Compliance Policy

Purpose: The purpose of this Compliance Policy is to establish guidelines and procedures to ensure that all employees, contractors, and representatives of Forgia GmbH adhere to applicable laws, regulations, industry standards, and internal policies.

Scope: This policy applies to all individuals associated with Forgia GmbH, including but not limited to employees, contractors, consultants, temporary workers, and agents.

Policy Statement: Forgia GmbH is committed to conducting its business in compliance with all relevant laws and regulations. We expect all individuals associated with our organization to act with integrity, honesty, and respect for legal and ethical standards.

Key Principles:
1. Compliance with Laws and Regulations: All individuals must comply with applicable laws of the Republic of Austria, EU and other applicable laws and regulations, and industry standards relevant to their roles and responsibilities. This includes but is not limited to laws related to antitrust, bribery and corruption, data protection, employment, environmental protection, and health and safety.
2. Export control and Sanctions
Forgia GmbH prohibits any activities that violate applicable sanctions laws and regulations. Prohibited activities include, but are not limited to:
a. Engaging in transactions or business dealings with sanctioned individuals, entities, or countries without proper authorization.
b. Facilitating transactions that involve the evasion or circumvention of sanctions.
c. Providing financial, material, or other support to sanctioned individuals, entities, or countries.
d. Concealing or falsifying information related to sanctions compliance.
Compliance with sanctions laws and regulations is essential to our reputation, integrity, and legal obligations.
By adhering to this policy, Forgia GmbH demonstrates its commitment to conducting business ethically and responsibly.
3. Ethical Conduct: We expect all individuals to conduct themselves with honesty, integrity, and fairness in all business activities. This includes avoiding conflicts of interest, maintaining confidentiality, and respecting the rights of others.
4. Reporting and Accountability: Individuals should promptly report any suspected violations of this policy or applicable laws and regulations to their supervisor, the Compliance Officer, or through the company’s reporting mechanisms.
Third parties may use the reporting channels, that is, the contacts of Forgia GmbH indicated on the company website, such as the company’s emails and phone numbers.
Forgia GmbH will investigate all reports of potential non-compliance and take appropriate disciplinary action if necessary. Upon the investigation of a case, the Compliance officer shall notify the company management and an individual or a legal entity that has reported the alleged violation.
5. Training and Awareness: Forgia GmbH will provide regular training and communication to ensure that all individuals are aware of their compliance obligations and understand the importance of ethical conduct in the workplace. The training shall be made on annual basis, unless the Compliance officer decides the circumstances require a more frequent training.

Responsibilities:
• Management: Management is responsible for setting the tone for compliance and providing leadership and support to ensure that compliance is integrated into all aspects of the business.
• Employees: All employees are responsible for understanding and adhering to this policy, as well as seeking guidance when unsure about compliance requirements.
• Compliance Officer: The Compliance Officer is responsible for overseeing compliance efforts, providing guidance and support to employees, conducting investigations, and ensuring that appropriate controls are in place to mitigate compliance risks.
The functions of the Compliance Officer shall be vested upon the Managing director, until the latter appoints the Compliance Officer.

Consequences of Non-Compliance: Non-compliance with this policy may result in disciplinary action, up to and including termination of employment or contract, as well as civil or criminal penalties for individuals found to have violated applicable laws and regulations.

Policy Review: Forgia GmbH acknowledges that for the proper performance of compliance procedures, the company should stay alert and up-to-date with the current requirements. In this connection, this policy will be reviewed from time to time to ensure that it remains up-to-date and effective in addressing compliance risks. Amendments to the policy may be made as necessary to reflect changes in laws, regulations, or business operations.

Approval: This Compliance Policy has been approved by Managing director of Forgia GmbH and is effective immediately.