Purchasing policy
SUSTAINABLE PROCUREMENT POLICY And Procurement Codes of Conduct
SC Pehart Tec GRUP SRL, producer of tissue paper and tissue paper products, has established its procurement policy as an integral part of the company’s overall objective, to satisfy customer requirements, to manage production processes in an efficient manner and to comply with the requirements imposed by the integrated management system.
We are aware that in order to continuously improve the quality of our products and work standards, we must rely on the suppliers selected for our production process. Pehart Grup believes that working together with our suppliers for a sustainable business will create a positive result for both parties.
The procurement policy of Pehart Tec Grup S.A. is correlated with the quality standards (SR EN ISO 9001), product safety (IFS HPC), environment (SR EN ISO 14001) and SSM (SR ISO 45001), but at the same time it contains specific requirements based on the Code of Conduct of the company’s employees.
This ensures the general conditions regarding:
a) the quality of purchased products and services
b) product safety / chemical management
c) environmental protection
d) social responsibility
e) the code of conduct of the employees of the purchasing department.
f) the code of conduct of our suppliers.
We will be permanently involved in a continuous process of improving the overall performance of our purchasing and supply activities. Therefore, in our supplier selection and evaluation system, their degree and capacity for innovation, process improvement and involvement will be of great importance.
We are committed to managing the risks and negative environmental impacts in our supply chain and to selecting suppliers that implement the best environmental practices
Date: 23.05.2025
Chief Executive Officer,
STANCIU GABRIEL
This procurement policy applies to all suppliers of materials and services of SC Pehart Tec GRUP SRL. This document contains the quality and sustainable development requirements required of its suppliers by Pehart Tec GRUP SRL and refers to international standards and defines the specific business requirements of our company.
In this document, the term “material” includes materials, packaging materials, chemical substances and preparations, services as well as merchandise. Merchandise can be ready-made hygiene products, cosmetic products, detergents, biocidal products, dispensers, as well as promotional items and others.
If a supplier’s production takes place on separate sites, or if part of its production process is subcontracted, the requirements of this standard continue to apply in full and include all subcontractors.
a) Quality
Our company’s adherence to the principles underlying the ISO 9001 standard aims to achieve maximum efficiency and high quality of our products. At the same time, as a result of the implementation of these standards, the entire process of our company has become customer-oriented.
Therefore, our company has assumed the following principles:
− the production process must be very safe and capable of helping to achieve the overall objectives
− process capabilities must reach the required specifications and these must be able to be continuously improved
− preventive actions to avoid defects are preferable to quality control actions and correction of non-conformities
− any detected defect must lead to corrective and preventive action
As a result of the above, Pehart Tec GRUP SRL suppliers must ensure that:
• the supplied products (raw materials, auxiliary materials, equipment, services, etc.) comply with the supply requirements and are correlated with their current and contractual technical specifications;
• each delivery of materials as previously referred to must be accompanied by transport documents, testing and quality certification documents as well as any other documents required according to the laws and regulations in force;
• to have its own system that allows the traceability of the materials/components used in the production of the delivered materials;
• will allow visits carried out by Pehart Tec GRUP SRL or by other bodies designated by Pehart Tec GRUP SRL necessary to assess the degree of satisfaction of the requirements related to the quality and safety of the delivered products and the technological processes necessary for their manufacture;
• the interaction between the supplier and Pehart Tec GRUP SRL will be documented, any introduction of a new product into our company’s manufacturing process being made only based on the PS 34 Procurement system procedure, using all the forms specified therein;
• all commercial reports will be the subject of a contract;
• all materials must be defined by an agreed technical specification or technical data sheet, and with a unique identification code, both during constant supply and in the development phases. Suppliers cannot make changes to the raw materials/components used or to the packaging methods unless these have been communicated to Pehart Tec GRUP SRL and accepted;
• all delivered materials will comply with the requirements imposed by national and international standards regarding product safety, environmental protection and OHS
• prior to the start of commercial collaboration, the supplier’s activity and the purchased products may be subject to a risk audit regarding product safety, as defined by the IFS-HPC standard
At the same time, in order to ensure that the above requirements are met, Pehart Tec GRUP SRL will act using any of the measures below:
• the extent of control applied to suppliers of raw materials, materials, services, etc. is done depending on the final products obtained;
• the evaluation and selection of suppliers is based on the evaluation criteria specific to the organization;
• potential suppliers will be analyzed according to their qualification procedure as well as risk assessment;
• annually, the collaboration between suppliers and Pehart Tec GRUP SRL will be evaluated in terms of performance indicators regarding the collaboration, as well as in terms of social responsibility, environmental impact and safety of the products supplied; this evaluation will establish the list of suppliers approved by our company;
• there are records of the results of the evaluations and re-evaluations of raw materials, materials, equipment to be purchased;
• the results of the validation of new products are kept.
b) Product Safety
Due to its focus on the end customer, Pehart Tec GRUP SRL has established procedures through which it wants to achieve the safety of the finished product from the consumer’s point of view, applying and obtaining at the same time the SR ISO 45001 and IFS HPC certifications. Based on this, all supplied materials must be accompanied by documents that will demonstrate the safety of the products and their use and handling.
Suppliers will send with each delivery, the following documents:
• technical data sheet of the product
• safety data sheet of the product with the specifications required by the various regulations and laws in force (e.g. REACH Regulation EC 1907/2006, special handling/storage requirements, etc.)
• information on toxicological tests already carried out
• information on tests specific to the food and cosmetics industry already carried out
• information on the various product safety tests already carried out (fire resistance, etc.)
• clear information on the presence of chemical substances
Prevention of contamination and control of the degree of hygiene: – the production of materials for Pehart Tec GRUP SRL will take place under well -controlled conditions. These conditions will also include actions to prevent contamination and control the level of hygiene both within the production process and during handling and transport
• All chemical substances supplied must comply with the legislation applicable to these types of materials. Suppliers may be required to follow the legislation valid for other countries and not only Romania or the EU if the finished product is delivered to those states.
• All suppliers must submit upon request information to attest that their activity is carried out in compliance with the norms regarding occupational safety and health as well as the fact that their activity is carried out in compliance with the labor legislation in force and other regulations regarding social responsibility.
In order to avoid contamination that may occur during the transportation of raw materials, materials and the finished product, the transport service providers of SC PEHART TEC GRUP SRL or the suppliers of raw materials and materials that also ensure their transportation will have to ensure that the following requirements are met:
1. Vehicles intended for the transport of goods must not contain unpleasant odors, must not have dust inside the means of transport, humidity, pests, mold or any other factors that may contaminate the transported products.
2. In the event that the goods must be transported or loaded under certain specific conditions (temperature, size, etc.), conditions well defined in the transport order, the vehicle intended for transport must be able to provide the required conditions.
3. The carrier is obliged to draw up a documented maintenance and repair program so that the repair or maintenance actions carried out do not affect or contaminate the transported products. Records of repair and maintenance work and corrective actions taken shall be kept.
4. The carrier is obliged to carry out periodic repairs so that the product requirements are not affected. Such work shall be documented and a short -term deadline shall be established to eliminate the fault.
5. All materials used for maintenance and repairs shall be maintained for their intended purpose (solvents, oils, etc.)
Transport invoices must be accompanied by signed and stamped supporting documents.
1. In the event that the conditions mentioned in points 1-6 are not met, we reserve the right to refuse loading or payment of the transport invoice.
2. Throughout the transport, the carrier is directly responsible for the transported productsand any contamination or destruction there of is borne exclusively by the carrier.
c) Protejarea mediului inconjurator
Pehart Tec GRUP SRL pays special attention to environmental protection aspects and as a result has implemented and obtained the certification SR EN ISO 14001.
Suppliers, in turn, must demonstrate that they adhere to the principles underlying this certification and that they will provide us with all the support in achieving the assumed objectives. Therefore, our suppliers must be able to demonstrate at any time that they comply with the regulations in force in the field of environmental protection.
Since cellulose is the most common raw material used by Pehart Tec Grup SRL, we pay special attention to it from the point of view of environmental protection. Thus, cellulose suppliers must use wood only from known sources.
Cellulose from wood with the following sources is not accepted:
• illegally cut wood
• wood from areas where logging violates human rights or the rights of indigenous peoples
• wood from protected forests
• wood from protected parks or areas under the law
Pulp suppliers must have reliable systems and documented procedures that allow for adequate control of the supply chain and traceability of the origin of wood raw materials.
This should ultimately be verified by an independent certification body.
Pehart Tec Grup SRL has committed to using only FSC certified cellulose in its own production process and therefore requires its suppliers to provide it with a declaration attesting to this for each delivery.
In order to achieve the above targets, the company has set itself the goal of achieving a Global Level of Sustainable Procurement. The objective is to educate all employees or new members of the procurement team on environmental issues in the supply chain by the end of 2025 (base year 2023).
d) Social responsibility
Sustainable procurement is a process by which an organization integrates environmental, social and economic criteria into its procurement process, with the aim of minimizing negative impacts on society and the environment and maximizing long-term benefits. This process helps promote corporate responsibility and contr ibutes to sustainable development.
The supply chain can have significant social risks that affect both suppliers’ employees and local communities. Understanding these issues is essential for responsible procurement management.
Our company’s suppliers are required to adhere to the best practices of social responsibility, actively demonstrating compliance with the following principles:
a. Human rights
– Respect for internationally recognized fundamental rights: freedom of association, elimination of forced and child labor, elimination of discrimination.
– The ILO Conventions and the Universal Declaration of Human Rights are reference documents.
b. Working conditions
– Reasonable working hours, fair wages and timely payment.
– Safe and healthy working conditions to prevent accidents and occupational diseases.
– Respect for the right to social dialogue and collective bargaining.
c. Equality and non-discrimination
– Policies that ensure equal opportunities for all employees, without discrimination on the basis of gender, age, ethnicity, religion or sexual orientation.
– Combating harassment and abuse in the workplace.
d. Forced and child labor
– Identifying and preventing practices involving forced labor or the exploitation of children.
– Respecting the legal age for employment and ensuring a protected environment for young people.
To ensure compliance with these social criteria, contractual clauses and commercial conditions must be clear and enforceable.
e) Pehart Group employee code of conduct
The Code of Conduct at Pehart Tec GRUP SRL was established in 2009 and defined a series of standards that have continuously contributed to the creation of the values that underlie our company: Professionalism, Fairness and Respect.
Integrity and ethics are considered characteristic elements of the way business is conducted within Pehart Tec Grup. To reinforce this aspect, it is prohibited to develop commercial business with companies owned (or in which they are shareholders) by employees of Pehart Tec GRUP SRL, or by their 2nd or 3rd degree relatives.
The way we treat each other, interact with customers and suppliers and show our respect for laws and regulations, contributes to the image of Pehart Tec as an involved company with high moral standing.
Correct actions are based primarily on honesty, professionalism and dignity. At the same time, acting correctly depends on how well we judge things and how receptive we are to how we are seen by others and how they may interpret our actions.
Through our daily activity, each of us is responsible for the image that the world forms about Pehart Tec Grup. By demonstrating loyalty and consistency, we will ensure the continued trust that we enjoy from our customers.
The principles of the Code of Conduct are the basis of our actions, contributing to the identification of strategic priorities and decision-making in current activity. They show clearly what the company can and cannot do, being a guarantee for the correctness of our actions and standards.
Based on the above premises, a supplier is expected to conduct business relations with Pehart Tec GRUP SRL in a transparent and ethical manner, and must not propose or participate in any illegal action, act of corruption or improper business practices.
The supplier is obliged to immediately inform the management of Pehart Tec GRUP SRL if he has knowledge of any activity of this nature.
At the same time, Pehart Tec GRUP SRL suppliers are prohibited from using child labor or from using the use of force and forcing other people to work for his benefit through corporal punitive actions or any other form of abuse.
At the same time, Pehart Tec GRUP SRL requires its suppliers to maintain the confidentiality of information resulting from the conduct of commercial activities between our companies.
f) Pehart Tec Grup SRL supplier code of conduct
1. Compliance with the law, internal guidelines and procurement policies
As a regional company, PEHART TEC GRUP SRL is subject to a wide variety of laws and regulations in each country in which we operate. This requires that, in addition to complying with all applicable policies in Romania, it is mandatory for all our collaborators to also comply with the law and regulations of the legal systems in which we operate. Any violation of the law, this Code of Conduct or any PEHART GRUP internal guidelines or policies by a supplier may result in disciplinary action or the calculation of penalties.
1. Competition and Antitrust Laws.
PEHART TEC GRUP is committed to promoting free and fair competition, without unlawful restrictions or cartel agreements. Violations of competition or antitrust laws can have serious consequences for PEHART GRUP, our reputation and the employee involved: significant penalties, civil liability, cancellation of contracts and/or criminal prosecution.
Therefore, each supplier of PEHART GRUP must comply at all times with all applicable competition and antitrust laws in the countries in which we operate and compete with our competitors only on the basis of price, products, quality and services offered by PEHART GRUP.
An illegal agreement does not necessarily have to be in writing: “collusion” or concertedpractices aimed at restricting competition are also illegal, even if they do not produce concrete anti-competitive effects. In case of doubt, the supplier must seek the advice of the local legal team or the Legal department before acting.
PEHART GRUP employees must refrain from any behavior that could even create the perception of an illegal practice. Examples of prohibited conduct:
– Communicating with a competitor about prices, customers, territories, offers, profit margins,
costs;
– Imposing or influencing a customer’s resale price;
– Abuse of a dominant position;
– Exclusivity agreements;
– Granting unjustified advantages to some customers (special discounts, free shipping,
unusual commissions);
– Conditional selling practices, refusals to collaborate or boycotts.
3. Prevention of bribery, corruption and fraud
PEHART TEC GRUP does not engage in any form of bribery or corruption to obtain commercial advantages. All collaborators must refrain from any behavior that could be considered improper or illegal.
It is strictly prohibited to offer, promise or grant, directly or indirectly, any improper advantage to public officials or private representatives, with the aim of:
– Influence decisions or acts;
– Obtain unjustified advantages;
– Use influence to affect an official act.
Gifts, favors, sponsorships, donations or charitable contributions that create conflicts of interest are not accepted. In case of doubt, consult your direct superior. PEHART TEC GRUP does not grant or accept political contributions.
4.Money Laundering
PEHART TEC GRUP policy prohibits doing business with individuals or entities involved in illegal activities. All employees must comply with local and international anti -money laundering laws. Any suspicious financial transactions (e.g. large cash payments) must be reported immediately to the direct Manager.
5. Insider Trading
PEHART TEC GRUP supports fair trading of securities and prohibits the use of insider information. Employees may not disclose or use non-public information about PEHART TEC GRUP or other companies to buy or sell securities. Insider information includes, but is not limited to: mergers and acquisitions, major lawsuits, dividend distributions, management changes, new strategies or unexpected financial results. Violation of this policy will result in disciplinary action and criminal liability.
6. Conflict of interest
Conflicts of interest – or the appearance of them – must be avoided. A conflict arises when personal interests affect decisions in favor of PEHART TEC GRUP. Examples:
– Awarding contracts based on personal relationships;
– Recruiting relatives without objective evaluation;
– Participating in activities that compete with PEHART TEC GRUP
– Holding a financial stake of more than 1% in a competing or partner company.
Any potential conflict of interest must be reported immediately to the contract manager.
7. Compliance with foreign trade regulations
– All PEHART GRUP companies comply with national and international laws on export control, imports and embargoes. Collaborators must conduct due diligence and follow internal procedures to avoid serious sanctions and reputational damage.
8. Financial records, records and reporting
– The accuracy and integrity of financial records and reports are essential. Collaborators must ensure that:
– – The data is accurate, complete and submitted on time;
– – It faithfully reflects the transactions and financial position;
– – It complies with applicable accounting and tax legislation.
Any doubt regarding the accuracy of the records must be reported immediately to the contract manager.
1. Confidentiality
Confidential information about PEHART TEC GRUP, products, raw materials, technologies, suppliers, customers or partners may not be disclosed or used for personal purposes, except as provided for by confidentiality agreements or legal obligations.
Confidential information includes customer lists, prices, processes, know-how, trade secrets, business plans, etc. Any unauthorized disclosure must be reported immediately.
10. Data protection and information security
PEHART TEC GRUP respects privacy rights and the law on the protection of personal data. Any unlawful processing of data is prohibited. Data must be protected against unauthorized access. Doubts regarding the compliance of procedures can be discussed with the Data Protection Officer.
Information security involves maintaining the confidentiality, integrity and availability of data. Collaborators must use information systems in a legal, ethical manner and in accordance with internal security policies and report security incidents to the responsible regional officer.
11 . Management and protection of PEHART TEC GRUP assets
PEHART TEC GRUP’s tangible (equipment, materials, etc.) and intangible (patents, software, know-how) assets must be used with care and exclusively for professional purposes. Any unauthorized use or misappropriation is prohibited.
12. Human rights and labor practices
PEHART TEC GRUP supports and respects human rights and labor standards. We do not tolerate human rights abuses and monitor the supply chain through periodic audits.
a) Equal treatment
We promote equal opportunities and fair treatment, without discrimination based on origin, gender, sexual orientation, religion, age, disabilities, etc. Any form of discrimination, harassment or intimidation is prohibited.
b) Fair working conditions
We respect the legislation on health and safety at work, prohibit forced and child labor, respect the minimum wage and legal working hours, as well as the right to association and collective bargaining. Violations must be reported immediately to the superior, the HR department.
Violation of these clauses by our suppliers may result in the calculation of penalties related to the total value of commercial exchanges between the parties, or the immediate cessation of any collaboration until the situations that have arisen are remedied.
13. Health, safety and environmental protection
PEHART GRUP complies with all legal requirements for the environment and occupational safety and promotes continuous improvement of processes. According to this principle, we ask our suppliers to:
– Protect the health and safety of employees and communities;
– Responsible management of natural resources and minimize the impact on soil, water and air;
– Ensuring the correct handling of products throughout the entire life cycle (purchase, manufacturing, packaging, classification, storage, disposal), communicating safety instructions and good handling practices to suppliers.
Violation of these clauses by our suppliers may result in the calculation of penalties related to the total value of commercial exchanges between the parties, or the immediate cessation of any collaboration until the situations that have arisen are remedied.
14. Compliance Management System
– PEHART GRUP requires employees to establish and implement:
– Compliance organization and risk management
– Internal structures and controls to ensure compliance with laws and policies.
– Policies and procedures
– Corporate guidelines and procedures that establish compliance requirements.
– Monitoring
– Periodic evaluations and audits to verify the effectiveness of the measures taken.
– Training
– Mandatory training programs.
– Whistleblowing channel
– Secure and confidential processes for internal and external reporting of violations, including the possibility of anonymous reporting. Anyone reporting a complaint in good faith will be protected against any retaliation.
Date: 23.05.2025
Chief Executive Officer,
STANCIU GABRIEL