Code of Ethics

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Contents

Foreword

I. The purpose of the Code of Ethics

II. The scope of theCode of Ethics

II. 1. Personal scope

II. 2. Temporal scope

III. Core values and expectations towards all employees, guests, and business partners

III. 1. Lawfulness and fairness

III. 2. Strengthening commitment, reliability, and loyalty

III. 3. Openness, transparency

III. 4. Protection of privacy and private interests

III. 5. Combating bribery (corruption)

III. 6. Competition

III. 7. Conflict of interest

III. 8. Safety and security

III. 9. Communication

III. 10. Employment and working conditions

III. 11. Harassment

III. 12. Non-discrimination, equal treatment, equal opportunities

IV. Further Company expectations of our employees in the workplace and, in their relationships with colleagues

IV. 1. In the course of their work, our employees should

IV. 2. Employees in their workplace relationships

IV. 3. Employees in private life should

V. Other specific conduct requirements for managers

V.1. To enforce the principles of the Code of Ethics

V. 2. For effective work managers should

V. 3. In carrying out management tasks managers should

V. 4. In their interactions with employees, managers should

V. 5. On recruitment, change of job, termination of employment managers should

V. 6. When assessing or recognising performance managers should

V. 7. In their relations with interest representation and advocacy organisations managers should

VI. Closing provisions

Dear Colleagues, Guests, and Partners,

Ethical operation has been an important element of the continued success of our company for more than 50 years.

This is a minimum standard we observe and continue to uphold in the future so that we can proudly say that we belong to the well-respected community of Danubius Hotels Zrt. 

Not only do we earn the trust of our guests and build partnerships with our suppliers with excellent professionalism, but we also create a safe environment and a supportive, retaining community of employees for all of us.

Success and integrity go hand in hand. This is what we believe, and this is what our parent company, the British CP Holdings Limited believes, too.

This Code of Ethics collects and structures the values we profess and stand for, but also ensures their accountability. It is a tool for all of us. A compass that shows the right and unerring direction to follow. 

Finally, the Code of Ethics is also a guarantee. A guarantee that Danubius Hotels Zrt. will always and in all situations stand up for those who abide by our rules. It protects them by enforcing the rules set out in it without exception and in all cases.

I trust that these core values and guidelines will strengthen the bonds between us, build trust in our business and human relationships.

Balázs Kovács

CEO

Danubius Hotels Zrt.

 

I. The purpose of the Code of Ethics

1. The purpose of issuing the Company’s Code of Ethics is

• to set out a framework of ethical standards of behaviour, based on our Company's core values, which all our employees, guests and business partners must understand and comply with;
• to let all our employees, guests and business partners know that our Company is committed to complying with the law and the Code of Ethics and that we will protect all our employees, guests and business partners against any violations of the Code of Ethics or any alleged wrongdoing;
• to deter persons who commit an offence or engage in objectionable conduct from committing the infringement;
• to prevent the wrongful conduct from happening.
  

2. This Code of Ethics summarises and defines the standards of conduct and behaviour that:

• provide a good basis for identifying ethically objectionable conduct, acceptable conduct, conduct that should be encouraged or sanctioned, as well as for impartial judgement;
• help us make the right decisions and take the right positions in the situations that arise, thus ensuring efficient and transparent operations;
• provide a moral basis for building and deepening trust in employee and business relationships;
• are consistent with the standards and requirements that guide those concerned in managing the relationships they have or wish to establish with their workplace, guests and business partners, resolving problems or managing conflicts;
• provide protection for all standard setters and contribute to the preservation of human dignity.
  

3. While this Code of Ethics does not contain standards for all possible conduct, nor does it provide guidance for all possible situations, our Company will continue to monitor and, take action against ethically objectionable conduct, whether committed by an employee, guest, business partner or any other third party, using all legal means available.

4. The present Code of Ethics does not contain provisions on offences covered by the Criminal Code

(e.g.: theft, fraud, embezzlement, bribery, etc.) or other violations of the law. Where a legal standard is stricter than those described here, it must be complied with.

II. The scope of Code of Ethics

II. 1. Personal scope

1. The Code of Ethics applies to all current and future employees, guests, and business partners of Danubius Hotels Zrt. or any other third party with whom our Company comes into contact.

II. 2. Temporal scope

1. This Code of Ethics will enter into force on 1 March 2024 and will remain in force until revoked.

III. Core values and expectations towards all employees, guests, and business partners

1. We set expectations for all areas of our organisation to comply with and enforce the Code of Ethics.

We operate a whistleblowing system as required by law, the details of which are set out in a separate policy.

2. If an employee is in doubt about the appropriateness or inappropriateness of their own or another employee's, guest's or business partner's conduct, or is uncertain about an ethical issue, they may seek prior assistance from the compliance officer, their line manager, any manager, HR staff they are in connection with, the audit or legal director or any member of the Executive Committee.

III. 1. Lawfulness and fairness

1. All our employees are expected to report any suspected or actual violations of the law that come to their attention, as set out in the Code of Conduct or other policies.

2. It is a fundamental requirement of our Company that our employees, guests and business partners are bound by the Fundamental Law, legislation, other legal instruments of corporate governance and the basic norms of social coexistence as set out in this Code of Ethics. 

3. We believe that all business is based on legality, integrity, and honesty. We provide a fair description of our services and price them accordingly. We respect the laws and regulations of the countries in which we operate, pay the appropriate public charges, and expect our business partners to do the same.

III. 2. Strengthening commitment, reliability, and loyalty

1. All employees and business partners of our Company are expected to contribute to the enhancement of our more than half a century of good reputation, the promotion and conscious communication of our values, by working in a disciplined and ethical manner and in full compliance with the law and internal rules, and in accordance with generally accepted social standards.

2. We expect our employees to use the assets, valuables, and tools entrusted to them and to make use of the professional skills, methods, and information they have acquired with due care and diligence.

III. 3. Openness, transparency

1. At our company, we believe that openness and transparency promote informed decisions, understanding, and trust. We give everyone - whether an employee, a guest, or a business partner - the opportunity to speak up if they experience something that does not seem right, to come forward with confidence against unethical behaviour without concern for any negative consequences.

2. We aim to provide a workplace, business and hotel environment that is free from any form of abusive or threatening behaviour.

3. Our Company offers protection against all forms of retaliation, so that no one in the company will be discriminated for voicing their concerns.

III. 4. Protection of privacy and private interests

1. Our company respects the privacy and private interests of its employees, guests and business partners, while expecting loyalty and openness to the group and its interests.

III. 5. Combating bribery (corruption)

1. Bribery is the act of offering, giving, promising, agreeing to, accepting, or soliciting something of value or advantage in order to induce or otherwise influence another person to act or make a decision.  Bribery may take the form of any reward or item of value offered to another person to obtain a business, contractual or personal advantage. Bribery is not limited to offering a bribe. It is also against the law for a person to stand on the receiving end of a bribe and to accept it.

2. In accordance with the Anti-bribery and Corruption policy of our owner, CP Holdings Limited, our Company has zero tolerance for bribery and corrupt activities and expects its business partners to take similar measures to prevent these from taking place.

3. The anti-corruption provisions apply to all our current and future employees, guests, business partners and all their agents and representatives. Our business relationships with our business partners is based on the principle that the parties will act professionally, fairly and in good faith in the conduct of their business. If there is reasonable ground to suspect that an employee or business partner has violated the rules against bribery and corruption set forth in this Code of Ethics, our Company reserves the right to terminate the relationship with said employee or business partner, subject to the law.

4. In view of our zero-tolerance policy against bribery and corruption, our employees must not engage in any form of bribery, either actively or passively, or through a third party (such as an agent or distributor).

5. Gifts and hospitality

To avoid bribery, our employees may accept business gifts only on a limited basis, depending on the circumstances and in accordance with the specific rules applicable to them.

Our Company will consider a customary business gift (regardless of who gives it to whom) to be acceptable if the giving or receiving of the gift meets the following requirements:

• it is in line with local legal regulations;
• it is clearly given on behalf of the business partner;
• it is appropriate to the circumstances, of the right type and value, and given at the right time, taking into account the reason for the gift;
• it is not given with the intent to influence, in exchange for an implied favour or benefit, to obtain or retain business or business advantage;
• it is non-cash or another cash substitute (e.g. vouchers or gift vouchers), excluding normal tips given to our employees directly involved in catering.

6. Facilitation payments and kickbacks

Facilitation payments are small payments (in cash or in kind) made to public officials for routine tasks that they are otherwise required to perform (e.g. to obtain permits, issue postal items or speed up the connection of utilities). Employees of our Company do not give or accept any Facilitation payments or kickbacks.

Legitimate administrative fees paid to an organisation (other than an individual) and legitimate payments made for expedited procedures, as well as payments for which an invoice can be issued on request, are not considered as facilitation payments.

7. Political contributions

Our Company will not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates as this may be perceived as an attempt to gain an improper business advantage.

8. Charitable contributions

Our Company encourages the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

Our Company will take all steps to ensure that charitable contributions are legal and ethical under local laws and practices, and that donations are not used to facilitate or cover up acts of bribery.  Donations may only be offered/transferred through the compliance officer of our company with prior approval of the compliance officer of CP Holdings Limited.

9. If any of our employees is unsure about whether something is a bribe, a facilitation payment, a gift or how to behave in relation to political or charitable donations, they can seek advice from the compliance officer.

III. 6. Competition

1. Our company conducts its business in accordance with fair competition standards and in compliance with applicable competition law. We collect information about our competitors only lawfully and use only publicly disclosed sources to acquire information about business, consumer, supplier and professional trends and actions of suppliers and competitors. We obtain this information lawfully and by fair means.

III. 7. Conflict of interest

1. Our Company believes it is important that no conflict of interest arises between its employees an in its relationships with guests and business partners, and therefore expects its employees, guests, and business partners to disclose any conflicts of interest they may encounter. Our Company is therefore in a position to take the necessary measures to remedy the situation to ensure fair business practices.

III. 8. Safety and security

1. Security must be a priority at work and in all areas of business, whether it's cybercrime, personal data or even potential dangers on working sites. We expect our employees, guests, and business partners to consider their own safety and security and that of others, ensuring the safety and security of everyone.

III. 9. Communication

1. Our company is committed to giving all employees, guests, and business partners the opportunity to share their ideas, concerns, suggestions, and feedback about our business without fear and with respect for the other party. In our communications, we will be careful and thoughtful, and we will go to great lengths to ensure that the language and tone we use is appropriate. All our business partners, guests, employees and third parties on our Company's premises are expected to behave in a courteous, polite, and respectful manner.

III. 10. Employment and working conditions

1.  Regarding employment conditions, the Company is committed to the following principles, which it equally requires from its business partners:

• Child labour is not tolerated. Employees (including those working actually in any other form of employment) must not be younger than the minimum legal age for employment or the maximum legal school age. No underage workers/students may be employed between 22:00 and 6:00. When employing under-age workers/students, the age-specific characteristics must be considered.
• We condemn all forms of forced labour.
• Physical or psychological punishment, verbal abuse and all forms of intimidation are strictly prohibited.
• Work must be performed within the framework of employment established and recognised in accordance with the applicable legislation.
• We take all necessary measures to ensure a clean, safe, and healthy working environment.
• We take special care to protect the health of our employees, and we expect our business partners to refrain from any behaviour or production processes that could have a negative impact on the health of our employees.
• We take accident and fire prevention measures to ensure that our facilities and their equipment are safe. We provide continuous and well-documented information and risk management training to our employees to ensure safety on a broader basis.
• Employees are entitled in particular, but not exclusively, to wages, paid annual leave as provided by law, fringe benefits, social security benefits and other leave and benefits provided by law. Overtime shall be paid at the legally determined rate.
• Workers must receive a certificate of payment of their wages. The payroll should be scheduled at least monthly. Our company fully complies with the legal requirements and rules on remuneration, income and all other forms of fringe benefits, and expects its business partners to comply with them.
• Our Company recognises the right of its employees to form elected organisations without prior authorisation and acknowledges that employees may be members of such organisations and may freely and independently participate in collective bargaining.

III. 11. Harassment

1. Our company prohibits, classifies as harassment, and takes firm action against any conduct that is offensive, abusive, sexual, or otherwise of a nature that is related to a characteristic of a person and is intended to create an intimidating, hostile, humiliating, degrading, or offensive environment for the individual.

2. Our Company firmly rejects all forms of conduct that are not based on mutual respect, in the knowledge that harassment occurs when our conduct offends others, regardless of its intentionality. Our company firmly rejects harassment and any form of behaviour that is not based on mutual respect.

3. Our Company has a zero-tolerance policy for any conduct by current or prospective employees, guests or business partners that is directed against employees be it:

• unwelcome sexual advances, sexual comments, emails, messages in any format or physical contact (sexual harassment);
• against all forms of insulting or degrading remarks about an individual's personal qualities, even if they are intended as a joke or light banter (verbal harassment)
• hostile and unethical communication, usually by one or more persons towards a person who is left in a vulnerable and hopeless situation (psychological harassment).

4. If one of our employees believes that he or she has been harassed by another employee, guest, or employee of our business partner, or if one of our guests or business partners believes that he or she has been harassed by one of our employees:

• can clearly indicate to the harasser that their behaviour is unacceptable, they should stop, recalling that our Company firmly prohibits all forms of harassment and that any violation of this prohibition will be strictly sanctioned within the limits of the law;
• note down what happened (date, time, place, situation, witnesses) and keep all evidence of the misconduct (e.g. documents, written conversations etc.);
• if you consider it necessary for our Company to intervene, report the incident immediately, even if you do not wish to disclose your name, through the dedicated reporting system.

5. Our Company will stand firmly by the persons who have suffered harassment, will treat his or her report strictly confidential and will provide him or her with special protection if he or she reports in good faith. No employee of the Company who has suffered any form of harassment is alone.

6. In case of harassment the person concerned may turn to the compliance officer, their line manager, any manager, HR staff he is in connection with, the audit or legal director or any member of the Executive Committee.

7. We assure all our employees, guests, and business partners that harassment cases will be investigated professionally and in full confidentiality, and that strict action will be taken against the harasser.

III. 12. Non-discrimination, equal treatment, equal opportunities

1. Our Company condemns negative, open, or implicit discriminatory treatment (act, activity, statement, omitted act, behaviour). We are firmly opposed to any form of discrimination that affects the equal opportunities of a person or group of persons.

2. Our Company considers discrimination any judgement that is made against a person not on the basis of his or her actions, but on the basis of his or her alleged characteristics or membership of a group with such characteristics. Considering that discrimination is a violation of the human dignity of all persons equally, the Company has a zero tolerance policy towards discrimination based on race, origin, social, national or ethnic origin, colour, sex, sexual orientation, marital status, parental status, childbearing status, age, disability, language, religion, political or other opinion, personal beliefs, property or other status, or any other characteristic, and expects full acceptance of all forms of discrimination against its employees, guests and business partners.

3.We are committed to the principle of equal treatment andexpect all our employees, guests, and business partners to treat all people, any group of people and other economic actors with the same respect and care, with equal consideration for the individual and without discrimination.

4. In light of the above our Company has zero tolerance towards the following conduct:

• Direct discrimination: if a person or group is, has been, or would be treated less favourably than another person or group in a comparable situation is, because of a perceived or real protected characteristic.
• Indirect discrimination: conduct which does not constitute direct discrimination, and which appears to comply with the requirement of equal treatment, and which puts persons with a protected characteristic at a substantially greater disadvantage than a person or group in a comparable situation is, was or would be in a comparable situation.
• Unlawful segregation: if, on the basis of a protected characteristic, a person or a group of persons is segregated from persons or groups of persons in a comparable situation, without this being expressly permitted by law.
• Retaliation: conduct which causes, seeks to or threatens to cause legal harm to a person who objects to, initiates or participates in proceedings for breach of the requirement of equal treatment.

5. Different treatment should in all cases be based solely on expertise and professional experience in our Company

IV. Further Company expectations of our employees in the workplace and, in their relationships with colleagues 

1. We expect our employees, regardless of their position in the organisational hierarchy, to continuously improve their professional and general knowledge, skills, competences, and abilities, and to perform their work professionally and to a high standard. All our employees must take responsibility for their actions and decisions.

2. At our company, all employees are expected to cooperate continuously, to be helpful and supportive, to build and maintain good working relationships in line with the hierarchical relationships in the areas concerned, and to be collegial in order to achieve common goals. In addition to the basic rules of social coexistence, and without being exhaustive, the following general guidelines and behavioural requirements are laid down:

IV.1. In the course of their work, our employees should

a) act in a way that is appropriate for the convincing and effective representation of the organisational goals and aspirations;

b) show their colleagues, managers, guests and business partners the respect they deserve, carry out the instructions they receive to the best of their ability and require each other to do the same;

c) behave in a manner consistent with the principles set out in this Code of Ethics and take action to address conduct that violates the Code of Ethics so that our Company can take appropriate action in a timely and appropriate manner;

d) display loyalty to the Company and its parent company, CP Holdings Limited and other members of the CP Group, as well as to its managers and employees;

e) act responsibly, reasonably, proactively and independently in the absence of clear job descriptions and in unforeseen and unexpected situations;

f) complete their working time efficiently, effectively, conscientiously and actively, meeting quality and quantity requirements;

g) act with integrity, care and good faith;

h) be aware of the importance of the tasks they have to carry out and the weight of their responsibilities;

i) keep up to date with internal regulations and legislation affecting their work and continuously strive to acquire, maintain and improve their professional knowledge, using it to the best of their ability in the performance of their duties;

j) show due consideration and courtesy to others;

k) place trust in others and earn the trust of others;

l) not put their managers, colleagues, guests, customers or partners in an unpleasant, humiliating, degrading or undignified situation, avoid personal or intrusive behaviour, or the denigration or discrediting of others;

m) display an appearance in accordance with the standards for their workplace;

n) keep their workplace and environment tidy and clean; they should consider it their personal responsibility to protect their health and safety and that of their colleagues, as well as the living and natural environment;

o) not consume alcohol, drugs or other mind-altering or psychotropic substances during working hours, and report to work well rested and free of these substances.

IV. 2. Employees in their workplace relationships

a) always strive for cooperation and joint problem-solving when carrying out tasks;

b) their formal and informal contacts should be characterised by a collegial attitude based on mutual respect, acceptance and understanding, and in the event of any interruption or breakdown in communication for whatever reason, they should endeavour to restore the expected state of affairs;

c) try to resolve their professional and other problems and disagreements related to their work and conduct in a timely manner; if this is not possible, inform their manager of what has happened, if possible, in the presence of the other party, and ask for his help in resolving the disagreement;

d) do not claim for themselves benefits or privileges beyond the agreed and regulated limits, and refuse such offers if any;

e) take care to protect each other's dignity, human and professional integrity, and remember that you are also protecting the honour of your workplace;

f) take responsibility for any wrong or inappropriate decisions or actions, do their utmost to correct or remedy them in a lawful and professionally appropriate manner, and accept and respond to valid criticism from managers and staff made as an opportunity to improve;

g) show a willingness to cooperate and provide selfless, collegial assistance to help our new colleagues integrate into the workplace; new colleagues should be actively involved in getting to know each other;

h) provide their managers, staff and other employees involved in the implementation of their professional tasks with the information they need to perform their work effectively, in a timely and effective manner;

i) do everything possible to achieve common results, to make group work more efficient, avoid competition and unnecessary rivalry where mutual cooperation, and assistance would be more beneficial.

IV.3. Employees in private life should

a) give no cause to doubt their integrity,  

b) develop their relationships in such a way that they do not conflict with their obligations at work and do not create an unprincipled conflict of interest, commitment or dependency situation that would be contrary to the law or the specific company policy on conflict of interest; 

c) not to engage in activities in their free time that are unworthy of their work or service;

d) refrain from making any ambiguous or misleading statements or information, whether written or oral, in relation to their job duties, in particular on social media and to the press/media;

e) refrain from using obscene, abusive or violent language or discrimination on certain external media (e.g. Facebook, Instagram, etc., where our name is used as an employer) or internal communication platforms (e.g. DH CheckIn) that may be associated with your employment with our Company and that may reflect badly on our Company or cause fear or distress;

f) employees of the Company may make statements to the press only in accordance with the relevant internal rules.

V. Other specific conduct requirements for managers

In addition to meeting the general standards of conduct set out in this Code of Ethics, our top management is also required to comply with the following specific standards of conduct in the performance of their duties:

V.1. To enforce the principles of the Code of Ethics

a) in the event of a suspected or actual breach of ethics, regulations or the law, to determine the necessary action in consultation with their line manager or the compliance officer;

b) to do their utmost to protect the privacy, reputation, honour, interests and confidentiality of victims of ethical or legal offences (with particular attention to victims of harassment, sexual violence and coercion as well as to minors);

c) to encourage employees under their authority to report incidents contrary to the principles of the Code of Conduct in order to enforce those principles.

V. 2. For effective work managers should

a) promote, by personal example, the development and maintenance of a cooperative, supportive, constructive and good working relationship and atmosphere in the departments under their leadership;

b) when allocating resources and assigning tasks, not abuse the power and opportunities of their position, and strive for equal workload when organising the division of labour also during cooperation with and between employees;

c) obtain the information needed to make decisions; provide other managers and employees with the information they need to carry out their work in a timely and appropriate manner; avoid withholding information, concealing information or providing information that could be misleading, in a way that could adversely affect the operation of the areas concerned;

d) encourage the development and fulfilment of talent and ensure equal opportunities for progress;

e) firmly refrain from any conduct that is contrary to this Code of Ethics and firmly uphold the core values set out in this Code of Ethics.  

V.3. In carrying out management tasks managers should

a) take responsibility for communicating and enforcing instructions issued by other managers to all employees under the manager within the organisational hierarchy;

b) in issuing tasks, orders and instructions - for the successful or unsuccessful execution of which they are responsible - strive for clarity, objectivity and the use of an appropriate tone of voice that maintains the authority of the manager without compromising the dignity and self-respect of those reporting to him;

c) seek and take into account the opinions, ideas and suggestions of their subordinates, depending on the nature of the work to be done and the possibilities offered by the situation;

d) encourage their subordinates to actively engage in planning and managing their own work by delegating a specific range of managerial functions, and to consciously exploit the benefits of creativity, self-expression, and self-realisation.

V. 4. In their interactions with employees, managers should

a) display exemplary behaviour at work and in their private lives that is worth following;

b) demonstrate an open, tactful, patient and understanding attitude when listening to and solving professional and human problems, issues and concerns of their colleagues;

c) protect their employees by all possible means against unfounded accusations, slander, harassment and all forms of discrimination; in such cases, give the accused employees the opportunity to defend themselves; if the accusations are substantiated, cooperate with the compliance officer in implementing the necessary measures or take such measures consistently after consultation with the compliance officer;

d) resolve workplace problems and conflicts with tact, empathy and care, but without hesitation or delay;

e) contribute to establishing and maintaining their trustworthiness and credibility through their honesty and openness;

f) not instruct their subordinates to work or perform activities that serve explicitly their personal goals and interests;

g) take into account the personal circumstances of their staff when unforeseen situations require extraordinary work;

h) show due social sensitivity in solving the problems of their subordinates; know and take into account their family, health, financial, existential and other - humanly reasonable - circumstances; in relation to them, observe any phenomena that indicate an unjustified change of lifestyle and do their best to solve or alleviate these problems;

i) help their subordinates who are facing difficulties; provide all necessary assistance within their competence, and, in the absence of their possibilities, initiate the Company's support for their staff in need;

j) managers should be helpful and constructive in their dealings with each other, respect each other's authority and work together with the Company's objectives in mind.

V. 5. On recruitment, change of job, termination of employment managers should

a) take into account the professional qualifications of job applicants and refrain from any form of discrimination, both in the recruitment process and in the selection decision; 

b) ensure equal opportunities for job applicants;

c) pay particular attention and care to applicants and new recruits; provide them with all the information they need to be properly informed and to help them make employment decisions and settle in as quickly as possible; 

d) consider it an important task to introduce new staff and familiarise them with their job;

e) in all cases, terminate the employment of subordinates in a spirit of mutual respect and appreciation, and do not put them in an undignified position in the event of dismissal;

f) ensure a dignified farewell at retirement and that retirees have the opportunity to keep in touch with their former colleagues, if they wish;

g) place particular emphasis on the education of young people and on ensuring the placement of students in training who are temporarily employed by our Company.

V. 6. When assessing or recognising performance managers should

a) be consistent, realistic and fair in performance-related controls, accountability, incentives and recognition;

b) strive for objectivity and fairness in their assessments, always communicating their opinions personally to the colleagues;

c) aim performance appraisal interviews primarily at developing subordinates and encouraging better results;

d) judge the work, behaviour and attitude of their subordinates on the same basis, whether it is a question of pay, rewards or sanctions;

e) focus the continuous assessment of their subordinates on performance, improvement and personal development and not on the individual.

V. 7. In their relations with interest representation and advocacy organisations managers should

a) seek agreement on contentious issues and avoid unnecessary conflict;

b) strive to cooperate with the interest representations and advocacy organisations and to establish equal partnership.

VI. Closing provisions

1. The content of the Code of Ethics must be communicated to all employees concerned through training.

2. Before hiring new employees, the Code of Ethics should be shared with new employees.

3. The Code of Ethics constitutes a part of all agreements drawn up with guests and business partners.

Budapest, April 2024