CORPORATE, GOVERNANCE, ETHICS AND COMPLIANCE

Conducting our business honestly, ethically, equitably and fairly, based on integrity, transparency and accountability is one of Avraz Group’s core values.

For that purpose, Avraz Group adopted a code of conduct, which provides a general statement regarding the Group’s expectations as to the legal and ethical nature of business conduct of its directors, officers, employees and representatives, while acting on its behalf.

It is the personal responsibility of each director, officer, employee and anyone acting on behalf of the Group to adhere to the relevant standards and restrictions and to avoid any activities which may involve the Group in any act which is not in compliance with applicable laws or its code of conduct.

Avraz Group operates worldwide, under various legal and regulatory regimes, and as such, is required to fully comply with applicable laws related to the prohibition of bribery. Among others, the Group is subject  to Israeli law, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the "OECD Convention"), as well as other laws in territories where the Group operates, strictly forbidding to give or offer any bribe to a public official.

The Group attaches utmost importance to prevention of bribery, kickbacks and corruption in all its business activities, and in the actions of anyone acting on its behalf, at all echelons of business.   

In line with the above, Avraz’s board of directors has determined to adopt anti-bribery and anti-corruption compliance program with zero tolerance for any acts of corruption and/or bribery. The program is obligatory for its executives and employees, all Avraz subsidiaries and affiliated entities and their employees, as well as third parties doing business with the Group. The Compliance Officer is a company’s officer reporting to the CEO.

This program sets out Avraz's standards on anti-bribery and anti-corruption compliance. It provides an overview of handling various red flags and the scenarios to be alert for, reporting requirements, and directs when and how additional guidance should be sought from the company’s dedicated functions. Among others, it outlines manner of conduct for all ELUL's executives and employees in cases of hospitality, entertainment or gift giving to third parties, donations and more. The program also sets records and books keeping requirements, which ensures accurate, proper and fair reflection of all business and financial activities of the Group.