I. Preamble

Fraport Twin Star Airport Management (hereinafter “FTSAM AD”) is a provider of high-quality airport services. In line with our basic values of honesty, integrity, trustworthiness, responsibility, transparency, loyalty, and fairness, we have high standards for doing business in a manner that is socially, economically, and ecologically sustainable for the future; we view sustainability as shaping the future responsibly.

Our reputation and good name as a company are key components of our success. All of us contribute, with all our work, each and every day to the positive image of FTSAM AD.

The Code of Conduct set out in this document reflects the culture of values we uphold at FTSAM AD and offers our employees a framework for dealing responsibly with the economic, legal, and ethical challenges of day-to-day business and taking action appropriately. FTSAM AD is committed to conserving the natural basis for life and strives to engage in environmental management to protect and preserve natural resources.

II. Scope of application

The principles of the Code of Conduct are binding on the entire Group, worldwide. They apply to all FTSAM AD employees. The FTSAM AD Code of Conduct cannot provide detailed instructions on how to act in all situations, nor is it intended to do so. Instead, it represents the general framework and the principles of action that guide FTSAM AD. How those principles are to be observed in real-world practice is, therefore, specified where necessary by internal company rules, regulations, and instructions.

Existing guidelines, collective labor agreements and internal company agreements apply without limitation alongside the Code of Conduct. Local adjustments may be made to take account of special circumstances, but must in all cases be based on the current Code of Conduct. All executives are tasked with upholding and spreading the Code of Conduct within the company and with ensuring compliance here-with. In their function as role models, they bear special responsibility in this regard.  
  

1. Compliance with laws, regulations, accepted standards, guidelines, and principles

Sustainability stands for more than just stated assumption of responsibility in the areas of the economy, ecology, and social matters. It also stands for our company’s actions in striving to fulfill its role as an accepted part of our society through uncompromising compliance with its laws, rules, and regulations.

As a result, we are committed to compliance with the applicable national laws and regulations and uphold internationally accepted standards, guidelines, and principles, especially the principles of the UN Global Compact, the Universal Declaration of Human Rights, the conventions of the United Nations, and the core labor standards of the International Labor Organization (ILO) as well as the OECD Guidelines for Multinational Enterprises.

The principles set out in the rest of this Code of Conduct must be observed by our employees and must not be circumvented through contractual agreements or comparable measures.

2. Prevention of corruption

The relevant legal provisions on fighting corruption must be observed. In our dealings with customers, suppliers, and service providers (hereinafter “Business Partners”) as well as with government institutions, the interests of FTSAM AD and the personal interests of FTSAM AD employees must be kept strictly separate by both sides. Actions and decisions, especially purchasing decisions, must always be free of non-objective considerations and personal interests. This means that money, or personal advantages or perquisites with monetary value, must never be either accepted or offered in return for preferential treatment during business dealings.

Furthermore, our employees agree not to offer, promise, request, grant, or accept any gifts, payments, invitations, or services during the course of business dealings where so doing could affect a business relationship in an impermissible manner. Our dealings with the above-mentioned advantages and perquisites are determined by the FTSAM AD principles of legal compliance, responsibility, and appropriateness.

Appreciation and respect for every human being are high priorities for us and among our core values. Cultivating and developing each and every individual’s potential for achievement lies at the heart of management’s responsibilities toward employees. We expect our employees to identify with the Company’s goals and demonstrate loyalty with regard to the Company’s interests. With that in mind, employees should avoid situations in which their personal, family, or financial interests could conflict with those of FTSAM AD. If it becomes apparent that such a conflict of interest could arise, the person concerned should disclose it and request the approval of the appropriate manager.

We encourage our employees to report corrupt and unlawful behavior. The first point of contact is the direct supervisor or the next higher manager. If an employee does not wish to contact that manager, other appropriate communication channels are available. (See final provisions > Section ii > Dealing with reports of violations).

3. Antitrust and competition law

We expect our employees and service providers to comply with all applicable national and international antitrust laws as well as the laws against unfair competition wherever relevant to the scope of their specific responsibilities. Agreements, understandings, or activities that affect prices or conditions, allocate sales territories or customers, or impede free, open competition in an impermissible manner are prohibited.

Agreements and understandings between customers and suppliers with the intent of restricting the freedom of contractual partners concerning prices and other conditions (setting of prices and conditions) are also prohibited. Reports regarding anticompetitive behavior must be directed to the direct supervisor or the next higher manager.

For questions regarding whether certain actions are permitted under competition or antitrust law, please feel free to contact your direct supervisor or the next higher manager.

4. Confidentiality, data protection and privacy

We are committed to transparent communication within the limits of business confidentiality. Our employees agree to maintain confidentiality with regard to business and trade secrets and to comply with the laws on data protection and privacy.

5. Occupational safety and health

Preventing accidents and illnesses in the workplace is a priority for FTSAM AD. We are committed to protecting and promoting good health, and we take care to ensure a safe, secure, healthful, and hygienic work environment for our employees. We provide appropriate equipment and materials and take the necessary measures to prevent accidents and adverse health effects that could arise in connection with our activities. We are committed to continuous improvement and further development of the work environment.

We expect our employees to assume personal responsibility for maintaining their health, and we support them in maintaining or developing a healthful lifestyle.

All employees receive regular information – aligned to their job and duties – on applicable health and safety standards as well as safety measures and are required to comply with the protective measures that are in place.

6. Dealing with alcohol and drugs

Health and safety are of great value to individuals and are also important to our company’s success and reputation. For these reasons, working under the influence of alcohol, drugs, and other intoxicants and consumption of these substances during working hours are strictly prohibited.

7. Working hours

We are committed to compliance with the relevant legal and collective provisions and occupational standards on working hours, paid vacation, and legal holidays as well as the relevant International Labor Organization conventions.

8. Compensation

Compensation at FTSAM AD is aligned to the relevant labor market and is under no circumstances lower than the applicable legal minimum standards or the minimum standards set by collective agreements.

9. Dealings with others

The principle of respect is a key component of the FTSAM AD culture of values. FTSAM AD stands for fair, respectful dealings with one another in a spirit of partnership. We do not tolerate any form of bullying or verbal, physical, and/or sexual coercion, violence, and/or harassment.

10. Freedom of association and collective bargaining rights

We respect the fundamental right to freedom of association and hereof the right of collective bargaining in order to settle general labor conditions within the group.

We offer the authorized bodies representing the employees an open and trustful collaboration and seek to ensure a fair exchange of interests within the group.

11. Dealing with child labor and forced labor

FTSAM AD rejects all forms of forced labor and child labor.

Age limit for recruitment is 18 years. Exceptions are possible in compliance with the applicable legislation. Adolescent employees should not be exposed to dangerous and uncertain situations or any situation that may have adverse effects on their health.

We are committed to ensuring that the rights of children and adolescents are respected. We do not tolerate any form of exploitation of children or adolescents.

12. Diversity

As an enterprise with an international alignment, FTSAM AD fosters diversity in its staff, acting according to the principle of equality and rejecting all forms of discrimination.

We are committed to prohibiting all forms of differentiation, exclusion, or preferential treatment particularly based on:

• ethnic, national, and/or social origin
• race
  
• skin color
  
• sex
• age
• religion, creed, and/or worldview
  
• political activities
  
• membership in an employee organization
  
• disability
  
• sexual orientation
  

FTSAM AD fully complies with the applicable laws and regulations.

i. Information and communications

All employees have access to the provisions of this Code of Conduct - in Bulgarian language.

Questions regarding understanding this Code of Conduct can be addressed to:

1. Elitsa Manolova, Ombudsman of FTSAM AD on tel. 052 573 232 or еlitsa.manolova@fraport-bulgaria.com
2. Milena Vasileva, Head of Integrated Management System & Internal Audit department on tel. 052 573 250 or milena.vasileva@fraport-bulgaria.com

ii. Dealing with reports of violations

We expect all employees to act responsibly and in line with the principles outlined in the Code of Conduct. We promote open, candid dealings with each other and foster a culture of mutual trust between employees and their individual managers. This applies both to the concrete meaning of the Code of Conduct in individual cases and to possible violations.

If a FTSAM AD employee does not wish to contact his or her direct supervisor or the next higher manager, there are various ways to report a violation, from noncompliance with the standards of conduct to financial criminal activities. Whistle-blowers are guaranteed protection when they use any of these reporting channels.

In addition to his immediate superior, on the website of FTSAM AD you can find other channels of communication that are available to you:

1. Elitsa Manolova, Ombudsman of FTSAM AD on tel. 052 573 232 or  еlitsa.manolova@fraport-bulgaria.com
2. The FTSEM AD electronic notification system– It is designed to receive signals for various violations of standards of conduct and / or financial and criminal activity. The system is accessible from company website at www.fraport-bulgaria.com
   

iii. Sanctions

In case of violations, we reserve the right to take disciplinary and legal action depending on the severity of the offense and in accordance with the rights and obligations of employers and employees under Labor code, Collective labor agreement and MSD 8.47.3.14 “Rulebook on the internal organization at work”.