INTRODUCTION

Aluminij Industries (hereinafter “Aluminij” or “we”) is committed to high standards of transparency, accountability, ethics and integrity, creating a culture where everyone feels free to speak about concerns securely and confidentially.

We are also committed to ensuring concerns are treated seriously and handled and/or investigated in a manner that protects a whistleblower’s identity.

We do not tolerate retaliation against anyone who speaks openly about conduct they believe is unethical, illegal or not in line with our Code of Business Ethics and policies, even if the concern doesn’t turn out to be substantiated, and as long as it is not raised knowing it is false.

PURPOSE

This policy is intended to inform all current and former employees and others (consultants, customers, suppliers and other third parties) of this commitment, to encourage reporting of possible violations at the earliest opportunity, and to lay out procedures for reporting and investigating complaints and the protections afforded to whistleblowers.

DEFINITION

A whistleblower is a person reporting information that he/she suspects on reasonable grounds to be about or to indicate a protected concern. A whistleblower may or may not be directly affected by a protected concern.

SCOPE OF THE POLICY

A whistleblowing concern covered under this policy include:

Although the whistleblower is not expected to prove the truth of an allegation reflected in the reported concern, if the whistleblower has evidence to demonstrate that there are sufficient grounds for concern and enough to warrant further investigation, the whistleblower is expected to produce such evidence.

This policy does not supersede the terms of any collective bargaining agreement or any other applicable law.

CONFIDENTIALITY AND ANONYMITY

A whistleblowing concern can either be made confidentially or anonymously:

Whistleblowers may submit protected concerns anonymously without disclosing their identity. However, proper handling and/or investigation is more difficult, and sometimes impossible, if Aluminij does not know the whistleblower’s identity.

Generally, whistleblower is encouraged to provide his/her name because it will make it easier for Aluminij to assess, investigate and address his/herdisclosure. If whistleblower do not provide his/her name, the investigation will be conducted as best as possible in the circumstances and whistleblower will still be protected in accordance with this Policy. Sometimes an investigation may not be possible unless enough information is provided, and it may make it difficult to offer whistleblower the same level of practical support if we do not know his/her identity.

POLICY BREACHES

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this Policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment.

POLICY REVIEW

This Policy shall be reviewed periodically.

Aluminij reserves the right to modify this policy, in whole or in part, at any time. Aluminij may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objective of good corporate governance.

 

 

INTRODUCTION

Aluminij Industries (hereinafter “Aluminij” or “we”)  is committed to protecting the privacy of its employees in all areas, but particularly in the collection, security, use and disclosure of their personal information.

Aluminij has a legal interest in processing data to ensure that our recruitment and wider HR function is legally compliant.

PURPOSE

The purpose of this Employee Privacy Policy is to set out the basis on which any personal data including special category personal data that we collect, or which employee provide to Aluminij, will be processed by us.

POLICY APPLICATION

This Policy applies to all personal information relating to potential, current and past employees, including interns and workstudy trainees, candidates for job positions and contractors.

For the purposes of this document, these persons are generally referred to as "Employees".

For the avoidance of doubt, this Employee Privacy Policy does not apply to the Personal Data of customers or other data subjects such as suppliers, customers or visitors.

SCOPE AND APPLICATION

Personal data is subject to data secrecy. Any unauthorized collection, processing, or use of such data by employees is prohibited.

Aluminij will take reasonable steps to protect the personal information held from misuse, loss and from unauthorised access, modification or disclosure. Personal information that is no longer required will be destroyed or, where appropriate, de-identified.

We store information either physically or electronically. Electronic records shall only be accessible to employees who have been issued with a personal login identification and access by Business Technology. Employees will only be given a level of access appropriate to their duties. Paper records will be housed in areas restricted to Human Resources and Payroll staff, or employees accompanied by Human Resources or Payroll staff. If these areas are unattended they will be locked.

Aluminij will only store personal information for as long as necessary for the purpose for which the information was sourced and provided and / or as required by law. In such cases, we will take reasonable steps to destroy or permanently de-identify an employee’s Personal Information.

Personal data must be safeguarded from unauthorized access and unlawful processing or disclosure, as well as accidental loss, modification or destruction. This applies regardless of whether data is processed electronically or in paper form.

Before the introduction of new methods of data processing, particularly new IT systems, technical and organizational measures to protect personal data must be defined and implemented. These measures must be based on the state of the art, the risks of processing, and the need to protect the data.

Under certain circumstances, Aluminij may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

This policy does not supersede the terms of any collective bargaining agreement or any other applicable law.

POLICY BREACHES

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment.

POLICY REVIEW

This Policy shall be reviewed periodically.

Aluminij reserves the right to modify this policy, in whole or in part, at any time.

 

 

INTRODUCTION

At Aluminij Industries (hereinafter “Aluminij” or “we”), we are led by our purpose to bring value to society, by enabling a better, safer and more interconnected world. As a fundamental part of this we commit to respecting human rights, both as an ethical obligation and as an important part of our role in society. We believe that respect for the dignity, rights and aspirations of all people is a cornerstone of business excellence.

PURPOSE

Respecting human rights enables us to live up to our purpose and to build trust.

We respect human rights in accordance with the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, and Labor law of Federation of Bosnia and Herzegovina.

SCOPE AND APPLICATION

We are committed to respecting human rights and we aim to:

At Aluminij, we respect human rights by actively seeking to avoid causing or contributing to adverse human rights impacts and to address any adverse impacts that may result from our activities. We seek to prevent or mitigate adverse human rights impacts that are directly linked to our operations, our services, and our business relationships and facilitate effective remediation when adverse human rights impacts occur.

Where local legislation and international human rights standards conflict, Aluminij will comply with local legislation, and seek ways to respect and influence positive change of international human rights standards within our sphere of influence.

We expect our business partners and other relevant parties to do the same, and to recognize and respect human rights.

Living the values of integrity and respect for people is core to the way we do business and our commitment to the protection of human rights.

POLICY BREACHES

This policy applies to all employees, officers and directors of Aluminij and its affiliated companies.

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this Policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment.

POLICY REVIEW

This Policy shall be reviewed periodically.

Aluminij reserves the right to modify this policy, in whole or in part, at any time.

 

 

COMMITMENT

Aluminij Industries d.o.o. recognises that our supply chain activities can have wide ranging social and environmental impacts and that our responsibility extends beyond our own operations, into our supply chain.

We are committed to socially and environmentally responsible procurement and have set high standards for the way we do business so our customers and other partners know we can be trusted.

Our business mindset requires that we work only with Suppliers who have the ability to consistently meet our standards and specifications and are committed to values of conduct that are compatible with our own.

This commitment is reflected in our Code of Business Conduct for Suppliers Aluminij Industries that sets out the minimum standards of behaviour we require of our Suppliers.

We ask our Suppliers to not just comply with the Code, but to use reasonable endeavours to exceed it and promote continual improvement throughout their business operations.

The United Nations Sustainable Development Goals (SDGs) invite action from the private sector to address some of the world’s most pressing development issues. Situated in a broader ethical sourcing framework, our Code is one way Aluminij Industries aligns with the SDGs.

APPLICATION AND ACCEPTANCE

The Code is applicable to all contract Suppliers and business partners, who are expected to cascade these requirements to their own supply chain.

Sustainability and compliance with this Code are part of the criteria Aluminij Industries uses during Supplier selection, and this Code is applicable to all of our Suppliers and their affiliates.

Suppliers must diligently provide official answers, documents, certificates related to sustainability as soon as it is requested by Aluminij Industries.

Adhering and signing this Code is therefore a requisite to do business with Aluminij Industries.

ASSESSMENT

By adhering to this Code, each Supplier accepts to be assessed or audited by Aluminij Industries or by a third party mandated by Aluminij Industries.

In case of violation of this Code, Aluminij Industries will determine corrective actions with the violating Supplier which can include termination of our business relationship.

QUESTIONS

Suppliers may raise any concern or questions by sending an email at the following email address:

in**@al******.com

We will provide guidance when requested.

 

 

  1. GOALS

Aluminij Industries d.o.o. has no legal responsibility for the business standards of its suppliers. However, according to UN and OECD standards, we are expected to act with due diligence towards our suppliers to avoid contributing to human and labor rights violations, environmental degradation, or anti-corruption violations within the supply chain.

Aluminij Industries defines responsible sourcing as conducting purchases in a way that enables the company to identify the risk that violations of human and labor rights, environmental protection legislation or anti-corruption legislation may occur in the company's supply chain and - if such violations are detected - initiate actions against the supplier to end the mismatch.

This document describes the key principles of responsible procurement in Aluminij Industries.

We believe that by adhering to these principles, we will not only contribute to more sustainable supply chains but also reduce commercial risk and strengthen our long-term competitiveness.

2.   SCOPE

This procedure covers all procurement activities within Aluminij Industries.

3.   LIABILITY

The senior management of the Company is responsible for updating this policy.

The Sales Department, the Procurement Department and the Legal Department are responsible for being guided by the principles of this policy.

4.   DESCRIPTION

4.1. PRINCIPLES FOR RESPONSIBLE SOURCING IN ALUMINIJ INDUSTRIES

Responsible sourcing in Aluminij Industries involves risk-based engagement with suppliers, meaning that efforts should be directed toward the product categories and suppliers that pose the greatest risk. Aluminij Industries is dedicated to continuous improvement, both in terms of setting internal goals and in terms of expectations for suppliers to achieve progress.

4.2. SUPPLIER REQUEST

Aluminij Industries Code of Business Conduct for Suppliers describes requirements for suppliers in relation to management and ethics, labor and human rights, occupational health and safety, and the environment. This Code should be communicated to all suppliers with a special focus on risky suppliers. Suppliers should be encouraged to present the same type of requirements to their suppliers.

4.3. RISK EVALUATION

Aluminij Industries will carry out a risk assessment of its suppliers to identify suppliers that may pose a risk of non-compliance with the requirements presented in Code of Business Conduct for Suppliers.

Supplier evaluation will be conducted according to our supplier evaluation procedure which includes the “Supplier Evaluation Form”. The supplier's risk assessment will be carried out based on the specified form. It will be categorized as low risk, medium risk or high risk. Suppliers that are assessed as medium or high risk suppliers should be subject to a more detailed risk assessment.

4.4. REACTIONS TO VIOLATIONS OF THE CODE OF BUSINESS CONDUCT FOR SUPPLIERS

The purpose of responsible sourcing is to use our purchasing power to better influence supplier business standards. Therefore, when violations of the Code of Business Conduct for Suppliers are discovered, the contract with the supplier should not be automatically terminated, even when the contract gives us the right to do so. Instead, the company will assess the severity of the breach. The usual response to non-compliance should be to follow up with suppliers through requirements, dialogue, and guidance.

Suppliers who do not meet our requirements will demonstrate a willingness to comply by documenting improvements within a specified timeframe. In case of a serious breach of requirements or lack of progress over time, the contract should be terminated. Risk issues associated with complex supply chains, such as for commodities, should be addressed on a case-by-case basis. Potential actions may include product certification, collaborative projects with other industry players, or government dialogue.

 

 

 

Aluminij Industries d.o.o. is dedicated to the development of the community in which we work. We consider it our duty to be drivers of development and initiators of the modernization of society, while at the same time respecting the environment and the society in which we live.

We stand for open communication, development and compliance with the requirements of the SA 8000 standard. The fundamental approach to social responsibility is respect for the rule of law and legal obligations. We respect national and international instruments and their interpretation.

We strive to provide a pleasant working environment for our employees by understanding their wishes and needs. We encourage suppliers and other legal entities (companies) and individuals with whom we cooperate to support social responsibility guidelines.

We believe that the success and sustainable development of Aluminij Industries comes as a result of the organization's ability to achieve its goals in the long term, while paying attention to the needs and expectations of all interested parties alike: customers and consumers, workers, owners, suppliers, partners and the wider community.

We have identified eight areas of special interest:

We have decided to fulfill the applicable requirements from the SA 8000 standard and the requirements of national labor laws.

Copies of this Policy are displayed in visible locations within the company's workplaces and are communicated to all employees, as well as the public and other interested parties upon request. The adequacy of the policy is reviewed periodically, and changes must be approved by the company's director before publication.

The company director is responsible for reviewing the adequacy, appropriateness and effectiveness of the SA 8000 social responsibility policy, procedures and results at least once a year.

To maintain the policy and fulfill the applicable instructions of this standard, we have selected a management representative for management systems.

 

 

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter "Aluminij Industries" or "we") is responsible for approving the sustainable development policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business, including suppliers, associates, and contractors.

PURPOSE

In order to protect our planet as best we can, our task is to follow an ambitious sustainability strategy with a strong focus on CO2 emissions and on the transparency of our operations and rational management of resources. We work closely with our partners to analyze each phase of aluminum production and to identify new opportunities and share data together with our experts, which ultimately results in more acceptable solutions for the entire community in which we operate. In this way, we continuously strive to be efficient and productive, bearing in mind the environment in every step of the process, and we actively implement our process management in accordance with legal norms and international conventions, which is verified by globally recognized certificates.

We do all this with the aim of creating a circular society that not only benefits our customers, but also provides the necessary resources for future generations.

Aluminij Industries aims to achieve the best possible achievements in the field of environmental protection and quality in all segments as well as in the field of health and safety at work in order to achieve the best possible safety of employees, associates and our visitors.

Taking responsibility for the implementation of the principles of sustainable development in regular business is manifested by supporting generally applicable principles in the areas of employment and work, ethics, biodiversity and environmental protection, health and safety at work, and quality and related leadership and management systems.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

 

 

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter "Aluminij Industries" or "we") is responsible for approving the energy and climate policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business or are our partners, including suppliers, sellers and contractors.

PURPOSE

It is our responsibility, and at the same time our focus, that resources are used as carefully and conscientiously as possible. This philosophy shapes everything we do. Aluminij Industries produces aluminum logs, small ingots and aluminum blocks which, apart from their shape, also differ in terms of production and energy requirements. Light, durable and infinitely recyclable, aluminum as a material can help solve many global energy and climate challenges.

The aluminum industry on a global level continuously introduces innovations in technological processes in order to reduce energy consumption and therefore carbon production, which has a direct impact on reducing environmental pollution in terms of impact on air quality and flora and fauna. It can be safely concluded that aluminum, as an industrially usable potential, has its important place in creating a greener future, in which Aluminij Industries also found its important place. Mostar.

The overall importance in contributing to environmental protection, and thus to the prevention of negative climate change, is the use of green energy. Namely, our company uses CNG – compressed natural gas as an energy potential and electricity that is entirely produced from green sources, regularly monitoring emissions of harmful gases into the air in accordance with legal obligations. In addition to all that, Aluminij Industries continuously works on the rationalization of energy consumption, which is the focus of the activities of all our employees, and therefore the entire team.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

 

INTRODUCTION

Aluminij Industries d.o.o. (hereinafter “Aluminij Industries” or “we”) is responsible for approving the recycling and circular economy policy for all employees and companies under M.T. Abraham Group, who were engaged with the common goal of creating a work environment that supports the aforementioned policy.

This policy applies to our entire organization and those with whom we do business or are our partners, including suppliers, sellers and contractors.

PURPOSE

Recycling is essential for modern business with materials such as aluminum and provides raw material for the same supply chain. Recycled or secondary aluminum is about 95% less energy intensive to produce than new or primary aluminum. Aluminum, as a material, can be endlessly recycled. This is why, according to estimates, 75% of all aluminum ever produced is still in use today.

Aluminum cans can serve as a striking example, since they are the most sustainable type of beverage packaging in almost every respect. With better recycling rates and a far greater proportion of recycled material than glass or plastic, aluminum cans are a tailor-made product that enables a highly circular economy in the industry in which they are used.

It is very important to emphasize that aluminum does not lose its original properties through recycling and that it has a high internal material value. These are the reasons from which it follows that it is also profitable from an economic point of view to return aluminum to the circular cycle consisting of decomposition, separation and reuse. One of the great advantages of aluminum is that it can be recycled extremely easily and efficiently, and in a way that does not impair its quality. In addition to favorable mechanical properties with excellent reshaping, light weight and resistance to corrosion, aluminum is a material that, compared to other metals, has a significantly lower impact on the environment.

Environmental protection and preservation of natural resources are the focus of Aluminij Industries d.o.o. which, considering the increased production on a global level with the simultaneous reduction of raw material stocks, is considered a commendable commitment.

In order to establish a line of sustainability, the best way is to form a circular business model that ensures the reuse of resources. Aluminum as a material fits perfectly into this – it retains its qualitative properties even after an unlimited number of recyclings. Namely, the entire production of logs, blocks and small ingots, which are products of Aluminij Industries, is based on the principle of recycling, i.e. aluminum products that have already been used as raw materials.

We want to initiate and support the recycling of aluminum packaging, but achieving this goal requires a comprehensive, responsible and reasonable consumer culture of recycling. The entire recycling agenda fully fits into our Company’s clear commitment to environmental protection and the preservation of natural resources.

VIOLATION OF POLICY

Violation of the law, this Code of Conduct or Aluminij Industries policy has appropriate consequences, including potential termination of employment. Failure to report knowledge of a breach, attempting to prevent a colleague from reporting a breach and falsely reporting a breach may also have consequences. All criminal offenses are reported to superiors.

POLICY OVERVIEW

This Policy is periodically reviewed and may be updated.

As a member of European Aluminium association we are resolute to follow it’s lead in aiding European Union and it’s policy makers on developing proposals and providing evidence and information of aluminium collection and recycling in the chain of aluminium. In accordance with EU regulation for reducing CO2 emissions the demand for recycled aluminium products is increasing. Before recycling the aluminium scrap has to be sorted and organized into alloys, thus the material which is already sorted is harder to source in the market.

Part of Aluminij Industries strategic goals is a construction of Scrap Aluminium Sorting Line, which will ensure controlled intake of aluminium scrap into production. We shall encourage local and regional scrap collection systems, with an aim to increase the recycling rates for end of the life product which are produced either out of or with aluminium.

We believe that an overall increase of scrap collection is beneficial to all members of the aluminium chain of supply, both downstream and upstream.

Our efforts will be aimed to educate and include our customers on collection and recycling of aluminium.

These strategies of recycling shall be revised annually.

 

 

INTRODUCTION
The maintenance of high ethical standards in adhering to national and international laws is one of the fundamental Aluminij Industries (hereandafter „ Aluminij“ or „we“) Principles.

Competition laws – also referred to as antitrust laws – are designed to protect competition. They prohibit business behaviour which has the objective or the effect of preventing, restricting or distorting competition. It is the belief of the management that even in the absence of such laws, the interest of the Aluminij, its employees and other are best served by the principles of free market economy and fair competition. For these reasons, it is the policy of the Aluminij to comply strictly, in all respects, with competition laws.

PURPOSE

As a company with worldwide business activities, Aluminij is subject to the competition and antitrust legislation in many jurisdictions. Although country-specific legislation is different in application, the underlying principles of anticompetitive behaviour are similar and the guidelines provided below highlight these behaviours.

This Policy is designed to make both management and employees aware of the basic rules, and how these rules affect their business behaviour in making commercial decisions.

This Directive cannot cover all facts and circumstances that may encounter in business activities. Accordingly, it is strongly recommended and expected that in every case of doubt or in any instance where an employee has a question as to whether a particular course of action is appropriate or not, should contact the legal department for advice.

This Policy sets out Aluminij approach to ensuring that we fully comply with competition laws applicable to our business activities and that we appropriately manage associated risks.

We are committed to competing fairly across our global operations and do not engage in practices that restrict fair market competition.

We are aware that the greatest risks occur when dealing with competitors, in particular through commercial agreements, coordinating strategy or exchanging sensitive information.

Competition laws aim to protect consumers by promoting free, undistorted competition between companies, protecting independent decision making of market participants, and preventing the misuse of market power.

In certain circumstances, agreements with competitors may be considered permissible when their restrictions to competition are outweighed by efficiencies, e.g. improvements in technology or production. Examples of such arrangements are Joint technical or quality control standards or Joint research and development ventures.

When employees are proposing, or invited to participate in, any arrangement with competitors, they must inform and consult with their Legal Department immediately and before the event.

We do not discuss or share commercially sensitive information with our competitors unless there is a legitimate reason, as this can of itself be a hardcore breach of competition law. We do not share detailed current and future pricing, cost and volume information and future strategy and investment plans, as this type of information is particularly high risk.

We do not share high risk information with our competitors.

We must inform Legal if we receive, or are asked to share, this type of information with a competitor.

Particular risks arise when the supplier, customer or agent is also a competing producer. We must not enter into agency or marketing agreements with competing producers without consulting Legal.

The obligation is on each employee to bring to the attention of the Legal Department as soon as an employee suspects that a transaction or activity may be viewed as anticompetitive promptly and before any action is taken on behalf of the Company, circumstances which may have anticompetitive implications.

POLICY BREACHES

We look out for certain clauses which are considered hardcore breaches invertical agreements and which attract significant penalties.

Failure to address the risk of anti-competitive practices may undermine our reputation and lead to investigations, fines and/or other penalties for the company and/or individuals.

POLICY REVIEW

This Policy shall be updated from time.

 

 

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