Compliance

Our 55-year history means not only an extraordinary tradition but also a commitment to our current operations. Together with procedures under laws and other legal regulations, we also ensure that our own codes of conduct apply to our management, our employees, and our dealings with other companies and organizations.      

The Code of Ethics of the Metrostav Group

The Code of Ethics of the Metrostav Group is a binding document stipulating the moral principles of the Metrostav Group. It defines behaviors and conduct for the corporations of the Group, its employees and colleagues.

Metrostav Group is a business grouping of legal persons (concern) operating in the construction industry within the meaning of § 79, of Act No. 90/2012 Coll. It comprises the controlling person, Metrostav a.s., and other persons managed by it, as stipulated on www.skupinametrostav.cz/en.

Moral Principles of Metrostav Group

1) We always adhere to the laws of the Czech Republic and the countries in which we operate and intend to operate.

We continuously follow and comply in practice with the legal code and ethical norms of the countries in which we operate or intend to operate. In addition to respecting relevant laws and rules, we actively prevent suspicions of any wrongdoing.

2) Trust, professionalism and stability are our fundamental shared values.

We continuously strive for creating a safe, creative and stable work environment. We always act professionally and with the highest professional care. Internally as well as externally we build relationships based on trust. We collaborate with natural and legal persons that are qualified and trustworthy. We duly charge all financial transactions. We report true information about our results. We pay taxes as well as social security, health insurance, and other obligatory payments honestly and in a timely manner.

3) Customer satisfaction is our main objective but never at the cost of violating ethical or legal norms.

We do not tolerate corruption, bribery and unfair competition. We do not provide or accept, directly or indirectly, any payments or remuneration that may lead to conduct in conflict with the law or ethical norms. We only collaborate with persons with whom we have no apparent or real conflict of interests and whose financial means come from legitimate sources. We pay attention to information security and data protection.

4) We assume our social responsibility to citizens of the countries, regions, cities, municipalities where we operate or intend to operate.

We strive for minimizing negative impacts of our construction and business activities on the environment and affected communities. We respect the needs and interests of natural and legal persons outside the Metrostav Group. We honor the legacy of previous generations and we act responsibly with future generations in mind.

5) We respect the rights and obligations of all our colleagues. We do not allow any discriminatory conduct.

We guarantee equal opportunities to people regardless of their sex, color, ethnicity, race, nationality, religion or any other different characteristic features. We do not condone harassment or discrimination. We act helpfully and with consideration, particularly with respect to the handicapped, seriously ill, elderly and families with children. In accordance with the law, we respect the rights of the employees to form unions or join them.

6) We do not allow any possible conflict of personal interests with the interests of the Metrostav Group. We protect movable and immovable assets as well as intellectual property as our own.

We protect and carefully maintain all movable assets, immovable assets, intellectual property and confidential information of the Metrostav Group. Work decisions must never be affected by individual, family or friendship interests.

7) We do not tolerate failure to adhere to the moral principles of the Metrostav Group.

Honoring and complying with the Code of Ethics of the Metrostav Group is the obligation of every employee of the Group. In the event of an indication of a violation of the Code, we notify the concerned employee about their unacceptable conduct. We also inform the line manager or appropriate director or the Director of the Internal Audit Unit of the Metrostav Group. Retaliatory steps against anyone who reported the breach of the Code of Ethics or helped disclose it are unacceptable. By doing this, we prevent possible damage, criminal and legal as well as moral sanctions against the Metrostav Group and all honest employees of the Group.

Zero Tolerance Statement

On January 1, 2012, Act no. 418/2011 Coll. Corporate Criminal Liability and Related Proceedings came into force. This allows to prosecute criminal acts conducted by the company bodies or people in positions as defined by the Act, which are attributed to a company irrespective of whether the particular person who committed the illegal act is known or can be identified.

Due to the fact mentioned above, Subterra a.s. declares a lasting commitment to compliance with all laws and prevention of any illegal conduct when working on the construction market both outside and inside the company.

Subterra a.s. also declares that it will consistently enforce and strictly observe the zero tolerance policy towards any unlawful conduct of their employee’s resp. other persons acting on its behalf.

Subterra a.s. categorically rejects any unlawful, unfair and immoral practices, it is strongly committed to make sure that all its employees resp. other persons comply with the laws, corporate values and culture.

Subterra Core Values

1) Our main goal is the continued success of Subterra a.s.

2) Our core corporate values are professionalism, credibility and stability.

3) The document „Our Management and Work Methods“ represents our company code of conduct. We treat each other with respect and dignity.

4) Professional qualification is the source of our corporate and personal confidence.

5) Customer satisfaction is our route to success. We are demanding not only of ourselves and our co-workers but also of our suppliers.

6) We maintain and guard the assets of Subterra a.s. as if they were our own.

7) We are always aware of the environment and occupational health and safety.

8) We reject illegal conduct and unethical behaviour. We keep our word.

Code of Conduct for Contractors

A) Preamble

Subterra is a business corporation founded and doing system in accordance with the existing legal system of the Czech Republic. Subterra is part of the Metrostav Group, a business group of legal entities (concern) operating in the construction industry under Section 79, Act No. 90/2012 Coll., on Business Companies and Cooperatives (Business Corporations Act). Subterra is a joint-stock company with a tradition of more than fifty years. The company has always ensured and continues to ensure that its operations in the market fully comply with legal and ethical standards. Subterra has long refused to act in breach of applicable law and/or moral, ethical standards and principles. The company also expects the same approach from all its employees and contractors. As a member of the Metrostav Group, Subterra has accepted the principles declared by the Metrostav Group Code of Conduct and, together with the Subterra Code of Conduct, ensures that they are fully respected in all aspects of its business.

In relation to the above Subterra published the following document Subterra Code of Conduct for Contractors. Subterra considers the acceptance and adherence to this Code of Conduct to be essential for any cooperation with the contractors now and in the future.

Subterra considers the following principles to be absolutely essential and any breach of these principles will not be tolerated:

  1. Compliance with the laws of the Czech Republic and countries in which Subterra operates.
  2. Emphasis on credibility, professionalism and stability.
  3. Customer satisfaction, but never at the cost of violating ethical, legal or other standards.
  4. Social responsibility towards citizens of countries, regions, cities, municipalities where Subterra operates in business.
  5. Respect for the rights and obligations of all Subterra employees and associates. Respect for the rights and obligations of all Subterra employees and associates.
  6. Conflict of any personal interests with the interests of Subterra or the Metrostav Group will not be tolerated.
  7. Protection of movable property, real estate, and intellectual property to the maximum extent possible.

B) Binding Principles for Contractors

With respect to the aforementioned principles, the contracting partner (hereinafter referred to as the Partner) declares that it acknowledges and will adhere to the principles enshrined in this Code of Conduct, especially in the context below. The Partner undertakes to transfer the principles set out in this Code of Conduct into cooperation with other contractors (subcontractors), including the requirement to comply with them.

The Partner is obliged and undertakes to observe the following principles in particular:

The Partner undertakes to respect the legal order and ethical standards of the countries in which it operates. At the same time, the Partner undertakes to comply with other standards (eg technical standards) if their compliance is expressly required by law, in the framework of concluded contracts or on the basis of existing business and / or industry practices. The Partner also undertakes to monitor and respond to changes in legislation, other standards and ethical rules in a reasonable manner.

In the course of its business and market activity, the Partner shall refrain from any action which could be considered illegal, unethical or immoral. Likewise, the Partner shall refrain from any conduct that could be viewed as corrupt or as a conflict of interest and shall not tolerate such conduct to other persons with whom it cooperates or acts in the course of its business activities.

The Partner is always committed to acting professionally and with the utmost professional care, building relationships based on trust within the company and outside the company. The Partner undertakes to cooperate only with persons who are qualified and trustworthy. The Partner undertakes to use for the fulfillment of duties and obligations exclusively persons qualified for this purpose, having an adequate professional qualification and meeting legal and contractual requirements.

The Partner undertakes not to tolerate corruption, bribery or unfair competition. The Partner undertakes not to grant or accept, directly or indirectly, any payments or other remuneration that should lead to acts in violation of laws or ethical standards. The Partner undertakes to cooperate only with persons who do not have a conflict of interest and the funds they have come from legitimate sources.

The Partner undertakes to ensure the security of the information and the protection of the data it obtains in cooperation with Subterra.

The Partner undertakes to try and work towards minimizing the negative impacts of its business activities on the environment.

The Partner undertakes not to tolerate any form of harassment or discrimination and to guarantee equal opportunities to people irrespective of gender, skin color, ethnicity, race, nationality, religion or other different characteristics, including proper protection of their personal data. The partner undertakes to be friendly and considerate, especially to disabled, seriously ill, seniors and families with children. In accordance with the law, the Partner recognizes the right of employees to create or join unions.

The Partner undertakes to protect and carefully maintain movable property, real estate, intellectual property, and trade secrets of itself and Subterra or other Metrostav Group companies.

C) Reporting unlawful and unethical conduct

The Partner undertakes to inform Subterra of any facts of which it is aware and which indicate any existing or imminent violation of legal, ethical or other standards. At the same time as providing the information, the Partner undertakes to take measures to prevent further occurrence of the undesirable situation which could possibly lead to further damage or to minimize the extent of the existing damage.

D) Ethics lines – contacts

The Subterra Ethics Line or Metrostav Group Ethics Line is used to alert the company of existing or imminent violations of legal, ethical and other standards.

The Partner acknowledges that the Subterra Ethics Line and the Metrostav Group Ethics Line are not intended to resolve daily business disputes or to resolve personal disputes. The above mentioned lines are not used to register complaints or claims of bad or insufficient work practice. The lines are not intended for reporting unusual events that require the involvement of the Emergency Response Services (police, emergency services, firefighters, etc.).

Lines

Subterra Ethics Line

compliance@subterra.cz

Metrostav Group Ethics Line

www.skupinametrostav.cz/en/code-of-ethics
Tel. +420 800 120 111 ( answering machine)

GDPR (privacy) link

osobniudaje@subterra.cz

Protection of personal data

Subterra a.s., business address Koželužská 2246/5, Libeň, 180 00 Prague 8, ID No. 45309612 is the administrator of personal data (hereinafter referred to as the Administrator).

There is no permanent Data Protection Officer working with the Administrator.

Information on the processing of personal data is provided by:

Lenka Mrkvičková, head of the Labour Relations Office, LMrkvickova@subterra.cz

The Administrator processes the personal data of data subjects for the purpose of fulfilling the employer’s obligations arising from labour relations, collective agreements and generally binding legal regulations, concluding and fulfilling contracts with business partners, enabling professional practice, ensuring the protection of the administrator’s assets, which are contained in a monitored area, and fulfilment of obligations towards relevant public authorities.

If the data subject believes that his / her personal data are being processed in violation of legal regulations, he / she has the right to file a complaint with the Office of Personal Data Protection, office address at Pplk. Sochora 727/27, 170 00 Prague 7, Czech Republic. Contact details are available at www.uoou.cz.

The data subject has the right to access, rectify, limit processing or delete personal data.

If you find that your privacy has been violated, please report this to e-mail osobniudaje@subterra.cz.