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Code of Business Conduct

The name "VPIphotonics" in this document and all documents it refers to includes organisations around the world and all legal entities acting under the relevant name.

This Code of Business Conduct is binding on all organisations acting under the name VPIphotonics and applies to the employees of these organisations as well. VPIphotonics requires compliance with these principles from all counterparties and partners.

The responsibility of VPIphotonics to comply with the present Code on the part of partners and counterparties is limited to business relationships solely in the context of VPIphotonics' cooperation with partners and counterparties.

Principles of legality and reasonableness

In its activity, VPIphotonics strictly observes the legislation of the countries in which it operates. If the provisions of contracts, agreements and other documents with legal status are stricter than legislative requirements, VPIphotonics shall comply with such requirements as a matter of priority. VPIphotonics' legal liability is limited to jurisdiction in which VPIphotonics seeks to comply with applicable law of other states on the basis of the principle of necessary and sufficient grounds, but has no direct obligation to do so unless otherwise established by documents.

Anti-corruption and anti-bribery initiatives

VPIphotonics strictly and rigorously complies with the anti-corruption legislation of the countries in which it operates.
The general anti-corruption and anti-bribery principles of VPIphotonics include the following:

  • Employees and representatives of VPIphotonics are prohibited from giving or offering any kind of bribe, "kickback", payment of money or anything of material or other value in conducting business negotiations, concluding deals at any stage with the purpose of retaining business or influencing the decision of third parties.

  • VPIphotonics employees and representatives do not invite public sector clients, including public officials, employees of public sector enterprises or public institutions or representatives of political parties to any events, including entertainment or charity events (even if the agenda of such events does not relate to business) to discuss issues related to decision-making, doing business or concluding deals.

  • VPIphotonics employees and representatives must exercise care and caution to ensure that any expenses (e.g. gifts, meals or meetings) offered or received by any VPIphotonics employee or third party in the conduct of business cannot reasonably be construed as a bribe or a binding offer. Business courtesies must not be interpreted as acts done to influence the recipient to grant a preference or to influence any decisions.

Accordingly, the above principles form the criteria for their reasonable acceptance. Employees and representatives of VPIphotonics may offer and accept business gifts, souvenirs, invite third parties to events (including entertainment events) and participate in such events, ensuring that:

  • This faithfully serves exclusively business purposes.

  • This does not and cannot influence in any way anyone's decisions.

  • This is presented in an open and transparent manner.

  • This is not contrary to the laws of applicable jurisdiction.

Antitrust and competition law

VPIphotonics strictly and rigorously complies with the antitrust and competition laws of the countries in which it operates. Employees and representatives of VPIphotonics must not take any action or conclude any agreement that unreasonably restricts the actions of other market players, misleads customers and suppliers or unreasonably reduces competition.

Conflict of interest

The term "conflict of interest" describes any circumstances that may call into question the ability of VPIphotonics employees and representatives to act with complete objectivity in relation to the company or business interests. In its activities, VPIphotonics management respects and follows up on the principle of avoiding conflicts of interest, when the personal interests of VPIphotonics employees and representatives may affect the objective conduct of business or lead to actions that are not in the interests of VPIphotonics.

Health and safety and environmental protection

VPIphotonics strictly and rigorously complies with all applicable regulations in the field of safe working conditions and environmental protection. VPIphotonics ensures that the quality of its products and services, production stability and employee morale are reinforced by a safe and healthy working environment. Environmental responsibility is an integral part of world-class production. Production operations exclude adverse impacts on society, the environment and natural resources at the level accepted by legal regulations and requirements.

Consideration of complaints and proposals

VPIphotonics ensures that it considers requests for violations of any publicly available policies and public declarations in a timely manner. VPIphotonics reserves the right not to consider requests that contain links to third-party websites that may be accepted as suspicious, do not contain a full and detailed description of the violation and and the corresponding evidence of the violation, or impose an unreasonable financial burden on VPIphotonics to obtain information.