CODE OF CONDUCT

Our Governing Objective is to grow as a multi-regional, vertically integrated cement producer, combining an entrepreneurial spirit and operational excellence with respect for people, society, and the environment.

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Ever since its incorporation in 1902 TITAN has been lead by the belief that business can combine competitiveness and efficiency with ethical principles and sensitivity to society’s needs.

TITAN Bulgaria, like all TITAN subsidiaries, has dedicated itself to following the TITAN values and principles and conducts its daily business in full compliance with the TITAN Group Code of Conduct.

"TITAN Group’s evolution over the past decades has taken us across geographical and cultural boundaries, yet the overarching Values established by our forbearers live on to guide us through ever-changing circumstances. As we continue on our journey, it is imperative that we provide clear guidance with respect to proper business conduct and ethical behavior to the people who represent us in carrying out their daily duties in many parts of the world. Our multi-regional business model allows us to rely on local management to best serve the needs of all our stakeholders with due recognition of local cultures. However, this freedom to manage and make decisions requires employees to operate at the highest levels of transparency, honesty, integrity and responsible behavior. It is with these principles in mind that we set forth in the following pages to establish common guidelines that are core to ethical business conduct throughout the Group.

With this Code of Conduct, we provide a statement of operating principles to help each of us understand what is expected, as we do our individual jobs every day. It is not exhaustive, and most companies within the Group will already have in place detailed procedures and systems to meet their local requirements. Where there is any doubt or when we face unusual circumstances, we should always seek a second qualified opinion. This Code should be viewed by all as a commitment by Group Management and all employees to achieve excellence in the way we do business, by adhering to the highest standards of corporate and social responsibility. A prerequisite for our commitment to these principles and Values is that we take the time to read the Code of Conduct carefully, review our actions in light of its guidelines and ensure that it is fully understood and implemented by all of us, the TITAN employees. To the best of our abilities, we shall also use our influence to promote the above principles to our contractors, suppliers and business associates. Your support is essential in making this Code a key tool in promoting the well-being of our businesses and all employees."

D. Papalexopoulos
Group CEO

Our strategy is driven by our aspiration to do the right thing. To ensure that we conduct our business with respect, accountability and responsibility, we have developed a series of group-wide policies that help every person at TITAN make the right decisions. Below you can discover more about our aims through our policies.

Anti-Bribery and Corruption Policy

Our Anti-Bribery and Corruption policy aims to ensure compliance with the respective rules prohibiting bribery and corruption. The policy applies to all TITAN Group employees, representatives and agents, all of whom are expected to follow the highest standards of professional and personal conduct at all times.

Dealing with a range of issues related to bribery and corruption, our policy complies with all applicable laws and contains TITAN Group’s global standards.

TITAN complies with all applicable anti-bribery laws, including the US Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA), and the local laws in every country in which we do business.

Competition Law Compliance Policy

Our Competition Law Compliance policy and guidelines aim to ensure compliance with competition laws in every country where we operate. The policy and guidelines place responsibility on all business units and entities controlled or managed by the TITAN Group, as well as every TITAN employee, to treat all customers and suppliers fairly, equally and openly.

The policy guides employees through the fundamental principles of competition law and helps identify solutions where relevant issues may arise. Additional to it, several guidelines are provided, which give an overview of key competition law provisions and indicate the types of conduct that might give rise to antitrust issues. TITAN employees are also required to obtain expert advice when faced with issues involving competition laws or when in doubt about compliance.

Corporate Social Responsibility (CSR) Policy

Our Corporate Social Responsibility (CSR) policy establishes a framework for pursuing our business goals in a socially responsible manner and contributing to the wellbeing of our employees and their families, the sustainability of the communities we work in, and society at large.

CSR is a core TITAN value, and our commitment to making a positive impact on the world around us goes beyond legal and regulatory compliance. Our policy also aims to add value to our business by promoting good business practices, enhancing our reputation, strengthening our license to operate and improving our competitiveness.

We aim to proactively and continuously improve in this area and adapt to an ever-changing business and social environment creating sustainable value for all. Essential to this is listening, engaging, communicating and building mutual trust with our stakeholders.

Environmental Policy

Our Environmental Policy reflects our commitment to sustainable development and our approach towards addressing the challenges and opportunities of climate change.

Main elements of our environmental policy include: assessment impacts, quarry rehabilitation, protection of local biodiversity, conservation and stewarding of water resources, resource recovery and managing waste, creating an environmentally responsible culture with our business partners and embedding innovation in our strategy.
The policy also encompasses our priorities under the Climate Change Mitigation Strategy, namely: energy efficiency, co-processing of alternative fuels and raw materials, product innovation and new technologies, and assessment of risks and opportunities across the value chain.

The policy sets out the environmental responsibilities by all business units and entities controlled or managed by the TITAN Group, as well as each TITAN employee.

Human Rights Policy

Our Human Rights policy establishes a framework for protecting and advancing human rights, both in our work and in our sphere of influence.

Respect for human rights is one of TITAN’s core values, as reflected in our Code of Conduct. Our policy is guided by the principles in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights.

The policy aims to raise awareness on human rights issues and ensure the commitment of all TITAN employees to the protection of human rights throughout the Group.

Health & Safety Policy

Our Health & Safety policy aims to achieve a healthy work environment free of incidents, injuries and accidents for all of our direct and indirect employees. It is aligned with all applicable laws and directives where TITAN is active.

At TITAN, Health and Safety is managed as an integrated system of goals with clear responsibilities and accountabilities. Our aim is to continuously improve and create an environment where every TITAN employee is responsible for their own and their colleagues’ safety. TITAN’s (Occupational) Health & Safety policy also includes sharing our know-how with stakeholders, suppliers, contractors and third parties to adopt similar health and safety policies.

Sanctions Policy

Our Sanctions policy aims to ensure compliance with sanction laws in every jurisdiction where the TITAN Group operates.

Our international presence as a Group obliges us to comply with any sanctions imposed, administered or enforced by international organizations or relevant national authorities. Under such circumstances, the Group is expected to implement and maintain adequate systems and controls to ensure compliance.

Our policy includes a practical guide and a list of best practices on issues including when to carry out due diligence, screening associated parties, training, and audit trail and record keeping.

Whistleblowing Policy

Our Whistleblowing Policy aims to guide our ongoing efforts to promote and strengthen ethical behaviors already embedded in our work culture. It establishes the framework for reporting work-related incidents that constitute, or may constitute, a violation of our corporate values and policies or retaliation against any person within TITAN Group.

The objective of the policy is to:
1. encourage the reporting of Incidents in good faith;
2. provide guidance as to how to make reports; and
3. provide comfort to reporting persons that their reports will be taken seriously and treated with confidentiality without fear of retaliation.

The Policy applies to all employees of TITAN Group worldwide, regardless of the legal basis of the working relationship and the position or the function of the employee. Third parties who have an ongoing relationship with TITAN may also rely on this Policy to report Incidents.
The Policy is supported by TITAN EthicsPoint, a platform where employees from every country can report work related concerns with confidentiality, by phone or online. The launch of this common platform across the Group enhances our efforts to foster a culture of integrity and ethical conduct across all our business units, while strengthening our ability to monitor non-compliance with TITAN policies.

TITAN Worldwide