Article 1 - Preamble
(1) AF Power Group s.r.o., Id. No. 028 94 254, with its registered office at Ostrovní 126/30, Nové Město, 110 00 Prague 1, entered in the Commercial Register administered by the Municipal Court in Prague under the file no. C 257611, as well as its employees and responsible persons[1], in joint support of ethical conduct which has been on the decline, and feeling the need to provide reliable, safe, high-quality services, develop positive relations with business partners and customers and honest commercial practices, and prevent the commission of criminal activity, hereby accept, acknowledge and share this Code of Ethics of AF Power Group s.r.o. (hereinafter only the “Code of Ethics”) as their expression of reverence and respect for generally accepted ethical principles and rules and legal regulations. The same intentions are also acknowledged and shared by the persons representing AF Power Group s.r.o. or acting on behalf of AF Power Group s.r.o.
Article 2 – Fundamental Provisions
(1) This Code of Ethics aims at adherence to generally accepted ethical principles, development of positive relations with customers and business partners, and avoidance of any illegal conduct with emphasis on eliminating or reducing the risk of criminal liability on the part of AF Power Group s.r.o. in the sense of the provisions of Act no. 418/2011 Coll., on Criminal Liability of Legal Entities and Proceedings against Them, as amended (hereinafter only the “Criminal Liability of Legal Entities Law”). A brief description of the risk of the company’s criminal liability is contained in Article 10 of this Code of Ethics.
(2) In their conduct, AF Power Group s.r.o., all its employees and responsible persons put emphasis on the interests of the company’s customers and business partners and abide by the laws of the Czech Republic. The employees and responsible persons of AF Power Group s.r.o. are bound to act in a manner ensuring that the good name and reputation of AF Power Group s.r.o. is not harmed.
(3) AF Power Group s.r.o., all its employees and responsible persons acknowledge that discrimination in any form is prohibited in their contact with customers and business partners, as well as other employees and responsible persons within the company.
(4) AF Power Group s.r.o. unequivocal and clear intent is to perform its business activities legally, with a high degree of respect for ethical norms and the rights of customers, and by no means participate in or benefit from any kind of criminal activity or cause material or non-material damage to another.
(5) AF Power Group s.r.o. pays attention to reliable, correct and trustworthy conduct, especially towards its customers. The actions, behavior and dealings of individual employees and responsible persons are closely linked with the good name and reputation of AF Power Group s.r.o.
(6) AF Power Group s.r.o. hereby declares zero tolerance of any criminal activity committed by its employees or responsible persons. Its employees and responsible persons shall not take part in any behavior associated with corruption. AF Power Group s.r.o. distances itself from any kind of corruption environment and does not, under any circumstances, support such environment, not even passively. It is prohibited to offer or give any undue advantage, directly or indirectly, to third parties with the purpose of influencing or rewarding them for a service provided, or to accept such an advantage, with the exception of common symbolic gifts given or received in the course of regular commercial relations.
(7) In their activities and in the development and implementation of electronic solutions and tools, AF Power Group s.r.o. and its individual employees and responsible persons apply the highest standard of personal and professional conduct. In particular, they act with integrity, responsibility and respect and in accordance with good manners. Employees and responsible persons are bound to always act on behalf of AF Power Group s.r.o. with prudence, due care, and respect for the law and internal regulations of AF Power Group s.r.o., including this Code of Ethics. In the event of any doubts regarding decisions issued by AF Power Group s.r.o., instructions of responsible persons or the interpretation of legal or internal regulations, employees and responsible persons are obliged to request all necessary information including expert opinions for their further steps in order to minimize the risk of an excess or a violation of binding rules, including negligent violation, on their part.
(8) The fundamental rules of the company’s anti-corruption conduct are set out in Annex no. 1 of this Code of Ethics.
Article 3 – Relations with State Authorities and Civil Society
(1) AF Power Group s.r.o. keeps all official records as required by applicable laws and pays attention especially to due protection of its accounting books.
(2) AF Power Group s.r.o. keeps accounts in a manner ensuring that they always contain truthful and accurate information regarding its business. AF Power Group s.r.o. pays taxes in a due and timely manner and avoids practices that might be considered tax evasion. AF Power Group s.r.o. considers the payment of all other mandatory amounts a matter of course.
(3) AF Power Group s.r.o. categorically opposes child and forced labor. Similarly, it does not practice any form of exploitation or slavery and does not apply any procedures restricting free movement of employees.
(4) AF Power Group s.r.o. actively cooperates with public authorities; it provides to them relevant, complete and truthful information in a timely manner. AF Power Group s.r.o. also voluntarily and to a reasonable extent publishes information regarding its business and other activities, and communicates with the public through appointed persons in an open and transparent manner.
(5) AF Power Group s.r.o. does not make donations or provide undue advantages to political parties, political movements, politically active persons, or any other entities closely associated with political parties.
(6) AF Power Group s.r.o. supports charitable activities according to its ability and means. It also sponsors charity events or projects with public-benefit purposes. AF Power Group s.r.o. does not make donations or provide other advantages to organizations founded for profit, or those that do not act in accordance with the principles laid out in this Code of Ethics or entities business contacts with whom could present a risk to the good name and reputation of AF Power Group s.r.o. Sponsorship agreements are always concluded in writing and with transparent terms.
Article 4 – Relations with Customers
(1) AF Power Group s.r.o., its employees and responsible persons always carry out high-quality, professional work to ensure customer satisfaction. AF Power Group s.r.o. renders high-quality services for which it is fully liable.
(2) It is the goal of AF Power Group s.r.o. to always fulfil the requirements of the customer in a complex way. AF Power Group s.r.o. offers its customers services which are beneficial for them. It also strives for long-term relationships with its customers. It openly communicates with its customers and flexibly reacts to their needs and requirements.
(3) AF Power Group s.r.o. behaves in a manner ensuring that its customers are not harmed. In the event that a risk to their interests arises, AF Power Group s.r.o. informs them in a suitable form so that they are aware of such risk.
(4) In offering its services, AF Power Group s.r.o., its employees and responsible persons provide truthful, undistorted, and complete information to the customers in a clear and comprehensible form. They also reply to all customer enquiries in the same manner. AF Power Group s.r.o. does not engage in false advertisement.
(5) AF Power Group s.r.o. fulfils its legal obligations and refuses to undertake commitments it cannot honor.
(6) AF Power Group s.r.o. undertakes not to publish confidential information regarding its customers without their consent, unless otherwise stipulated by law.
(7) AF Power Group s.r.o. measures the level of satisfaction of its customers on a regular basis by telephone, email or personal interview.
Article 5 – Relationship with Owner
(1) AF Power Group s.r.o. pursues the purpose for which it was founded by its owner. It informs the owner of its strategy, current financial situation and achieved results on a regular basis; in managing its business, the company conscientiously applies the principles of honesty, accountability and transparency.
Article 6 – Relations with Business Partners
(1) AF Power Group s.r.o., its employees and responsible persons act towards the company’s business partners in a professional and proper manner and strive to build mutual trust.
(2) AF Power Group s.r.o. only chooses reliable, quality suppliers. Their services are assessed on a regular basis.
(3) AF Power Group s.r.o. consistently fulfils its contractual obligations and refuses to undertake commitments it cannot honor.
(4) AF Power Group s.r.o. keeps the trade secrets of and confidential information concerning its business partners.
Article 7 – Relations to Employees
(1) The management of AF Power Group s.r.o. undertakes to adhere to the following rules regarding the company’s employees:
a) fully respect its employees’ rights, including the privacy of conveyed messages, and acknowledge their privacy, personal values and needs;
b) actively make available all the information that its employees should or need to know for the performance of their work;
c) actively support regular training of the employees;
d) acknowledge the employees’ right to submit proposals for improvement and complaints;
e) allow the employees to turn to a body providing legal support;
f) continuously create an adequate and motivating work environment and ensure its dignity;
g) voluntarily grant adequate space for employees who wish to actively participate in the development of AF Power Group s.r.o. and the company’s decision-making;
h) secure safety and health protection at work;
i) hire new employees on the basis of transparent tenders; employees are hired based on their qualifications, skills and abilities;
j) fairly remunerate the company’s employees for the work performed and provide employee benefits according to the company’s ability.
(2) Employees undertake to adhere to the following rules vis-a-vis AF Power Group s.r.o.:
a) work properly and conscientiously, according to their strength, knowledge and abilities, and for the benefit of AF Power Group s.r.o., within the framework of their employment contracts and position and job description, and in accordance with the company’s internal regulations;
b) always act in accordance with the company’s legitimate interests and ensure that the good name of AF Power Group s.r.o. is not harmed by their conduct;
c) conscientiously abide by valid laws and company internal regulations, and actively enquire as to the timeliness of applicable regulations necessary for their work;
d) refrain from activities in relation to which they have not been instructed or trained;
e) inform their superiors of any shortcomings and defects that present a risk for AF Power Group s.r.o.,
f) properly manage the funds of the company, minimize expenditures of the company, and protect its assets from damage, loss, destruction or abuse;
g) prevent the possibility of a conflict between their own interests and the interests of AF Power Group s.r.o. or its partners; they may not, in particular, use their position in AF Power Group s.r.o., or the information or business contacts obtained in the course of their employment with AF Power Group s.r.o. for their personal enrichment or the enrichment of another, or perform work for the company’s suppliers or competitors, with the exception of activities allowed under paragraph 4 letter c) of this Article; never prioritize their own personal interest in the event of a conflict, but inform their superiors of such conflict without delay;
h) secure protection and safety when using IT systems and processing data, and lock their work computers whenever they leave the workplace;
i) maintain complete confidentiality regarding the know-how of AF Power Group s.r.o., respect the copyright of others and protect other forms of intellectual property, including after the termination of their employment;
j) refrain from using confidential (i.e. internal, not available to the public) information or business contacts obtained in connection with their work activities for their own benefit or the benefit of third parties, or for work-unrelated purposes; handle such data with due diligence and care;
k) under no circumstances offer, promise or provide gifts or other undue advantages to third parties, with the exception of promotion items given with the knowledge of the management of AF Power Group s.r.o. or small gifts or refreshments provided in the context of regular business relations, and never accept or ask for such gifts or advantages;
l) report any suspicion of a serious breach of this Code of Ethics, criminal law provisions or other legal provisions without undue delay;
m) make good use of working time to fulfil the tasks assigned to them and carry out their work conscientiously and with a creative attitude.
(3) Employees undertake to keep the following rules vis-à-vis each other:
a) honor their colleagues and mutually respect each other’s rights, refrain from harassing others by making inacceptable proposals; smoking is allowed only in reserved areas;
b) refrain from any form of bullying subordinates when in the position of a superior; the same rule applies to subordinates vis-a-vis their superiors;
c) superiors trust their subordinates, set for them clear and achievable goals and foster a sense of responsibility in them.
(4) Employees are furthermore entitled to:
a) submit complaints, proposals, petitions and other submissions to report unethical conduct or propose measures for improvement;
b) ask for a training aimed at deepening their qualifications or related to their work position;
c) carry out secondary activities without their superior’s prior consent only if such activities consist of scientific, educational, publishing, literary or artistic activities, management of their own assets, performance of an honorary position, or if such activities do not have a negative impact on the commercial policy of AF Power Group s.r.o. or the performance of tasks assigned to the given employee.
(5) Employees are bound to refuse any conduct or activity by which they might commit a criminal offence, or violate legal regulations or the internal regulations of AF Power Group s.r.o.
Article 8 – Intellectual Property
(1) AF Power Group s.r.o. respects and protects the copyright, licenses and information of others and protects other forms of intellectual property as well.
(2) AF Power Group s.r.o. protects confidential information not available to the public regarding its business and development of electronic solutions and tools.
Article 9 – Relationship to Environment
(1) AF Power Group s.r.o., its employees and responsible persons behave in a manner ensuring that no environmental damage occurs.
(2) Employees and responsible persons acknowledge the impact of their behavior on the environment. They separate and place recyclables in labelled recycling bins, reduce all different kinds of waste, prevent the escape and spreading of hazardous substances, maintain the rules of hygiene and safety at work, use office supplies economically, print only the required quantity of documents, and within the extent possible conserve water and energies.
(3) AF Power Group s.r.o. has assessed its risks in order to minimize possible environmental damage.
Article 10 – Criminal Liability of AF Power Group s.r.o.
– Mandatory Information and Rules
(1) The Criminal Liability of Legal Entities Law stipulates that AF Power Group s.r.o. can be prosecuted for the acts of its employees and responsible persons.
(2) AF Power Group s.r.o. is criminally liable if an employee or responsible person of the company commits a criminal offence during the performance of work tasks for AF Power Group s.r.o. or within the framework of an activity performed for AF Power Group s.r.o. if such criminal offence can be attributed to AF Power Group s.r.o.
(3) A criminal offence can be attributed to AF Power Group s.r.o. if it is committed through an act of the company’s responsible person. A criminal offence can furthermore be attributed to AF Power Group s.r.o. if committed by its employee or responsible person:
a) on the basis of a decision, approval or instruction of AF Power Group s.r.o. bodies;
b) because the bodies of AF Power Group s.r.o. failed to carry out measures that:
(ba) should have been carried out by law; or
(bb) can be reasonable required from them, in particular if they failed to perform mandatory or necessary supervision of the activities of employees or other persons subordinated to them, or failed to adopt measures to prevent or avert the consequences of a committed criminal offence.
(4) The Criminal Liability of Legal Entities Law does not specify the measures that AF Power Group s.r.o. is to adopt. However, not adopting relevant measures carries the risk of criminal liability for AF Power Group s.r.o. All employees and responsible persons of the company are thus obliged to duly acquaint themselves with the nature of risky behaviors constituting the criminal offences for which AF Power Group s.r.o. can be criminally liable, as well as with all related legal regulations.
(5) If an employee or responsible person commits a criminal offence during the performance of his work tasks for AF Power Group s.r.o. or within the framework of an activity performed for despite the fulfilment of the obligation to acquaint himself with the nature of risky behaviors under the preceding paragraph, such an act shall constitute excess on the part of such employee or responsible person in which AF Power Group s.r.o. shall by no means be involved.
(6) In the event of any doubts regarding an instruction or decision of their superior, employees may consider the compliance of such an instruction or decision with legal regulations, this Code of Ethics and other internal norms of AF Power Group s.r.o. Should an employee become suspicious that he might commit a criminal offence by carrying out the relevant instruction or decision, such employee is entitled to demand such instruction or decision in writing.
(7) The responsible persons of and employees in managerial positions in AF Power Group s.r.o. are bound to ascertain and verify the existence of suitable and effective measures aiming to prevent the risk of the company’s criminal liability. Employees and responsible persons shall report the risk of the company’s criminal liability to the person selected for this purpose.
(8) The responsible persons of and employees in managerial positions in AF Power Group s.r.o. are bound to instruct their subordinates with regard to legal regulations applicable to their work and draw their attention to the risks associated with the performance of their work.
(9) AF Power Group s.r.o. performs an internal audit on a regular basis. The company management emphasizes processes aiming at the improvement and adoption of preventive or corrective measures.
(10) AF Power Group s.r.o. carries out regular trainings with regard to the risk of its criminal liability as a legal entity. Each employee and responsible person is instructed with regard to such risk at the commencement of their employment and subsequently in regular intervals (at least once a year) during their employment.
Article 11 – Relations with Competitors; Competition and Public Procurement
(1) AF Power Group s.r.o. adheres to the rules of fair competition and does not abuse its position on the market. AF Power Group s.r.o. commits not to conclude any agreements restricting or distorting competition.
(2) In the event that AF Power Group s.r.o. bids for a public contract, its bid always contains truthful information. Should the company identify any irregular practices in the relevant procurement procedure, it shall report them to the competent bodies.
(3) AF Power Group s.r.o. never harms or uses for its benefit the good name of its competitors and never attempts to obtain information on their business in a deceitful manner.
Article 12 – Receipt of Submissions; Expression of Concerns
(1) Employees are entitled to submit complaints, proposals, petitions and other submissions calling attention to:
a) suspected commission of a criminal offence;
b) violation of legal regulations;
c) violation of the Code of Ethics of AF Power Group s.r.o.;
d) any behavior promoting corruption or actual corruption practices;
e) the settling of old scores with a colleague or business partner;
f) provision of unethical or untruthful information;
g) a proposal for improvement measures or other submissions.
Such submissions may also be anonymous. In such event, AF Power Group s.r.o. ensures that such submissions are discussed in confidential mode. Other facts considered relevant by the employee may also be reported.
(2) If a submission is marked as confidential by the employee, or the employee expresses the need for discretion in another way, the addressee of such confidential information must ensure that the identity of the informant and the contents of the submission are not disclosed.
(3) In the event that an employee reports in good faith an unethical conduct of a colleague or unethical practices within AF Power Group s.r.o., his report shall not have a negative impact on his employment. Prohibition of retaliation constitutes a part of the company’s whistleblower protection.
(4) In the event that a complaint proves to be justified, AF Power Group s.r.o. undertakes to restore compliance and adopt measures to prevent repetition of the relevant harmful conduct.
Article 13 – Final Provisions
(1) AF Power Group s.r.o., its employees and responsible persons undertake to adhere to all ethical principles set forth in this Code of Ethics during their activities and work.
(2) Responsibility for a full implementation of this Code of Ethics rests with the statutory body of AF Power Group s.r.o. who shall ensure that all employees and responsible persons are familiar with this Code of Ethics.
(3) Employees and responsible persons must by duly and demonstrably instructed with regard to the rules contained in this Code of Ethics, as well as the risk of, prevention and avoidance of the criminal liability of AF Power Group s.r.o. The company undertakes to carry out corresponding training on a regular basis.
(4) AF Power Group s.r.o. refuses to tolerate any violation of the rules set forth in this Code of Ethics. Employees and responsible persons of AF Power Group s.r.o. acknowledge that they may expose themselves, as well as AF Power Group s.r.o., to criminal-law or civil-law penalties and must therefore act in a manner ensuring that they do not commit a crime, nor violate legal regulations or internal regulations of AF Power Group s.r.o. by their decisions and conduct.
(5) All AF Power Group s.r.o. employees and responsible persons are bound to adhere to the provisions of this Code of Ethics. Violation of its rules by an employee or responsible person shall be considered a violation of work duties and punished as such in accordance with the applicable provisions of Act no. 262/2006 Coll., Labor Code, as amended (hereinafter only the “Labor Code”). The compensation of any damage shall be handled in accordance with the applicable provisions of the Labor Code, or, as the case may be, the Act no. 89/2012 Sb., Civil Code, as amended (hereinafter only the “Civil Code”).
(6) AF Power Group s.r.o. acknowledges that the Code of Ethics needs to be continually amended, developed and updated. It is the company’s clear and unequivocal commitment to not allow criminal activity in any way.
Article 14 - Effectiveness
(1) This Code of Ethics of AF Power Group s.r.o. shall become effective on May 1, 2024.
Annex no. 1 – Fundamental Anti-Corruption Rules
Article 1 – Corruption and Conflict of Interests
(1) The term “corruption” is not defined by Czech law; however, corruption offences in the sense of Act no. 40/2009 Coll., Criminal Code, as amended, include, in particular, the following: acceptance of a bribe (Section 331), bribery (Section 332), indirect bribery (Section 333), machinations in insolvency proceedings (Section 226), breach of regulations on rules of economic competition (Section 248 para. 1 letter e), arranging advantage in the commission of a public contract, public contest and public auction (Section 256 para. 1 and 3), machinations in the commission of a public contract and public contest (Section 257 para. 1 letter b and c), or machinations in a public auction (Section 258 para. 1 letters b and c). Criminal offences with features of corruption in certain special situations may also include, for example, breach of duty in the management of the assets of another (Sections 220 and 221) and abuse of information and position in business relations (Section 255).
(2) Conflict of interests is often discussed in connection with corruption. Interests in this context means personal (private) interests on one side (where a personal interest is an interest that brings its bearer a personal advantage or prevents possible reduction of a material or other benefit), and interests that must be promoted or defended by these bearers of personal interests on the basis of their position or function on the other side.
(3) The fact that there is a possibility of a conflict of interests does not automatically exclude third parties from having relationships with AF Power Group s.r.o. However, where a conflict of interest occurs between the interests of AF Power Group s.r.o. and a personal interest, the bearer of such personal interest must not prioritize his personal interest over the interests that he is bound to promote and defend. At the same time, however, it must be obvious from the given situation that the third party did not gain any advantage as a result of its relationship to the employees of AF Power Group s.r.o. For this reason, the following procedures are laid down for situations where a risk of a conflict of interest exists:
a) the relevant employee is obliged to report to his superior, to the maximum extent allowed under the law, situations leading to the emergence of an actual or suspected conflict of interests;
b) the superior of such employee is responsible for the resolution of such actual or suspected conflict of interests;
c) the person with the conflict of interests must not participate or be involved in any other way in decision-making to which such conflict of interests relates;
d) resolution of the conflict of interests must be duly documented.
Article 2 – Objectives of Anti-Corruption Efforts
(1) The objective of anti-corruption efforts is to secure an environment in which corruption is rejected and the protection of property emphasized.
(2) A clear organizational structure, appropriately set accountability relations, good internal and external communication and an overall transparency of certain processes belong to systemic measures necessary to achieve this objective. It is furthermore extremely important that all AF Power Group s.r.o. employees abide by the law and internal regulations, understand the importance of ethical principles in the performance of their work and adhere to them. AF Power Group s.r.o. bodies must promote behavior that rejects corruption, emphasize the importance of protecting the assets of the state and minimize damage caused by illegal conduct of others. AF Power Group s.r.o. bodies must lead by example in behaving correctly.
(3) Systematic training of employees on a professional level in the area of combating corruption needs to be introduced, ideally guaranteed by an expert in this area. To this purpose, the following groups must be trained:
a) employees of AF Power Group s.r.o. at commencement of employment (introduction of a mandatory minimum);
b) employees of AF Power Group s.r.o. on work positions involving an increased risk of corruption (periodical trainings);
c) employees of AF Power Group s.r.o. in managerial positions (improvement of their ability to identify in time the features of a corrupt behavior or corrupt environment and adopt, within their own competence, adequate measures to minimize them).
(4) A mandatory minimum shall include an explanation of the term corruption, the types of corruption, possible areas of occurrence, penalties for corrupt behavior, and demonstrations of practical examples of corrupt behavior, including the correct reaction on the side of the employee. Periodical trainings must focus, in addition to the passing of general information, on practical guidance on how to look for, assess, manage and monitor corruption risks in workplaces, the correct set up of a control and management mechanism, the possibility of corrective measures, the importance of supervising the implementation of such measures etc.
Article 3 – Control Mechanisms
(1) Regular testing of control and management mechanisms in areas of a high corruption risk is important to verify the effectiveness of such mechanisms in the detection and exposure of corruption.
(2) It is the duty of all employees in managerial positions to maintain a list of positions with an increased risk of corruption at their workplaces (so called positions of importance), summaries of activities with a real risk of corruption and measures for its prevention, including the obligation to update and refine such lists periodically on the basis of each implemented organization, mobilization and dislocation change, but at least once a year.
Article 4 – Anti-Corruption Measures
(1) A specific objective in this area is to minimize loss caused by corrupt behavior and prevent repetition of similar corruption scenarios. A thorough analysis of the causes of corruption is essential to enhance the prevention mechanisms aimed to reduce repetition of corruption.
(2) The goal of these measures must be to guarantee the right of the employees of AF Power Group s.r.o. to submit complaints, proposals, petitions and other submissions calling attention to behaviors violating the law or the company’s internal regulations, or to unethical conduct, or proposing measures for improvement.
(3) Corrective measures include amendments to internal regulations, adoption of disciplinary measures, handling of an incurred damage, and informing the employees of AF Power Group s.r.o. of the steps that have been taken in connection with confirmed corruption or unethical or illegal conduct (including the inference of liability and compensation of any damage).
(4) AF Power Group s.r.o. bodies declare their readiness in the event that a failure to adopt adequate corrective measures is established.
(5) Quantitative and qualitative assessment of the fulfilment of obligations in connection with the anti-corruption measures, the effectiveness of implementation of these measures and the corrective measures, and proposing amendments to the Code of Ethics or the anti-corruption measures by each individual employee of AF Power Group s.r.o. in a managerial position constitutes the central pillar of the anti-corruption measures.
Article 5 – Gift Policy
(1) The statutory body of AF Power Group s.r.o. shall define, on an annual basis and no later than on December 31 of each year, a list of gifts which AF Power Group s.r.o., its employees and responsible persons are allowed to offer to business partners. The economic value of such items must be adequate.
[1] A responsible person in the sense of Section 8 para 1 of the Criminal Liability of Legal Entities Law means a) the statutory body or a member of the statutory body of or another person in a managerial position within AF Power Group s.r.o. authorized to act on behalf of AF Power Group s.r.o.; b) a person in a managerial position within AF Power Group s.r.o. exercising management or supervisory activities; c) any person exercising decisive influence on the management of AF Power Group s.r.o. if such person’s acts constituted at least one of the conditions under which a consequence occurred that gave rise to the criminal liability of AF Power Group s.r.o.
(1) AF Power Group s.r.o., Id. No. 028 94 254, with its registered office at Ostrovní 126/30, Nové Město, 110 00 Prague 1, entered in the Commercial Register administered by the Municipal Court in Prague under the file no. C 257611, as well as its employees and responsible persons[1], in joint support of ethical conduct which has been on the decline, and feeling the need to provide reliable, safe, high-quality services, develop positive relations with business partners and customers and honest commercial practices, and prevent the commission of criminal activity, hereby accept, acknowledge and share this Code of Ethics of AF Power Group s.r.o. (hereinafter only the “Code of Ethics”) as their expression of reverence and respect for generally accepted ethical principles and rules and legal regulations. The same intentions are also acknowledged and shared by the persons representing AF Power Group s.r.o. or acting on behalf of AF Power Group s.r.o.
Article 2 – Fundamental Provisions
(1) This Code of Ethics aims at adherence to generally accepted ethical principles, development of positive relations with customers and business partners, and avoidance of any illegal conduct with emphasis on eliminating or reducing the risk of criminal liability on the part of AF Power Group s.r.o. in the sense of the provisions of Act no. 418/2011 Coll., on Criminal Liability of Legal Entities and Proceedings against Them, as amended (hereinafter only the “Criminal Liability of Legal Entities Law”). A brief description of the risk of the company’s criminal liability is contained in Article 10 of this Code of Ethics.
(2) In their conduct, AF Power Group s.r.o., all its employees and responsible persons put emphasis on the interests of the company’s customers and business partners and abide by the laws of the Czech Republic. The employees and responsible persons of AF Power Group s.r.o. are bound to act in a manner ensuring that the good name and reputation of AF Power Group s.r.o. is not harmed.
(3) AF Power Group s.r.o., all its employees and responsible persons acknowledge that discrimination in any form is prohibited in their contact with customers and business partners, as well as other employees and responsible persons within the company.
(4) AF Power Group s.r.o. unequivocal and clear intent is to perform its business activities legally, with a high degree of respect for ethical norms and the rights of customers, and by no means participate in or benefit from any kind of criminal activity or cause material or non-material damage to another.
(5) AF Power Group s.r.o. pays attention to reliable, correct and trustworthy conduct, especially towards its customers. The actions, behavior and dealings of individual employees and responsible persons are closely linked with the good name and reputation of AF Power Group s.r.o.
(6) AF Power Group s.r.o. hereby declares zero tolerance of any criminal activity committed by its employees or responsible persons. Its employees and responsible persons shall not take part in any behavior associated with corruption. AF Power Group s.r.o. distances itself from any kind of corruption environment and does not, under any circumstances, support such environment, not even passively. It is prohibited to offer or give any undue advantage, directly or indirectly, to third parties with the purpose of influencing or rewarding them for a service provided, or to accept such an advantage, with the exception of common symbolic gifts given or received in the course of regular commercial relations.
(7) In their activities and in the development and implementation of electronic solutions and tools, AF Power Group s.r.o. and its individual employees and responsible persons apply the highest standard of personal and professional conduct. In particular, they act with integrity, responsibility and respect and in accordance with good manners. Employees and responsible persons are bound to always act on behalf of AF Power Group s.r.o. with prudence, due care, and respect for the law and internal regulations of AF Power Group s.r.o., including this Code of Ethics. In the event of any doubts regarding decisions issued by AF Power Group s.r.o., instructions of responsible persons or the interpretation of legal or internal regulations, employees and responsible persons are obliged to request all necessary information including expert opinions for their further steps in order to minimize the risk of an excess or a violation of binding rules, including negligent violation, on their part.
(8) The fundamental rules of the company’s anti-corruption conduct are set out in Annex no. 1 of this Code of Ethics.
Article 3 – Relations with State Authorities and Civil Society
(1) AF Power Group s.r.o. keeps all official records as required by applicable laws and pays attention especially to due protection of its accounting books.
(2) AF Power Group s.r.o. keeps accounts in a manner ensuring that they always contain truthful and accurate information regarding its business. AF Power Group s.r.o. pays taxes in a due and timely manner and avoids practices that might be considered tax evasion. AF Power Group s.r.o. considers the payment of all other mandatory amounts a matter of course.
(3) AF Power Group s.r.o. categorically opposes child and forced labor. Similarly, it does not practice any form of exploitation or slavery and does not apply any procedures restricting free movement of employees.
(4) AF Power Group s.r.o. actively cooperates with public authorities; it provides to them relevant, complete and truthful information in a timely manner. AF Power Group s.r.o. also voluntarily and to a reasonable extent publishes information regarding its business and other activities, and communicates with the public through appointed persons in an open and transparent manner.
(5) AF Power Group s.r.o. does not make donations or provide undue advantages to political parties, political movements, politically active persons, or any other entities closely associated with political parties.
(6) AF Power Group s.r.o. supports charitable activities according to its ability and means. It also sponsors charity events or projects with public-benefit purposes. AF Power Group s.r.o. does not make donations or provide other advantages to organizations founded for profit, or those that do not act in accordance with the principles laid out in this Code of Ethics or entities business contacts with whom could present a risk to the good name and reputation of AF Power Group s.r.o. Sponsorship agreements are always concluded in writing and with transparent terms.
Article 4 – Relations with Customers
(1) AF Power Group s.r.o., its employees and responsible persons always carry out high-quality, professional work to ensure customer satisfaction. AF Power Group s.r.o. renders high-quality services for which it is fully liable.
(2) It is the goal of AF Power Group s.r.o. to always fulfil the requirements of the customer in a complex way. AF Power Group s.r.o. offers its customers services which are beneficial for them. It also strives for long-term relationships with its customers. It openly communicates with its customers and flexibly reacts to their needs and requirements.
(3) AF Power Group s.r.o. behaves in a manner ensuring that its customers are not harmed. In the event that a risk to their interests arises, AF Power Group s.r.o. informs them in a suitable form so that they are aware of such risk.
(4) In offering its services, AF Power Group s.r.o., its employees and responsible persons provide truthful, undistorted, and complete information to the customers in a clear and comprehensible form. They also reply to all customer enquiries in the same manner. AF Power Group s.r.o. does not engage in false advertisement.
(5) AF Power Group s.r.o. fulfils its legal obligations and refuses to undertake commitments it cannot honor.
(6) AF Power Group s.r.o. undertakes not to publish confidential information regarding its customers without their consent, unless otherwise stipulated by law.
(7) AF Power Group s.r.o. measures the level of satisfaction of its customers on a regular basis by telephone, email or personal interview.
Article 5 – Relationship with Owner
(1) AF Power Group s.r.o. pursues the purpose for which it was founded by its owner. It informs the owner of its strategy, current financial situation and achieved results on a regular basis; in managing its business, the company conscientiously applies the principles of honesty, accountability and transparency.
Article 6 – Relations with Business Partners
(1) AF Power Group s.r.o., its employees and responsible persons act towards the company’s business partners in a professional and proper manner and strive to build mutual trust.
(2) AF Power Group s.r.o. only chooses reliable, quality suppliers. Their services are assessed on a regular basis.
(3) AF Power Group s.r.o. consistently fulfils its contractual obligations and refuses to undertake commitments it cannot honor.
(4) AF Power Group s.r.o. keeps the trade secrets of and confidential information concerning its business partners.
Article 7 – Relations to Employees
(1) The management of AF Power Group s.r.o. undertakes to adhere to the following rules regarding the company’s employees:
a) fully respect its employees’ rights, including the privacy of conveyed messages, and acknowledge their privacy, personal values and needs;
b) actively make available all the information that its employees should or need to know for the performance of their work;
c) actively support regular training of the employees;
d) acknowledge the employees’ right to submit proposals for improvement and complaints;
e) allow the employees to turn to a body providing legal support;
f) continuously create an adequate and motivating work environment and ensure its dignity;
g) voluntarily grant adequate space for employees who wish to actively participate in the development of AF Power Group s.r.o. and the company’s decision-making;
h) secure safety and health protection at work;
i) hire new employees on the basis of transparent tenders; employees are hired based on their qualifications, skills and abilities;
j) fairly remunerate the company’s employees for the work performed and provide employee benefits according to the company’s ability.
(2) Employees undertake to adhere to the following rules vis-a-vis AF Power Group s.r.o.:
a) work properly and conscientiously, according to their strength, knowledge and abilities, and for the benefit of AF Power Group s.r.o., within the framework of their employment contracts and position and job description, and in accordance with the company’s internal regulations;
b) always act in accordance with the company’s legitimate interests and ensure that the good name of AF Power Group s.r.o. is not harmed by their conduct;
c) conscientiously abide by valid laws and company internal regulations, and actively enquire as to the timeliness of applicable regulations necessary for their work;
d) refrain from activities in relation to which they have not been instructed or trained;
e) inform their superiors of any shortcomings and defects that present a risk for AF Power Group s.r.o.,
f) properly manage the funds of the company, minimize expenditures of the company, and protect its assets from damage, loss, destruction or abuse;
g) prevent the possibility of a conflict between their own interests and the interests of AF Power Group s.r.o. or its partners; they may not, in particular, use their position in AF Power Group s.r.o., or the information or business contacts obtained in the course of their employment with AF Power Group s.r.o. for their personal enrichment or the enrichment of another, or perform work for the company’s suppliers or competitors, with the exception of activities allowed under paragraph 4 letter c) of this Article; never prioritize their own personal interest in the event of a conflict, but inform their superiors of such conflict without delay;
h) secure protection and safety when using IT systems and processing data, and lock their work computers whenever they leave the workplace;
i) maintain complete confidentiality regarding the know-how of AF Power Group s.r.o., respect the copyright of others and protect other forms of intellectual property, including after the termination of their employment;
j) refrain from using confidential (i.e. internal, not available to the public) information or business contacts obtained in connection with their work activities for their own benefit or the benefit of third parties, or for work-unrelated purposes; handle such data with due diligence and care;
k) under no circumstances offer, promise or provide gifts or other undue advantages to third parties, with the exception of promotion items given with the knowledge of the management of AF Power Group s.r.o. or small gifts or refreshments provided in the context of regular business relations, and never accept or ask for such gifts or advantages;
l) report any suspicion of a serious breach of this Code of Ethics, criminal law provisions or other legal provisions without undue delay;
m) make good use of working time to fulfil the tasks assigned to them and carry out their work conscientiously and with a creative attitude.
(3) Employees undertake to keep the following rules vis-à-vis each other:
a) honor their colleagues and mutually respect each other’s rights, refrain from harassing others by making inacceptable proposals; smoking is allowed only in reserved areas;
b) refrain from any form of bullying subordinates when in the position of a superior; the same rule applies to subordinates vis-a-vis their superiors;
c) superiors trust their subordinates, set for them clear and achievable goals and foster a sense of responsibility in them.
(4) Employees are furthermore entitled to:
a) submit complaints, proposals, petitions and other submissions to report unethical conduct or propose measures for improvement;
b) ask for a training aimed at deepening their qualifications or related to their work position;
c) carry out secondary activities without their superior’s prior consent only if such activities consist of scientific, educational, publishing, literary or artistic activities, management of their own assets, performance of an honorary position, or if such activities do not have a negative impact on the commercial policy of AF Power Group s.r.o. or the performance of tasks assigned to the given employee.
(5) Employees are bound to refuse any conduct or activity by which they might commit a criminal offence, or violate legal regulations or the internal regulations of AF Power Group s.r.o.
Article 8 – Intellectual Property
(1) AF Power Group s.r.o. respects and protects the copyright, licenses and information of others and protects other forms of intellectual property as well.
(2) AF Power Group s.r.o. protects confidential information not available to the public regarding its business and development of electronic solutions and tools.
Article 9 – Relationship to Environment
(1) AF Power Group s.r.o., its employees and responsible persons behave in a manner ensuring that no environmental damage occurs.
(2) Employees and responsible persons acknowledge the impact of their behavior on the environment. They separate and place recyclables in labelled recycling bins, reduce all different kinds of waste, prevent the escape and spreading of hazardous substances, maintain the rules of hygiene and safety at work, use office supplies economically, print only the required quantity of documents, and within the extent possible conserve water and energies.
(3) AF Power Group s.r.o. has assessed its risks in order to minimize possible environmental damage.
Article 10 – Criminal Liability of AF Power Group s.r.o.
– Mandatory Information and Rules
(1) The Criminal Liability of Legal Entities Law stipulates that AF Power Group s.r.o. can be prosecuted for the acts of its employees and responsible persons.
(2) AF Power Group s.r.o. is criminally liable if an employee or responsible person of the company commits a criminal offence during the performance of work tasks for AF Power Group s.r.o. or within the framework of an activity performed for AF Power Group s.r.o. if such criminal offence can be attributed to AF Power Group s.r.o.
(3) A criminal offence can be attributed to AF Power Group s.r.o. if it is committed through an act of the company’s responsible person. A criminal offence can furthermore be attributed to AF Power Group s.r.o. if committed by its employee or responsible person:
a) on the basis of a decision, approval or instruction of AF Power Group s.r.o. bodies;
b) because the bodies of AF Power Group s.r.o. failed to carry out measures that:
(ba) should have been carried out by law; or
(bb) can be reasonable required from them, in particular if they failed to perform mandatory or necessary supervision of the activities of employees or other persons subordinated to them, or failed to adopt measures to prevent or avert the consequences of a committed criminal offence.
(4) The Criminal Liability of Legal Entities Law does not specify the measures that AF Power Group s.r.o. is to adopt. However, not adopting relevant measures carries the risk of criminal liability for AF Power Group s.r.o. All employees and responsible persons of the company are thus obliged to duly acquaint themselves with the nature of risky behaviors constituting the criminal offences for which AF Power Group s.r.o. can be criminally liable, as well as with all related legal regulations.
(5) If an employee or responsible person commits a criminal offence during the performance of his work tasks for AF Power Group s.r.o. or within the framework of an activity performed for despite the fulfilment of the obligation to acquaint himself with the nature of risky behaviors under the preceding paragraph, such an act shall constitute excess on the part of such employee or responsible person in which AF Power Group s.r.o. shall by no means be involved.
(6) In the event of any doubts regarding an instruction or decision of their superior, employees may consider the compliance of such an instruction or decision with legal regulations, this Code of Ethics and other internal norms of AF Power Group s.r.o. Should an employee become suspicious that he might commit a criminal offence by carrying out the relevant instruction or decision, such employee is entitled to demand such instruction or decision in writing.
(7) The responsible persons of and employees in managerial positions in AF Power Group s.r.o. are bound to ascertain and verify the existence of suitable and effective measures aiming to prevent the risk of the company’s criminal liability. Employees and responsible persons shall report the risk of the company’s criminal liability to the person selected for this purpose.
(8) The responsible persons of and employees in managerial positions in AF Power Group s.r.o. are bound to instruct their subordinates with regard to legal regulations applicable to their work and draw their attention to the risks associated with the performance of their work.
(9) AF Power Group s.r.o. performs an internal audit on a regular basis. The company management emphasizes processes aiming at the improvement and adoption of preventive or corrective measures.
(10) AF Power Group s.r.o. carries out regular trainings with regard to the risk of its criminal liability as a legal entity. Each employee and responsible person is instructed with regard to such risk at the commencement of their employment and subsequently in regular intervals (at least once a year) during their employment.
Article 11 – Relations with Competitors; Competition and Public Procurement
(1) AF Power Group s.r.o. adheres to the rules of fair competition and does not abuse its position on the market. AF Power Group s.r.o. commits not to conclude any agreements restricting or distorting competition.
(2) In the event that AF Power Group s.r.o. bids for a public contract, its bid always contains truthful information. Should the company identify any irregular practices in the relevant procurement procedure, it shall report them to the competent bodies.
(3) AF Power Group s.r.o. never harms or uses for its benefit the good name of its competitors and never attempts to obtain information on their business in a deceitful manner.
Article 12 – Receipt of Submissions; Expression of Concerns
(1) Employees are entitled to submit complaints, proposals, petitions and other submissions calling attention to:
a) suspected commission of a criminal offence;
b) violation of legal regulations;
c) violation of the Code of Ethics of AF Power Group s.r.o.;
d) any behavior promoting corruption or actual corruption practices;
e) the settling of old scores with a colleague or business partner;
f) provision of unethical or untruthful information;
g) a proposal for improvement measures or other submissions.
Such submissions may also be anonymous. In such event, AF Power Group s.r.o. ensures that such submissions are discussed in confidential mode. Other facts considered relevant by the employee may also be reported.
(2) If a submission is marked as confidential by the employee, or the employee expresses the need for discretion in another way, the addressee of such confidential information must ensure that the identity of the informant and the contents of the submission are not disclosed.
(3) In the event that an employee reports in good faith an unethical conduct of a colleague or unethical practices within AF Power Group s.r.o., his report shall not have a negative impact on his employment. Prohibition of retaliation constitutes a part of the company’s whistleblower protection.
(4) In the event that a complaint proves to be justified, AF Power Group s.r.o. undertakes to restore compliance and adopt measures to prevent repetition of the relevant harmful conduct.
Article 13 – Final Provisions
(1) AF Power Group s.r.o., its employees and responsible persons undertake to adhere to all ethical principles set forth in this Code of Ethics during their activities and work.
(2) Responsibility for a full implementation of this Code of Ethics rests with the statutory body of AF Power Group s.r.o. who shall ensure that all employees and responsible persons are familiar with this Code of Ethics.
(3) Employees and responsible persons must by duly and demonstrably instructed with regard to the rules contained in this Code of Ethics, as well as the risk of, prevention and avoidance of the criminal liability of AF Power Group s.r.o. The company undertakes to carry out corresponding training on a regular basis.
(4) AF Power Group s.r.o. refuses to tolerate any violation of the rules set forth in this Code of Ethics. Employees and responsible persons of AF Power Group s.r.o. acknowledge that they may expose themselves, as well as AF Power Group s.r.o., to criminal-law or civil-law penalties and must therefore act in a manner ensuring that they do not commit a crime, nor violate legal regulations or internal regulations of AF Power Group s.r.o. by their decisions and conduct.
(5) All AF Power Group s.r.o. employees and responsible persons are bound to adhere to the provisions of this Code of Ethics. Violation of its rules by an employee or responsible person shall be considered a violation of work duties and punished as such in accordance with the applicable provisions of Act no. 262/2006 Coll., Labor Code, as amended (hereinafter only the “Labor Code”). The compensation of any damage shall be handled in accordance with the applicable provisions of the Labor Code, or, as the case may be, the Act no. 89/2012 Sb., Civil Code, as amended (hereinafter only the “Civil Code”).
(6) AF Power Group s.r.o. acknowledges that the Code of Ethics needs to be continually amended, developed and updated. It is the company’s clear and unequivocal commitment to not allow criminal activity in any way.
Article 14 - Effectiveness
(1) This Code of Ethics of AF Power Group s.r.o. shall become effective on May 1, 2024.
Annex no. 1 – Fundamental Anti-Corruption Rules
Article 1 – Corruption and Conflict of Interests
(1) The term “corruption” is not defined by Czech law; however, corruption offences in the sense of Act no. 40/2009 Coll., Criminal Code, as amended, include, in particular, the following: acceptance of a bribe (Section 331), bribery (Section 332), indirect bribery (Section 333), machinations in insolvency proceedings (Section 226), breach of regulations on rules of economic competition (Section 248 para. 1 letter e), arranging advantage in the commission of a public contract, public contest and public auction (Section 256 para. 1 and 3), machinations in the commission of a public contract and public contest (Section 257 para. 1 letter b and c), or machinations in a public auction (Section 258 para. 1 letters b and c). Criminal offences with features of corruption in certain special situations may also include, for example, breach of duty in the management of the assets of another (Sections 220 and 221) and abuse of information and position in business relations (Section 255).
(2) Conflict of interests is often discussed in connection with corruption. Interests in this context means personal (private) interests on one side (where a personal interest is an interest that brings its bearer a personal advantage or prevents possible reduction of a material or other benefit), and interests that must be promoted or defended by these bearers of personal interests on the basis of their position or function on the other side.
(3) The fact that there is a possibility of a conflict of interests does not automatically exclude third parties from having relationships with AF Power Group s.r.o. However, where a conflict of interest occurs between the interests of AF Power Group s.r.o. and a personal interest, the bearer of such personal interest must not prioritize his personal interest over the interests that he is bound to promote and defend. At the same time, however, it must be obvious from the given situation that the third party did not gain any advantage as a result of its relationship to the employees of AF Power Group s.r.o. For this reason, the following procedures are laid down for situations where a risk of a conflict of interest exists:
a) the relevant employee is obliged to report to his superior, to the maximum extent allowed under the law, situations leading to the emergence of an actual or suspected conflict of interests;
b) the superior of such employee is responsible for the resolution of such actual or suspected conflict of interests;
c) the person with the conflict of interests must not participate or be involved in any other way in decision-making to which such conflict of interests relates;
d) resolution of the conflict of interests must be duly documented.
Article 2 – Objectives of Anti-Corruption Efforts
(1) The objective of anti-corruption efforts is to secure an environment in which corruption is rejected and the protection of property emphasized.
(2) A clear organizational structure, appropriately set accountability relations, good internal and external communication and an overall transparency of certain processes belong to systemic measures necessary to achieve this objective. It is furthermore extremely important that all AF Power Group s.r.o. employees abide by the law and internal regulations, understand the importance of ethical principles in the performance of their work and adhere to them. AF Power Group s.r.o. bodies must promote behavior that rejects corruption, emphasize the importance of protecting the assets of the state and minimize damage caused by illegal conduct of others. AF Power Group s.r.o. bodies must lead by example in behaving correctly.
(3) Systematic training of employees on a professional level in the area of combating corruption needs to be introduced, ideally guaranteed by an expert in this area. To this purpose, the following groups must be trained:
a) employees of AF Power Group s.r.o. at commencement of employment (introduction of a mandatory minimum);
b) employees of AF Power Group s.r.o. on work positions involving an increased risk of corruption (periodical trainings);
c) employees of AF Power Group s.r.o. in managerial positions (improvement of their ability to identify in time the features of a corrupt behavior or corrupt environment and adopt, within their own competence, adequate measures to minimize them).
(4) A mandatory minimum shall include an explanation of the term corruption, the types of corruption, possible areas of occurrence, penalties for corrupt behavior, and demonstrations of practical examples of corrupt behavior, including the correct reaction on the side of the employee. Periodical trainings must focus, in addition to the passing of general information, on practical guidance on how to look for, assess, manage and monitor corruption risks in workplaces, the correct set up of a control and management mechanism, the possibility of corrective measures, the importance of supervising the implementation of such measures etc.
Article 3 – Control Mechanisms
(1) Regular testing of control and management mechanisms in areas of a high corruption risk is important to verify the effectiveness of such mechanisms in the detection and exposure of corruption.
(2) It is the duty of all employees in managerial positions to maintain a list of positions with an increased risk of corruption at their workplaces (so called positions of importance), summaries of activities with a real risk of corruption and measures for its prevention, including the obligation to update and refine such lists periodically on the basis of each implemented organization, mobilization and dislocation change, but at least once a year.
Article 4 – Anti-Corruption Measures
(1) A specific objective in this area is to minimize loss caused by corrupt behavior and prevent repetition of similar corruption scenarios. A thorough analysis of the causes of corruption is essential to enhance the prevention mechanisms aimed to reduce repetition of corruption.
(2) The goal of these measures must be to guarantee the right of the employees of AF Power Group s.r.o. to submit complaints, proposals, petitions and other submissions calling attention to behaviors violating the law or the company’s internal regulations, or to unethical conduct, or proposing measures for improvement.
(3) Corrective measures include amendments to internal regulations, adoption of disciplinary measures, handling of an incurred damage, and informing the employees of AF Power Group s.r.o. of the steps that have been taken in connection with confirmed corruption or unethical or illegal conduct (including the inference of liability and compensation of any damage).
(4) AF Power Group s.r.o. bodies declare their readiness in the event that a failure to adopt adequate corrective measures is established.
(5) Quantitative and qualitative assessment of the fulfilment of obligations in connection with the anti-corruption measures, the effectiveness of implementation of these measures and the corrective measures, and proposing amendments to the Code of Ethics or the anti-corruption measures by each individual employee of AF Power Group s.r.o. in a managerial position constitutes the central pillar of the anti-corruption measures.
Article 5 – Gift Policy
(1) The statutory body of AF Power Group s.r.o. shall define, on an annual basis and no later than on December 31 of each year, a list of gifts which AF Power Group s.r.o., its employees and responsible persons are allowed to offer to business partners. The economic value of such items must be adequate.
[1] A responsible person in the sense of Section 8 para 1 of the Criminal Liability of Legal Entities Law means a) the statutory body or a member of the statutory body of or another person in a managerial position within AF Power Group s.r.o. authorized to act on behalf of AF Power Group s.r.o.; b) a person in a managerial position within AF Power Group s.r.o. exercising management or supervisory activities; c) any person exercising decisive influence on the management of AF Power Group s.r.o. if such person’s acts constituted at least one of the conditions under which a consequence occurred that gave rise to the criminal liability of AF Power Group s.r.o.
Registration : 02894254
VAT ID : CZ02894254
VAT ID : CZ02894254
Ostrovni 126/30, 110 00
Prague 1 Czech Republic.
Prague 1 Czech Republic.
Email: info@afpowergroup.com
Trade: trading@afpowergroup.com
Trade: trading@afpowergroup.com
© AF Power Group s.r.o. All rights reserved.