful to offer gifts or entertainment to any ATOZ employee or representative or believe to receive them, even if they are of insignificant value.  Gifts and entertainment should not embarrass ATOZ and the Vendor.

Acceptable Gifts:  Gifts should be infrequent and not considerable in value e.g. (less than 100 of your local currency).  Acceptable gifts comprise such things as reasonably priced apparel or mementos bearing the logo of the business partner. Gifts must comply with the local law.  Cash or cash equivalents such as gift cards or shopping vouchers should never be given or accepted.   Gifts to ATOZ employees that violate our policies will be returned to the Vendor or handled in a manner that complies with our internal policies.

Inappropriate Payments and Illegal Conduct Bribery, Rewards and Similar Payments.  ATOZ does not pay nor accept bribes, rewards, or similar payments. We do business on the qualities of our services, not established on any form of bribery or any other corrupt or unethical business practice.  Vendors shall not offer nor accept bribes to obtain an inappropriate benefit.  Vendors are responsible for overseeing the conduct of their subcontractors and ensuring that state and local laws are not violated.

Gifts

Gifts and entertainment from Vendors are only permitted under very limited circumstances. Before offering or providing anything of value (including meals and entertainment) to ATOZ personnel, you should be certain that you are permitted to do so. A “gift” is anything of value for which a person is not required to pay the retail or usual and customary cost. A gift may include, but not be limited to, meals, products, services, travel, tickets to entertainment or sporting events, or other accommodations. Any gift or entertainment provided must be reasonable and modest, considered an accepted business practice, and legal. Please refer to the Conflict-of-Interest section of this Code for further guidance regarding gifts and entertainment

MEALS AND ENTERTAINMENT

  • Acceptable: Meals, travel and entertainment expenses as a part of business process to help create goodwill and enhance business relationships. Such invitations to meals may be extended only if such meals are business related, to hold bona fide business discussions.

 

  • Unacceptable: Any meals, travel, and entertainment expenses above $250.00 and equivalent to $250.00 after conversion to local currency requires pre-approval by our Compliance team.

5.     CONFIDENTIALITY

Confidentiality and Protection of Information.

ATOZ respects the privacy of personal information received from policy holders, clients, employees, and other individuals. Personally, Identifiable Information (“PII”) is information that can be used to uniquely identify, contact, or locate a single person or can be used with other sources to uniquely identify a single individual. Examples of PII include (without limitation) an individual’s home address and phone number, PIN number, health information, and financial information. All PII obtained by you in connection with your services to ATOZ shall be considered ATOZ’S confidential information and subject to the obligations described below. In addition, most jurisdictions have regulations relating specifically to the protection of PII. You must be familiar with those regulations and use PII only as necessary to perform your services and in compliance with all such regulations.

Without ATOZ’S prior written consent, you shall not transmit or take any PII of ATOZ to locations outside of the Canada and United Kingdom, and you shall comply with all other security and confidentiality requirements communicated to you by ATOZ in your handling of ATOZ’S PII.

6.     DATA PRIVACY

Data Protection and Privacy. We expect our vendors to protect confidential information. Vendors must adopt and maintain processes to provide reasonable protections for personal, proprietary, and confidential information, including information that they access, receive or process on behalf of ATOZ. Vendors should recognize that unauthorized use or disclosure of such information may have personal, legal, reputational, and financial consequences for the vendor, individuals whose personal information may be implicated, and for ATOZ. In addition, vendors must comply with all applicable privacy / data protection and information security laws and regulations.

7.     INTERNATIONAL TRADE MATTERS

ATOZ believes that diversity is a social and economic imperative and looks to vendors to share this commitment in their operations and within their supply chain. Vendors are expected to take proactive steps to provide a full spectrum of businesses – based on the ownership structure (for example, women owned, locally owned), scale (for example, small or medium enterprise) or nature of the enterprise (for example, social enterprise) – with the opportunity to compete on a fair and equal basis for business.

The Vendors shall update the ATOZ about any relevant restriction on the export of any product or service outside the country.

While conducting business with or on behalf of the ATOZ. The Vendors must comply with the Federal and local laws and shall not discriminate potential business partners on the basis of their race, ethnicity, nationality or religion etc.

8.     ENVIRONMENTAL SECURITY

We encourage our vendors to adhere to similar environmental efforts as appropriate to their businesses and aligned with best practices locally and globally in accordance with the provision of applicable law of the country. This includes implementing processes to identify and manage risks and opportunities related to the environment and water.

9.     LABOR & HUMAN RIGHTS

ATOZ is committed to abide by the enforced labor and human rights and believe that Vendors must abide by applicable employment standards, labor, non-discrimination, and human rights legislation. Where laws do not prohibit discrimination, or where they allow for differential treatment, we expect Vendors to be committed to nondiscrimination principles and not to operate in a way that unfairly differentiates between individuals. Vendors must be able to demonstrate that, in their workplaces:

  • Child, forced, or compulsory labor is not used.
  • Discrimination and harassment are prohibited, including discrimination or harassment based on any characteristic protected by law.
  • Retaliation for speaking up is prohibited and employees are free to raise concerns and speak up without fear of reprisal.
  • Appropriate and reasonable background screenings, including investigations for prior criminal activity, have been conducted to ensure the integrity and good character of the Supplier’s Employees.
  • Clear and uniformly applied employment standards are used that meet or exceed legal and regulatory requirements.

Armed Conflicts.

It is the duty of the Vendors to ensure that the products offer to the ATOZ do not REPEAT do not originate from sources that directly or indirectly benefit armed groups or criminal syndicates that perpetrate human rights abuses.

Child Labor.

It is the sole responsibility of the Vendors to comply with the Child Labor laws and not employ child labor and should take the necessary preventive measures to ensure that it does not employ anyone under the applicable legal minimum age of employment. Such measures include age verification systems, training for managers, and communicating with sub-vendors and Vendors on child labor issues. ATOZ fully supports and abides by the UN Convention on the Rights of the Child. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is higher. When employing workers over the age of 15 (or 14 where the law of the country permits) and under the age of 18, vendors must ensure that such employment is in accordance with the relevant law and must provide adequate protection against any conditions that may be hazardous to the health and safety of young workers.

Coerced Labor and Human Trafficking.

ATOZ does not tolerate slavery, forced labor, or human trafficking in any form and ABC will not knowingly work with vendors who engage in these practices or permit their subcontractors to engage in these practices. We expect our vendors to fully comply with requirements of applicable slavery, forced labor and human trafficking laws, including without limitation the UK Modern Slavery Act 2015 and Canada Slavery act.

Harassment and Abuse.

The employees conducting business with or on behalf of ATOZ shall be respectfully treated by the Vendors. The Vendors shall involve in any physical, sexual, psychological, or verbal harassment or abuse.

WORKPLACE HEALTH AND SAFETY LAWS.

We expect Vendors to provide healthy and safe workplaces and comply with relevant health and safety laws. Vendors are also expected to provide all their employees with adequate information and instruction on health and safety concerns and to enable their employees to meet their responsibilities for the maintenance of a healthy and safe workplace.

Wage and Benefits.

As per the applicable provision of law, the Vendors shall timely pay to their employees who conduct business for or on behalf of ATOZ. The Vendor shall not delay or withhold the compensation and payment of the employees and shall make compensation and payment as authorized by applicable laws.

Work Authorization.

While conducting business with ATOZ or on behalf of ATOZ, the Vendor must not knowingly employ persons who are not authorized to work as per the provision of law. Further to this, for the purpose of employment the Vendors must not require their employees to surrender government-issued identification, passports, or work permits as a condition of employment, and may only hold such documents temporarily for the purpose of completing legitimate administrative and immigration processing. For conducting business on behalf of ATOZ if a Vendor engage a foreigner then it is the duty of the Vendor to comply with all immigration and other provision of law of the Country where such person are employed.

10.   COOPERATION WITH THE REGULATORY AUTHORITIES

ATOZ encourages our vendors to institute effective management systems that utilize the best available techniques and practices to adhere to this Code and continuously improve their performance. This should include a process for the identification and proactive mitigation of risks associated with compliance to this Code, as well as a process for ongoing monitoring and review of risk controls, and prompt and accurate reporting of all incidents.

The Vendors shall equitably support and cooperate with the government authorities and ATOZ for conducting enquires, audit, investigation and review related to business.

11.   REPORTING VIOLATIONS

 If you came to any potential or actual violation of the Code, please make a report to our Compliance Team via [email protected]

Date April 01, 2021

 

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