Ethics and Compliance


The impeccable business reputation is our key intangible asset and strategic resource for development that fosters our success, profitability, and agility. We support the ideas of virtuous, ethical and responsible business conduct.

As an international public company, we are building a compliance system in accordance with the best international practices and requirements of the jurisdictions in which our subsidiaries operate. By strengthening the compliance function step by step, we strive to maintain and increase confidence from counterparties and partners of our company, as well as to strengthen our position in the market.

In order to improve the risk management process, in addition to the compliance department, the company formed a Compliance committee, consisting of professionals with high competence and knowledge in the field of compliance, risk management, finance, legal issues, anti-corruption requirements, personnel management and compliance with human rights, environmental protection and data security. This allows the company to perform a comprehensive risk assessment and build a strategy for the development of the compliance function in accordance with the needs of the company and its stakeholders.

CODE OF CONDUCT

One of the key elements of the compliance culture in Astarta is the Code of Conduct based on the Global Principles of Business Ethics of the Food and Agriculture Organization of the United Nations (FAO UN), the UN Global Sustainable Development Goals 2030, the Paris Agreement, the Declaration and recommendations of the International Labor Organization.

Astarta is a team of like-minded people, and conducting business based on the highest ethical standards is our common position, shared by all employees.

TRUST LINE

Astarta encourages a culture of openness, transparency, and partnership and fosters a culture of zero tolerance for fraud and corruption by maintaining a dialogue with employees and partners based on trust and mutual respect. 

The Trust Line is a software product used by Astarta and maintained by Ethicontrol, an external contractor, which guarantees complete anonymity and impartiality of the registration of reports and the confidentiality of information received from the whistleblowers. 

A whistleblower, i.e. a company employee, individual or representative of a legal entity, can report concerns, known violations, make suggestions regarding the company’s activities, or provide other feedback on the experience of cooperation with Astarta without hesitation.

You can contact the Trust Line in the following ways:

  • via a secure web portal at the link: astarta.ethics.help
  • by calling 0 800 357 194. Calls are free of charge from all mobile operators and are received on business days from 09:00 to 18:00. After hours and on weekends, you can leave a message on the answering machine;
  • send a letter by e-mail to [email protected] or by post to: 58 Yaroslavska St., Kyiv, 04071, Ukraine, Astarta-Kyiv LLC, Trust Line communication channel.

MANAGEMENT OF CONFLICTS OF INTERESTS

Astarta sustains transparent and trustful relations with its employees. We support aspirations of our employees for professional development and do not limit their right to interests outside of their professional activity, however, we check that such interests do not lead to a conflict of interest that could negatively affect the company’s business.

For this purpose, Astarta has implemented the Regulation on Management of Conflict of Interest, that defines the criteria and situations of the conflict of interest, required actions in the event of its occurrence, and also describes the procedure for the annual declaration of the conflict of interest by employees. The Regulation is applicable to all employees, regardless of their position and work function.

Due attention to the management of conflict of interest and related risks contributes to boosting confidence among counterparties and business partners whilst ensuring the fulfillment of the company’s long-term obligations, as well as protection from reputational and financial risks.

SANCTIONS POLICY

In connection with the increasing role of the international sanctions policy, especially against the background of an armed aggression against our country, the introduction of the national sanctions and amendments to related laws, Astarta developed and implemented the Sanctions Policy, that allowed to establish the criteria and conditions of cooperation with counterparties, checking their possible exposure to international and national sanctions, and participation in collaborative activities.

The Sanctions Policy aims to preserve the impeccable reputation of the company, avoid any cooperation with counterparties under international or national sanctions, related financial, operational, and other risks, as well as to ensure continuity of business processes.

COOPERATION WITH COUNTERPARTIES AND BUSINESS PARTNERS

Astarta is a reliable business partner. We build business relations on mutually beneficial terms and fulfill our obligations in full. We highly appreciate and respect our counterparties and partners, therefore we promote high ethical standards in our business and act exclusively within legal grounds.

We appreciate that our success is closely related to the success of our business partners, therefore, we are interested in mutually beneficial cooperation, we constantly improve our business processes, increase the quality of our products, introduce the latest technologies, and enroll highly qualified employees.

We focus on establishing long-term business relationships, so it is of importance who we work with. We respect business reputation of our counterparties and business partners, practice zero tolerance for corruption and pay due attention to the identification and assessment of sanctions risks.