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Code of conduct

Code of conduct for service providers provided by professionals

Pursuant to the Terms of Use of the information technology company services and the associated road assistance package services (hereinafter: Terms of Use) from 24th May 2022, which are in application from 1st June 2022, company VOZZi Operations B.V., Weerdestein 1, 1083 GG Amsterdam, The Netherlands (hereinafter: the Company), represented by the director Vladimir Sijakovic, on 23rd June 2022 brings the following

CODE OF CONDUCT FOR SERVICE PROVIDERS PROVIDED BY PROFESSIONALS

PREAMBLE

Due to the need to harmonize its business with the needs of the market and basic moral principles, as well as to improve relationships with professionals, as well as relationships with clients, service users, business partners, the public and the wider environment, the Company with this Code of Conduct regulates issues related to professional ethics and rules of conduct for service providers provided by Professionals, and sets out its principles and rules.

SUBJECT AND SCOPE OF APPLICATION

Article 1

The Code is not only an internal act of the Company, but also produces legal effect on those persons who enter into a contractual relationship with the Company in accordance with the Terms of Use as a Professional, as well as on persons who come into direct contact with users of the Company’s services, that is, the service providers of those Professionals (hereinafter, jointly: the Executives). All executives are obliged to treat the users of services, as well as the public and the widest environment in the performance of their contractual obligations in accordance with the Code, and perform the services they provide according to the rules and recommendations of the Code.

Article 2

In its business, the Company unreservedly supports the idea that in business, as well as in life, only a correct relationship and responsible behavior ensures mutual trust and respect in interpersonal and business relationships.

Article 3

The Company’s business is based on compliance with laws, other regulations, general acts, contracts between economic entities and business customs. The Company’s obligation is to provide quality, clear and credible information to potential and current users of its services.

Article 4

In addition to all executives, the principles and rules of this Code are binding on all persons who are engaged in the name and / or on behalf of the Company to perform any activity. Their non-compliance implies determining responsibility and taking disciplinary measures, including termination of engagement, i.e. contractual relationship.

KEY PRINCIPLES OF THE EXECUTIVE

Article 5

Be an ambassador. Ensure that content related to you, such as texts, images, or videos, and is consistent with how you present yourself at work. This is especially important if you represent the Company in doing business.

Article 6

Identification of executives / Use of clause. If you talk about the Company or the products and services provided by the Company on the Internet, it should be made clear that you are an executive with the Company.

Executives must emphasize that they do not to speak on behalf of the Company. If you run your own site or your social media profile that is associated with the company in any context, your profile should include a clause such as “The views expressed on this site are personal and not the Vozzi service or the Company providing it.” Only authorized executives are allowed to communicate and make announcements on behalf of the Company.

Article 7

Think twice. We advise executives to use filters, lists and groups within social networks to separate personal from business content they publish. Where this is not possible, we advise all executives, especially those who work directly with clients, to make their private profiles “job-friendly”.

Please think twice before complaining online about the poor quality of someone else’s goods / services. The seller of the goods or service provider you are complaining about may be a current or future business partner of the Company or a Professional, and you may be in charge of providing the service.

We advise everyone to avoid participating in heated debates and fierce debates of any kind on the Internet.

Respect your social media audience and your colleagues. This includes a ban on ethnic name-calling, racist and sexist comments, abusive language, swearing, etc. Attacks on colleagues will not be tolerated under any circumstances.

Article 8

Personal responsibility. You are personally responsible for the content you post on social media, blogs, or any other media. Please remember that the internet never forgets. This means that everything you post will be visible to a large number of people over a very long period of time. If you are unsure about the content you want to publish, consult your immediate supervisor or contact the Company.

PRINCIPLES OF BUSINESS ETHICS

Article 9

Respect for the principles and rules of business ethics includes, but is not limited to, the following principles:

  1. Professional performance of business activities;
  2. conscientious and complete undertaking and fulfillment of obligations;
  3. performing business activities in a way that does not endanger the professional reputation;
  4. use of permitted means to achieve business goals;
  5. compliance with regulations on incompatible business;
  6. keeping of business secrets;
  7. avoiding conflicts between personal and business interests;
  8. refraining from using political or other influence or pressure to achieve business goals;
  9. resolving disputes with clients, service users and business partners amicably, through negotiations or mediation, with an effort to continue business relations;
  10. performing business activities in accordance with the regulations on protection and improvement of the environment.

Article 10

Executives are obliged to respect, supplement, encourage and motivate each other in order to provide the highest quality service to users, as well as to show the same respect to those users.

Article 11

All executives are equal in terms of application of this Code, regardless of which specific Professional they are engaged with, or the type and manner of their engagement.

Article 12

Each executive has, above all, personal responsibility for the quality of the work performed.

Article 13

The relationship with users and the mutual relations of executives are based on respect for human dignity and basic human rights and freedoms.

Article 14

Executives have the obligation to adhere to the regulations governing safety and health when providing services.

Article 15

Executives are not obliged to declare (express) to anyone in any way, including, but not limited to, Company clients, other executives and third parties with whom they come into business contact, about any religious, political, trade union or any other commitment.

The executives respect each other’s stated religious, political and trade union affiliations as well as the racial, national and gender affiliation of their colleagues and it is not allowed to endanger basic human rights on any grounds.

Article 16

Good interpersonal relationships are a condition for achieving business goals. Satisfaction is achieved by adequate expression and evaluation of professional, creative, intellectual and moral values of the executives.

Article 17

All executives have a duty to act in the best interest of the user, in accordance with their powers and responsibilities.

Article 18

All executives are obliged to act professionally and to solve the problems they encounter in providing their services.

Article 19

Every executive must be disciplined, hardworking and responsible for the work he performs, honest, conscientious, open and correct in relation to others.

Article 20

Executives build their mutual relations on understanding, tolerance, respect, trust and willingness to cooperate, creating a positive working atmosphere.

Article 21

It is the obligation of every executive to adhere to basic social principles in terms of behavior in the workplace, addressing and communicating with other executives, clients, service users, business partners and others, personal tidiness and appropriate dress code, as well as tidiness of the workplace, avoiding unnecessary noise and disturbances of other executives in performing work.

Article 22

Executives are obliged to refrain from commenting on clients, service users and business partners, as well as giving inappropriate comments in any communication.

Article 23

Executives are prohibited from sharing content on social networks that is related to the Company’s business, and which could adversely affect the business reputation and reputation of the Company, as well as lead to any damage.

Article 24

It is the obligation of every executive to actively seek a solution to the problems he / she encounters in performing the service he / she provides, as well as to inform his / her superiors about them and to critically review the results of his / her actions.

Article 25

In the specific provision of services, all executives enjoy equal rights and cannot be restricted in exercising their rights regardless of gender, race, color, language, religion, national or social origin, and affiliation with a national minority, membership in political and trade union organizations, financial status, birth or other personal status.

Article 26

The use of narcotics and alcohol during the provision of services and their introduction into work premises or vehicles with which the service is provided is prohibited.

Article 27

The executive is obliged to inform his manager about the occurrence of emergency situations such as illness, personal problems, or some other reason, in order for the manager to adjust the emergency situation to the needs of the job.

Article 28

Communication in the spirit of healthy business cooperation should be imperative for all executives.

Article 29

The executives are obliged to perform the entrusted tasks in such a way that the interests of the users, i.e. the Company, are not subordinated to the private interest, nor do they cause a conflict between them. A conflict of interest exists when the executive makes a decision or influences the decision-making which creates property or non-property benefit for him or related persons, not acting exclusively in the best interest of the user or the Company.

Article 30

Executives are obliged to:

  1. not to use the property of the user or the Company in their personal interest;
  2. not to use confidential information to increase personal property or the property of other persons;
  3. not to abuse their position.

RELATIONS OF SUPERVISORS TO EXECUTIVES

Article 31

Managers and leading management of the Company and Professionals, by their engagement, appropriate behavior and respect for legal regulations, moral and ethical principles, serve as an example to executives, contribute to the development of respect and trust between executives and users.

Article 32

In relation to subordinates, managers must be correct and fair, without exceptions and biased feelings. It is necessary for them to demand expertise and responsibility from the executives and not to allow their decisions to be influenced by non-business relations (family, friends and other ties). It is necessary to encourage teamwork and discover the abilities of individuals, to provide maximum contribution to the realization of business goals and not to favor individuals.

Article 33

Managers are obliged to respect the personality of subordinates and to communicate any objections to the work and behavior of the subordinate concretely and with arguments.

Article 34

The basic obligation of the manager is to focus on goals, organize work, monitor results and take measures to improve them.

Article 35

Managers are expected to improve teamwork and team spirit and to ensure the exchange of knowledge.

Article 36

A manager can be honest, fair and consistent and serve as an example of desirable conduct and behavior.

RELATIONS OF EXECUTIVES TO SUPERIORS

Article 37

The attitude of the executives towards their superiors is based on mutual respect and esteem.

Article 38

Executives perform entrusted tasks and duties by superiors, unless they are contrary to the law or endanger their personal safety.

Article 39

Executives point out to their superiors the possibilities of more successful and efficient realization of entrusted work tasks in order to achieve better business results.

Article 40

Possible problems are solved in well-intentioned, direct and concrete communication between those who are affected by the problems, and if that is not possible, the solution should be directed to persons at a higher hierarchical level.

ATTITUDE OF EXECUTIVES TOWARDS CLIENTS – USERS

Telephone

Article 41

The executive is obliged to always be professional, interested, polite and short in a business telephone conversation.

The telephone conversation always begins with a presentation, stating the name of the executive, and a shorter name of the Company or Professional who hired him.

The executive does not leave a message for the person whose service or information is requested to call him later.

The executive responds to the business message immediately or as soon as possible.

The executive avoids private telephone conversations, especially in the presence of the user.

The executive strives to end each official conversation in a friendly and positive tone.

Letters – e-mail

Article 42

Business letters always state the Professional and the function, i.e. the position of the executive who writes the letter, as well as all the necessary contact information.

Address the letter correctly, to the person, his function and company.

The writing style adapts to the topic and the person to whom it is written.  Always check for errors in letters and other messages.

Letters and e-mails are answered immediately or as soon as possible.

If it is necessary for another executive to be acquainted with the received or sent mail, a letter or e-mail is always forwarded to that (team) person, immediately.

Meetings

Article 43

When scheduling, clearly define the purpose of the meeting.

The purpose of the meeting is also determined by the circle of persons who are invited and who attend it.

When receiving clients, executives who are not invited and are not actively involved in business should not attend the meeting.

The decision on who attends the meetings is made by the meeting organizer and, if necessary, the Company.

Upon receipt of clients, each executive must be provided with a free room (without the presence of other executives) at the scheduled date of the meeting. If this is not possible, the executives who are present due to the circumstances must not interfere in the business conversation, unless they are explicitly asked about something by the organizers of the meeting.

In business meetings, never talk about works in which you are not competent and which do not fall within the description of your job. Always include the most competent person (or more) from each area in the business meeting, according to the level of knowledge required for that meeting.

In meetings, stick to the topic of the meeting and do not make digressions, i.e. do not talk about topics that have no direct connection with the work that is being done. If the client is doing this, have an understanding for it if it is in the interest of the business, but discreetly try to bring the conversation back to the business level.

Clients that you estimate are just wasting their time and yours, prevent it in a cultural, but also clear way.

RULES ON THE USE OF SOCIAL NETWORKS

Article 44

The rules for the use of social networks are prescribed in order to define the expectations of the Company from the executives, whether they are authorized representatives of the company in the public digital space or present themselves on the Internet as the executives of the Company.

Activity on social networks during working hours and after it, the impression left by the executives at the Company and the impression of the Company or its business is the central place of these Rules.

Article 45

These rules help to protect the Company, the business and its trademark under which it operates from negative publicity by clarifying what is and what is not acceptable behavior on social networks.

Scope of application of rules on the use of social networks

Article 46

The rules on the use of social networks apply in particular to those executives who:

  • have a profile on one of the social or business networks (such as LinkedIn, Facebook, YouTube, Google+, etc.) and disclose that they are executives for the Company, either as official spokespersons or in the context of personal information; or
  • share any information related to their business in the Company or about the products and services of the Company; or
  • publish comments, reviews and other content on forums, social networks, websites or blogs, either in person or within the profession; or
  • are active on micro-blog platforms (like Twitter)

Rules for all executives

Article 47

Executives should not use social networks for private purposes during working hours.

Article 48

Only authorized persons can officially represent the Companies on any social network. If you are not sure who the authorized person is, contact the manager of the Professional or one of the Company’s representatives.

Article 49

The executives are responsible for the views expressed on social networks, which are not in accordance with these rules, therefore, discretion and domestic upbringing are appealed to.

Article 50

Executives may make a personal contribution (not as an official representative of the Company, but through posting on a personal profile) on the topic of self-activity, providing services or topics related to the Company, emphasizing that the executives are with the Company, as long as they do not represent it as the official view of the Company or offer to solve a problem related to the work of the Company. Such problems will be dealt with by authorized persons of the Company.

Article 51

Executives are not allowed to comment on a problem or topic related to the Company so that their comments (positive or negative) appear to come from someone who is not employed by the Company.

Article 52

Creating a specific group or administering an official group that publishes information about the group as well as the areas in which the Company operates requires the approval of the manager.

Article 53

If Executive wants to represent the Company as an executive or open a group, it is necessary to contact the Company.

Article 54

If Executive is contacted by a representative of the print or digital media regarding content published on the Internet regarding the Company, it is indispensable to refer that representative to the Company’s manager, explaining that executives do not have the authority to speak or make statements or comments on behalf of the Company.

Article 55

Executives may not publish any information about clients and users of the Company’s services. This applies in particular not only to the name, registration marks, time and place of service, but also to absolutely every aspect of providing the service to the user. If you are in doubt whether you can publish any information, you need to contact the manager before publishing, who will decide on the publication of such information.

Article 56

Posting on social media can lead to media announcements. If the Executive is contacted by a media representative, it is necessary to contact the Company’s Marketing Sector before answering anything and they will advise how to proceed.

Article 57

It is obligatory to respect copyright. If the Executive is not the copyright owner, must not use it. Before publishing someone’s   copyright work, it is necessary to check with the copyright owner to see if you have permission to do so.

Article 58

It is forbidden to create personal or unofficial profiles that contain elements of the brand name, for example “Marko VOZZI Markovic”, @VozziAna, @IvaVozzi or @Pera-slepanje-Vozzi and the like.

Subsidiaries and representative offices

Article 59

In order to ensure consistency and clarity of the message, subsidiaries, representative offices, their PR representatives and advertising agents may not directly publish content on the Company’s social media channels, nor run their own accounts. Requests to publish PR information or marketing information and YouTube videos should be submitted to the Company for approval and publication (if approved).

Article 60

Subsidiaries and representative offices are not allowed to initiate or be involved in running the competition on Facebook in cooperation with the Facebook pages of other brands without the consent of the Company. This applies to brands that are in partnership with the Company’s service (VOZZi) as well as people who have an impact on the Internet.

Reporting

Article 61

It is very important to immediately report any violation or potential violation of these rules, contact  supervisor or any of the Company’s agents.

In the report, it is necessary to provide the following information: name and surname, position, location of the job and information of the executive who violated or potentially violates the rules with details that are known to you. Name of the person who reported violation/potential violation will remain a secret.

Anyone who reports a suspicion of a violation or violation of these rules enjoys full protection within the Whistleblower Protection Act.

OFFICIAL CHANNELS ON SOCIAL NETWORKS AND CONTACTS

Article 62

The company has the following official channels of communication on social networks:

Article 63

The company has the following official contacts:

RESPECT OF THE POLITICAL RIGHTS OF EXECUTIVES

Article 64

Executives have the right, in accordance with the Constitution and laws, to actively participate in political life, outside working hours and outside the workplace, and the exercise of rights based on work is not conditioned by the political engagement of executives.

Article 65

It is prohibited to use your position in a business entity or the property of a business entity to provide political support to a candidate, political party, movement or group.

Article 66

Executives are not allowed to assert their status in an economic entity when acting on behalf of a political party, movement or group.

COMPETITION

Article 67

Executives may be directly or indirectly engaged by any third party to provide the same or similar services they provide to customers, without limitation, provided that the Company’s customers have an advantage in the provision of services.

Article 68

The active status of the executive in any association or organization does not require any prior or subsequent approval. Engagement of executives outside the Professional, i.e. outside the services provided to the Company’s customers, whether with or without compensation, must not jeopardize the provision of services to the Company’s customers, where the performance of work is considered endangered if it takes time and attention necessary for high quality services they provide.

BUSINESS SECRET AND CONFIDENTIAL INFORMATION

Article 69

Executives are obliged to keep a business secret that they came across in the course of their work. Any information or data whose unauthorized disclosure to third parties could harm the Company or could benefit competitors is considered a business secret.

Article 70

As required by the general acts of the Company, confidential information includes knowledge relating to, but not limited to:

  1. negotiations, contracts with clients, service users, business partners and other persons, as well as on business plans of an economic entity that are not known to the public;
  2. other ongoing or forthcoming business transactions, especially if they relate to status changes and changes in ownership structure;
  3. research and further development of the business entity, patents and innovations;
  4. data on clients, service users, business partners and executives;
  5. know-how;
  6. unpublished information on services;
  7. unpublished financial and accounting information;
  8. other information whose publication may affect the reputation of the company.

Article 71

Disclosure of information whose publication is obligatory on the basis of the law, i.e. which is related to a violation of the law, violation of good business practice or the principle of business morality, shall not be considered disclosure of a business secret or confidential data of an economic entity.

Article 72

Executives and members of their families must not use confidential information and business opportunities in order to obtain material or intangible benefits for themselves or for related persons.

Article 73

Data on service users and business relations with them have the character of confidential data and cannot be disclosed to third parties. Data on service users may be disclosed to judicial authorities without their consent only on the basis of an adequate court order.

PROHIBITION OF BRIBERY AND ACCEPTANCE OF BRIBES

Article 74

Any occurrence that constitutes a bribe must be reported to the Company immediately. Adherence to this rule is of special importance for the reputation of the Company, as well as the quality of the Company’s relations with business partners.

Article 75

The executive, or a member of his family, may not offer, give, display, promise or accept money, goods, rights, services, and gifts of greater value or the possibility of influence from another person who is in a business relationship with the Company.

Article 76

A gift of higher value is considered to be money, thing, right or service, as well as any other benefit obtained or performed without payment of appropriate monetary compensation, with compensation at a significantly lower price than the market or without appropriate counteraction, and whose value exceeds one half of the average monthly net salaries in the respective country.

Article 77

It is allowed to accept and give gifts of lesser value, unless accepting such a gift is not a condition for concluding a deal or puts the giver in a more favorable position compared to competitors.

TREATMENT OF COMPANY PROPERTY

Article 78

Preservation and increase of assets is of crucial importance for ensuring proper execution of undertaken obligations and quality of business.

Article 79

Executives are responsible for preserving, enlarging and rationally using the items that make up the Company’s assets, which are entrusted to them to perform the work.

COMPLIANCE WITH THE CODE

Article 80

Adherence to the Code is the obligation of all executives.

Article 81

The Code of Conduct for executives is directly applicable. Failure to comply with the Code constitutes a breach of contract and may be sanctioned by termination of that contract.

Article 82

The Company has a seat in Amsterdam, The Netherlands, and together with its organizational units/members of the Holding, operates both in the countries of the European Union and outside the European Union; the Company’s intention is to harmonize all its rules with jurisdictions in the countries where it operates. Therefore, if this Code violates applicable local laws, the Company will comply with local laws. In addition, the Company may adopt regional or country-specific regulations on this subject to adapt to local conditions or regulations and will notify executives in the jurisdiction where it applies.

INTERPRETATION OF THE CODE

Article 83

An executive who has doubts about the interpretation or application of any provision of this Code should contact the Company.

Article 84

The person to whom the Code applies is obliged to inform the person in charge of supervising the observance of the Code about the violation of the provisions of the Code or about the well-founded suspicion that the violation was committed by an obligated person. Managers are obliged to take the problem seriously and solve it in accordance with ethics, values and all legal regulations.

Article 85

The authentic interpretation of this Code is provided by the Director of the Company.

FINAL REGULATIONS

Article 86

The Company will regulate all possible amendments to this Code by amending (annexing) it.

Article 87

This Code has been drafted in the English language, but may be translated into other languages. In the case of a translation, only the English version produces legal effect.

Article 88

This Code shall enter into force on the eighth day from the day of its publication on the Company’s website.

In Amsterdam, on 23.06.2022

Published on 23.06.2022

Start of application on 01.07.2022

VOZZi Operations B.V.

Vladimir Sijakovic, Director

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