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Company's Code of Ethics

  1. Introduction
  2. Compliance with Laws and Regulations
  3. Conflicts of Interest
  4. Records Management
  5. Employment Practices and Policies
  6. Harassment and Discrimination
  7. Health and Safety
  8. Use of Company Assets
  9. Confidential Information
  10. Customer Policy
  11. Choosing Suppliers and Consultants
  12. Cooperation with Governmental Authorities
  13. Corruption
  14. Gifts and Entertainment
  15. Political Activities and Contributions
  16. Environmental Responsibility
  17. Reporting of violations



1. Introduction

Under our Code of Ethics, we seek to conduct our business in accordance with the highest standards of business ethics at all of our locations throughout the world, and we encourage employees to bring ethical questions to management's attention so that we can maintain our high standards.

The common values of high business ethics that have characterized our approach to business in Bulmar Consult throughout our history demand high professional standards, place a premium on honesty and fair dealing in relationships with our customers, suppliers, employees and other persons with whom we have business relationships, and anticipate that we will compete vigorously and fairly in the markets we serve and comply with laws that affect our business.

The Code of Ethics also reinforces our commitment to the spirit and practice of equal employment opportunity and the benefits of a diverse workforce.


2. Compliance with Laws and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which our ethical standards are based. We believe that employees who obey the law and abide by high ethical standards are also more productive. Failures to obey legal or ethical standards can also cost the company money in legal fees, fines, penalties, sanctions or the opportunity cost of management and other employees’ time spent addressing such failures. Each employee of Bulmar Consult has an obligation to comply with the Bulgarian laws and the laws of the foreign countries in which we operate. We will not tolerate any activity that violates any laws, rules or regulations applicable to us or our employees or representatives.


3. Conflicts of Interest

Every employee has a primary business responsibility to Bulmar Consult and must avoid conflicts of interest. A conflict of interest arises when an employee takes actions or enters into relationships that oppose the interests of the Company or interfere with the employee’s performance or independent judgment when carrying out his or her duties. The Company strictly prohibits its employees from taking any action or entering into any relationship that creates, or even appears to create, a conflict of interest without the prior approval of a supervisor. For purposes of determining whether a conflict exists, the actions of an employee’s immediate family members are treated as those of the employee and are therefore subject to the same considerations.


4. Records Management

In the proccess of work we create or prepare some type of information during the workday, such as financial reports, accounting records, business plans, contracts, offers and expense reports. People inside and outside Bulmar Consult depend on these reports to be accurate, truthful and properly maintained. These people include employees, customers, government representatives, auditors, and the communities in which we operate. No one may deviate from our commitment to manage information accurately and truthfully.


5. Employment Practices and Policies

The succeed of Bulmar Consult is a result of our employees proffesionalism. Our ability to compete effectively in existing markets and to expand into new ones is directly linked to attracting and retaining the best and brightest employees. Understanding this, we pursue fair employment practices in every aspect of our business.

Apart from the fair financial salaries and bonuses that our employees receive for their job, we are commited to to an excellent environment in which they can develop their personal and professional skills. To support this environment and practices our managers should take objetive decisions when determining the pays and stimulus of the employees, based on criteria like quality and quantity of the performed work, loyalty to the company, skills and attitude against the work.



6. Harassment and Discrimination

All people deserve to be treated with respect.

This is why, our employees will not engage in any harassment or discriminatory conduct based on race, religion, sex, age, national origin, sexual orientation, disability, citizenship. Harassment is not always overt or deliberate. In many cases, it is subtle. Our commitment applies to all people, regardless of whether or not they are Bulmar Consult’s employees.  It is our policy to maintain a work environment free from discrimination and sexual advances or harassment that may affect an employee’s terms or conditions of employment.


7. Health and Safety

We’ve taken great care in developing Bulmar Consult’s health and safety regulations and risk assessment, based on the requirements and standards of Bulgarian law, so that we can provide the foundations of a safe, secure and free of danger work environment. This is why our employees are required to comply with all applicable environmental, health and safety regulations of the Company and always participate in the regular trainings.


8. Use of Company Assets

Employees and managers should seek to protect Bulmar Consult’s assets. Theft, carelessness and waste have a direct impact on the Company’s financial performance. Employees must use the Company’s assets and services solely for legitimate business purposes of the Company and not for any personal benefit or the personal benefit of anyone else. However, limited reasonable use for personal interests of company assets such as computers, e-mail, mobile phones, etc is permitted. But any use of such items for personal business use or illegal or immoral activities may result in the termination of the employees, contract. Since the afore-said items are owned by Bulmar Consult, the Company shall have the right from time to time to randomly or for cause to access or monitor these items, and the employees and managers hereby expressly provide their consent to such actions. All employees must advance the Company’s legitimate interests when the opportunity to do so arises.


9. Confidential Information

We are committed to free and open competition in the marketplace. Employees must avoid actions that reasonably could be construed as being anti-competitive, monopolistic or otherwise contrary to laws governing competitive practices in the marketplace, including government and antitrust laws. No employee may obtain or give competitive information by unethical, unlawful or illegal means. Employees must refrain from using any confidential information belonging to any former employers.

Further, it is improper to make false or deceptive statements concerning a competitor company. If you are in a position to speak on behalf of Bulmar Consult, you must ensure that your statements are based upon current, accurate data, and you should refrain from commenting on another company’s business reputation or financial or legal situation.

10. Customer Policy

The success of Bulmar Consult and our customers is reciprocal. By providing our customers with products and services of superior quality and value, delivered on time and at fair prices, we gain their respect and loyalty. Remaining committed to both quality and value in current and future products helps us gain and keep a clear competitive edge. This is a commitment that must be shared by each and every one of us to ensure that we are successful. We must also continue to improve and keep open the lines of communication with our customers. This is central to our strategy of offering customers broader solutions that completely satisfy their requirements. Communicating involves professionalism both in how we obtain critical information from customers, as well as in how we respond to that information within Bulmar Consult.


11. Choosing Suppliers and Consultants

We strive to be fair in our choice of suppliers and consultants and are honest in all business interactions with them. We choose our suppliers and consultants based on appropriate criteria, such as qualifications, competitive price, and reputation. Anyone responsible for buying or leasing materials or services on behalf of Bulmar Consult must conscientiously guard their objectivity.

We also expect our suppliers and others who do business with us or on our behalf - to conduct their business on behalf of Bulmar Consult in compliance with all applicable laws and regulations and in accordance with the highest ethical standards.


12. Cooperation with Governmental Authorities

We at Bulmar Consult understand the importance of keeping good relations with the governmental authorities. Cooperation on all levels is important, so all problems can be resolved in the quickest way possible. Having this in mind, our company makes no attempt to illegally influence the resolutions of the governmental authorities or their representatives and officials, follows all the laws and requirements, applicable to its activity, stays true to the letter and to the spirit of laws and pays taxes in full and on time.


13. Corruption

Bribery or the offer or payment of money to public officials is absolutely prohibited. Bulmar Consult employees should not offer directly or indirectly anything of value to companies or government authorities, to obtain an improper advantage, or to retain or obtain business.  Because Bulmar Consult’s business partners (vendors, suppliers,clients, consultants, etc.) may also be required to comply with these laws, employees should exercise due diligence in selecting the company’s business partners and should avoid relationships with parties with a history of corrupt practices.

Because of the complexity of the laws, and the severity of the consequences for violations of the anti-corruption laws, the managers should be consulted in advance for advice on dealings with company and government officials.



14. Gifts and Entertainment

Business gifts and entertainment are courtesies designed to build understanding and goodwill among people in a business relationship, and in some cultures they play a very important role. Problems arise when they compromise — or even appear to compromise — the recipient’s ability to make objective and fair business decisions or when they are contrary to applicable laws. Directly or indirectly offering or receiving any gift or entertainment that might be perceived to improperly influence a business interaction violates our commitment to maintaining objectivity and transparency in our relationships. All gifts, entertainment and business travel provided to or by third parties must be moderate and reasonable.


15. Political Activities and Contributions

Bulmar Consult encourages all its employees to be informed voters, but personal participation in the political process, including contributions of time or financial support, is completely voluntary.

As private citizens, employees may participate in the political process, including contributing to the candidates or political parties of their choice. However, such personal political activities or contributions must not involve or even appear to involve use of Bulmar Consult funds or resources. Employee work time also is considered a contribution by Bulmar Consult. Therefore, employees cannot be paid by the company for any time spent campaigning for a political party.

The company requires that all employees must inform the managers in case they support a political party so that a possible conflict of interest can be prevented.



16. Environmental Responsibility

We work to comply with all applicable environmental standards established by governmental agencies in the locations where we operate and with Bulmar Consult policies and procedures. Any violation of environmental law, regulation, or policy by the Company personnel or others acting on our behalf must be reported to the Environment Health and Safety Department immediately.


17. Reporting of violations

We are committed to creating a working environment in which employees can and do behave in the right way.  We expect employees to raise with their line manager, or where they are uncomfortable doing so, with their next up line manager, any concerns they may have of serious wrongdoing or behaviour that is not in the letter or spirit of our values or our Code of Ethics.

Compliance with our Code of Ethics is a basis for good working relations between the employees and Bulmar Consult.

Bulmar Consult

West Industrial Area - South, Bulmar Building
Varna, Bulgaria, PO BOX 260

T +359 (52) 55 41 61
F +359 (52) 55 41 60

bulmar@bulmarconsult.com

© 2010 Bulmar Consult Ltd. All rights reserved