Created: 1st June 2024.
Version: 2
Last Update: 1st March 2025
Last revision: 1st June 2025
CODE OF ETHICS AND BUSINESS CONDUCT
Message from our managing director
One of the core principles of Manupackaging Magyarország Kft.’s operations is our commitment to ethical behaviour. Our goal is to ensure business conduct and integrity that is based on fairness, an ethical culture, and compliance.
In the long term, we can only be successful if we take responsibility for our decisions and actions—both personally and on corporate level. Our employees must act lawfully, ethically, and in the best interest of the company in all situations.
Thank you for supporting our values and contributing to maintaining proper business practices. This means for us not only providing high-quality and fairly priced products and services but also acting with integrity, honesty, and transparency at all times.
Our Code of Ethics and Business Conduct applies to all our current employees, non-employee workers, and business partners, including subcontractors, suppliers, and customers.
Together with our employees and business partners, we aim to build an economy and business environment based on mutual respect, responsibility, and accountability.
Gábor Arató
managing director
- Introduction
This Code outlines the ethical principles and business conduct guidelines that define our operation and business relationships. It applies to all our colleagues, including executives, employees, non-employee workers, subcontractors, and consultants. We expect all our business partners to respect these principles.
Our commitment to integrity and ethical behaviour is grounded in trust and credibility, which can only be achieved through ethical business practices. Leaders have a particular responsibility to set an example through their own behaviour.
- Our purpose
Our aim is to develop cutting-edge solutions to the packaging challenges of the business world and improve the quality, safety, health, and environmental aspects of storing, transporting, and distributing demanding products. We take our responsibility seriously and are committed to promoting environmentally conscious packaging, in alignment with the waste hierarchy (prevention, reduction, reuse, recycling, disposal) and the dissemination of eco-friendly solutions. We believe that building trust- and credibility-based operation and relationships is necessary to exist in a transparent and accountable economy.
We express our commitment within professional communities as well:
- UN Global Compact: While our company has not formally joined the UN Global Compact due to its small company size, we fully consider and apply these ten principles.
- BCSDH Sustainable Corporate Management Guidelines: We are a member of the Business Council for Sustainable Development in Hungary (BCSDH), and we uphold its expectations regarding transparent and ethical operations, responsible corporate governance, partnerships, and respect for core values.
- MVÜK Code of Ethics: Our Managing Director is a member of the Hungarian Business Leaders’ Forum (MVÜK), and is committed to ethical leadership, value-based relationships, personal and collective responsibility, openness, acceptance, solidarity, and trust-based management.
- Our ethical and business conduct values
Honesty
Integrity
Respect for Others
Responsibility
Reliability
Accountability
Lawfulness
Meritocracy
Culture of Learning from Mistakes
Our Code of Ethics and Business Conduct is an integral part of our Corporate Sustainability Governance Policies manual and complementary we have additional internal guidances on specific topics to strengthen our corporate responsibility governance and due diligence.
- Our Code of Conduct
This Code of Conduct supports understanding of Manupackaging’s values, guidelines, ethical principles, and key legal elements. It cannot address every question or situation, but provides a shared foundation that guides everyday behaviour, decision-making, and shapes our identity.
If an employee or business partner observes unethical or improper behaviour or intent, they are required to report it to the Managing Director. Such reports are handled confidentially, and no retaliation shall occur against those who report concerns in good faith.
The company ensures a procedure is in place to allow all stakeholders to report concerns securely and confidentially about issues such as corruption, bribery, undue advantage, information security incidents, false invoicing, harassment, or other unethical conduct addressed in this document. Reports are treated confidentially, and whistleblowers are protected against retaliation.
Reporting Methods: Reports can be submitted via email at etika@manupackaging.hu, by mail, or in person/by phone, specifying the subject, preferably addressed to the Managing Director.
Investigation Process: All reports are received by the Managing Director, who pre-evaluates their relevance. For cases requiring investigation, a three-person committee—comprising internal or external members—will be involved to ensure objective, impartial decision-making.
Consequences: Our goal by maintaining this reporting procedure and the investigations is preventing non-conformities, conduct root cause analysis in cases of incidents to prevent repetition, reduction of risks or negative impacts, or if necessary remediation. However, in cases of intentional and severe misconduct identified during the investigation (whether by the subject or the reporting party), termination of employment or business relationship may be warranted.
The company is committed to addressing all ethical matters transparently and ensuring that all employees and business partners are aware of company values and expectations. For ethical issues not covered in the current Code, the company will continuously review and revise its policies to reflect legal changes and industry best practices.
4.1 Compliance with legislation
All employees are required to comply with applicable economic, labor, environmental, and all relevant legislation and internal policies, ensuring lawful and fair business conduct. We expect employees and partners to stay informed about the latest laws and regulations, align their processes accordingly, and continuously monitor compliance to foster improvement.
4.2 Fair business conduct
We believe in free and fair competition, open and transparent business practices, and are committed to operating in compliance with competition law and fair market behaviour and rules.
What this means in practice:
We engage with competitors only in legally permitted ways, reject market-sharing or cartel-related attempts, and provide communication based on verifiable data in marketing and sales, furthermore we ensure access to quality information by stakeholders. When employees move between competitors, we respect and expect adherence to confidentiality obligations.
4.3 Anti-corruption measures
The company maintains a zero-tolerance policy for any form of corruption. Corruption includes abuse of entrusted power or position for personal gain—such as bribery, nepotism, money laundering, facilitation payments, unauthorized benefits, falsification, and other misconduct.
What this means in practice:
We reject gifts exceeding 10% of the actual legal minimum wage, do not accept compensation, commission, rewards, or facilitation payments from suppliers or customers. Attempts to influence decisions (kickbacks, bribery) must be reported to the Managing Director. Accepted gifts, if any, must be shared with the team whenever feasible.
4.4 Handling sensitive financial transactions
The company ensures that sensitive financial transactions are conducted securely, traceably, and ethically. All approvals are documented (digitally or in writing), and payments are made exclusively by authorized personnel through secure banking systems.
What this means in practice:
Ad-hoc payments require financial or executive approval. Further details are outlined in the internal regulation Financial transactions.
4.5 Confidentiality, data protection, and information security
Protecting the confidentiality on business information and personal data is of utmost importance. The company is committed to safeguarding third-party data and takes all necessary measures to prevent unauthorized access, disclosure, or misuse. We strictly comply with data protection laws, including the GDPR, and ensure all employees and partners handle shared information with the highest level of care.
What this means in practice:
Confidential information about clients or partners must never be shared with unauthorized persons, not even in casual conversations. Refer to internal policy IT and information security for further details.
4.6 Respect for human rights and values
The company respects human dignity and values, and acknowledges its responsibility to uphold human rights. We do not tolerate discrimination, harassment, child labour, or forced labour. We are committed to fair and lawful employment practices and reject discrimination based on gender, age, nationality, religion, disability, political or religious beliefs, sexual orientation, or any personal characteristic. We aim to foster an inclusive workplace and society where everyone can contribute meaningfully within our value chain.
What this means in practice:
Reports of harassment or discrimination are thoroughly investigated, and corrective and preventive actions are taken when necessary. We do not tolerate any form of unfair treatment, abusive communication, microaggressions, or behaviour that violates human dignity.
4.7 Fair Employment and working conditions
The company is committed to ensuring a safe, healthy, and fair working environment. Our goal is to prevent work-related injuries and illnesses, support physical and psychological well-being, and promote work-life balance. We endorse a family-friendly workplace atmosphere and policies. Harassment, intimidation, or workplace aggression in any form is strictly prohibited.
What this means in practice:
We set a goal of zero workplace accidents and ensure good working conditions, organization, and infrastructure. We offer competitive benefits and foster a strong sense of community through team-building initiatives and company culture. Concerns related to working conditions or work-life balance are investigated and addressed with tailored solutions. All employees are officially registered and earn a salary exceeding 105% of the legal minimum wage.
4.8 Environmental Protection
The company is committed to environmentally conscious operation that support sustainable development. Our goal is to slow climate change by mitigation practices, we strive to minimize our carbon footprint and negative environmental impacts. Through the development and promotion of sustainable packaging solutions, we support our clients in adopting eco-friendly practices.
What this means in practice:
We encourage green office practices such as energy-saving, minimizing paper usage, and promoting micromobility and public transportation. We help employees adopt more conscious habits through awareness programs.
4.9. Conflict of interest
It is crucial that all decisions serve the company’s economic interests while upholding sustainability principles. All employees must avoid conflicts of interest and report potential issues to the Managing Director.
What this means in practice:
If an employee or its relative holds a decision-making role at a supplier or customer company, it must be reported to the Managing Director. Employees may not hold positions incompatible with the company’s ethical principles or business interests.
- Closure
This Code is binding for all employees and partners and supports the maintenance of proper business practices. We regularly review the content of this Code and the awareness and trust related to this document and its intentions, and if necessary we take actions to improve.