This Code of Ethics sets out the fundamental principles and rules of conduct in ADD d.o.o., Ljubljana (hereinafter: the Company).
The Code applies to all persons who work in or cooperate with the Company, regardless of the legal basis of cooperation (employees, management, contractual partners, students, interns, external contractors, and any other persons acting on behalf of or for the account of the Company).
The purpose of the Code is to:
- protect the integrity, reputation, and trust in the Company,
- guide everyday decision-making and behaviour,
- promote lawful, responsible, and transparent business operations,
- safeguard personal data, information, and information systems,
- strengthen a safe, respectful, and inclusive working environment.
The Code cannot cover every possible situation. In case of doubt, we act in line with the principles of integrity, sound judgement, applicable legislation, and internal rules, and seek timely guidance from a supervisor.
2. Our Core Values
The Company operates based on the following values:
2.1. Integrity
The Company operates based on the following values:
2.2 Responsibility
We take responsibility for our work, decisions, and their consequences. We perform tasks diligently, conscientiously, and on time.
2.3 Respect
We respect colleagues, users, customers, partners, and other stakeholders. We communicate with dignity, without insults, humiliation, or discrimination.
2.4. Confidentiality and Security
We protect confidential information, personal data, trade secrets, and information systems. We handle information based on the principle of confidentiality.
2.5. Professionalism and Qualit
We perform our work professionally, with appropriate care and in accordance with quality standards. We continuously develop our knowledge and improve our processes.
3. Responsible Innovation
As a Company, we develop and use technologies responsibly, safely, and with consideration for their impact on people, privacy, society, and the environment.
4. General Rules of Conduct
4.1 Legality and Compliance
In our work, we comply with:
– applicable legislation,
– regulations,
– contractual obligations,
– internal acts, policies, and procedures of the Company,
– professional standards for our field of work.
4.2. Acting in the Interest of the Company
We act in the best interest of the Company and its legitimate business objectives. We do not use our position, authority, access rights, or information for personal benefit or for the benefit of third parties.
4.3. Leading by Example
Management and leaders create a culture of integrity, respect, safety, and responsibility through their own behaviour. They are obliged to explain rules, support employees in ethical dilemmas, and act promptly when violations are identified.
5. Interpersonal Relations and Work Environment
5.1. Respectful and Inclusive Environment
The Company fosters a work environment in which the following are prohibited:
– discrimination,
– harassment,
– bullying
– intimidation,
– offensive or humiliating communication,
– retaliatory behaviour.
We consider diversity, inclusion, and respect for human rights as an integral part of responsible business.
5.2. Professional Communication
We communicate clearly, respectfully, and constructively. We provide criticism professionally and with the goal of improvement, never humiliation.
5.3. Alcohol, Drugs, and Other Misuse
It is not permitted to perform work at the workplace or on behalf of the Company under the influence of alcohol, illegal drugs, or other substances that impair judgement, safety, or work ability, unless otherwise permitted by law or internal rules (e.g. prescribed medication used according to instructions and without impact on safety).
6. Responsibility Toward Customers, Users, and Partners
6.1. Fair and Transparent Business
We conduct business with customers, users, and partners in an honest, professional, and transparent manner. We do not provide misleading information, conceal material risks, or make commitments we cannot responsibly fulfil.
6.2. Quality of Services and Solutions responsibly fulfil.
We develop, implement, and maintain solutions that ensure an appropriate level of quality, safety, reliability, and traceability.
6.3. Responsible Relations with External Partners
External partners are selected based on objective, verifiable, and non-discriminatory criteria (expertise, reliability, integrity, compliance, security, quality, references, capability to deliver). We expect them to adhere to the same ethical standards we follow.
6.4. Fair Competition
We respect competition laws and do not engage in agreements, coordination, or practices that restrict competition or are otherwise unlawful.
7. Prevention of Corruption
7.1. Zero Tolerance for Corruption
The Company has zero tolerance for corruption, bribery, and other forms of improper influence. It is prohibited to directly or indirectly promise, offer, give, request, or accept benefits to influence business decisions.
7.2. Fraud
We do not tolerate fraud, forgery, concealment of facts, or any conduct intended to obtain unjustified gain or to cause harm to the Company, customers, or third parties.
8. Protection of Personal Data, Confidential Information, and Business Documentation
8.1. Personal Data Protection
We process personal data of employees, customers, users, partners, and other individuals lawfully, fairly, transparently, and in the minimal necessary scope. Access is granted only to those who need it for their work.
We recognise that privacy and personal data protection are fundamental rights; therefore, we act with particular care in collecting, using, storing, transferring, and deleting data.
8.2. Confidential Information and Trade Secrets
We do not disclose confidential information to unauthorised persons, regardless of its form (oral, written, electronic, visual, or other). Confidentiality remains binding even after employment or cooperation ends
8.3. Handling Documentation and Records
Business documentation, technical documentation, project records, logs, contracts, minutes, emails, and other records must be kept truthfully, accurately, completely, and traceably. Documentation may not be destroyed, concealed, altered, or made unusable contrary to rules or prescribed retention periods.
9. Information Security and Responsible Use of Technology
As a company operating in the field of information technology, we devote special attention to information security. Each individual is responsible for the secure use of IT assets, systems, and data.
9.1. Permitted Use of Systems
Information systems, applications, user accounts, access rights, and technical equipment must be used lawfully, with authorisation, safely, and in accordance with internal policies.
9.2. Prohibited Conduct
The following is especially prohibited:
– unauthorised access to information or telecommunications systems,
– using another person’s accounts, passwords, keys, or access tools without permission,
– attempting to obtain or distribute access credentials without authorisation,
– installing or using malicious code, tools, or software intended to damage systems
– unauthorised interception, interruption, or disruption of communications,
– intentional deletion, alteration, damage, or disabling of systems or data,
– using unlicensed software,
forging or using false electronic documents or records.
9.3. Safe Use of Tools and New Technologies
We use only approved tools, services, and applications, or those authorised through the internal approval process. Before using new technologies (e.g. cloud services, AI tools, development tools, plugins), we assess security, contractual, licensing, and data risks.
9.4. Security Incidents
Any suspected security incident (e.g. phishing, unauthorised access, lost device, data exposure, malware, unusual system behaviour) must be reported immediately in accordance with internal procedures.
9.5. Development and Testing
During development, testing, and maintenance of IT solutions, we follow security and privacy-by-design principles, environment separation, minimal access, change traceability, and proper handling of vulnerabilities.
10. Company Assets and Intellectual Property
Company assets (hardware, software, infrastructure, documentation, data, trademarks, code, know-how, business information, research, innovations) must be used carefully and exclusively for lawful business purposes.
11. Separation of Business and Private Activities & Public Communication
11.1. Separation of Roles
In private life, we speak in our own name unless explicitly authorised to represent the Company. Personal views must not be presented as Company positions.
11.2. Social Media
When using social media privately, we do not disclose trade secrets, internal information, customer data, or other confidential content. We maintain respectful and dignified communication even in personal posts.
12. Reporting Violations, Ethical Dilemmas & Whistleblower Protection
12.1. Duty to Speak Up
If we detect illegal, unethical, or otherwise inappropriate behaviour, we are obliged to report it. We strive to maintain a strong “speak-up” culture.
12.2. Reporting Channels
In case of suspected irregularities, the following reporting channels are available:
- by email: zaupnik@add.si,
- in writing to: ADD trgovina, inženiring, vzdrževanje d.o.o., Tbilisijska ulica 85, 1000 Ljubljana, addressed “to the confidential adviser for internal reporting – do not open”
12.3. Confidentiality and Handling Reports
Reports are handled confidentially, impartially, promptly, and objectively. All persons involved must protect the whistleblower’s identity and the integrity of the process.
12.4. Prohibition of Retaliation
The Company does not tolerate retaliation against anyone who, in good faith, submits a report, raises concerns, or participates in an investigation. Retaliation is a separate violation of the Code.
13. Responsible Decision-Making in Ethical Dilemmas
When uncertain how to act, we ask ourselves at least the following questions:
– Is the behaviour lawful?
– Is the behaviour in line with internal rules and this Code?
– Is the behaviour fair and professional?
– Would the behaviour be acceptable if reported by the media or explained to a customer?
– Am I acting in the interest of the Company and not for personal benefit?
– Could the behaviour harm trust, reputation, safety, or the rights of others?
– Who is affected by the decision (customers, colleagues, partners, the public)?
– Have I asked the responsible person for advice if in doubt?
– Have I asked the responsible person for advice if in doubt?
14. Training, Implementation, and Responsibility for the Code
14.1. Familiarisation
All employees are acquainted with the Code at the start of cooperation and regularly thereafter, as needed.
14.2. Duty to Understand and Comply
Each individual is responsible for understanding and complying with the Code in their work.
14.3. Violations and Consequences
Non-compliance with the Code constitutes a breach of obligations and may result in employment-related, contractual, liability, disciplinary, administrative, or criminal consequences, depending on the nature of the violation.
14.4. Custodian of the Code and Updates
Management is responsible for interpreting, monitoring implementation, and proposing updates to the Code. The Code is reviewed and updated as necessary due to changes in legislation, business models, technologies, or identified risks
15. Final Provisions
This Code of Ethics enters into force and applies as of 01 January 2026.
The Code is published on the Company’s website and intranet and is binding on all persons to whom it applies.
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