The Code of Conduct applies to all employees*   and all managing directors of Faport Twin Star Airport Management AD (FTSAM).

The Code of Conduct represents the universal basis and the principles of action that guide FTSAM. Its observation is specified by further internal company regulations and instructions.

All executives are tasked with upholding and spreading the Code of Conduct within the company and with ensuring compliance herewith. In their function as role models, they bear special responsibility in this regard.

*Employees: all employees and temporary workers working at FTSAM, including managers, student assistants, short-term employees, apprentices, trainees, and interns.

2.1 Compliance with Laws, Accepted Standards, and Principles

As part of the Fraport Group, FTSAM is committed to its social responsibility for sustainable development. This means taking responsibility in the areas of economy, ecology, and social matters and adopting a course of action that complies with laws and regulations.

We are committed to internationally recognized standards, regulations and principles, such as the principles of the UN Global Compact, the UN Agenda 2030 and its Sustainable Development Goals, the UN Universal Declaration of Human Rights and the core labor standards of the International Labour Organization (ILO). We are committed to compliance with the applicable national laws.

2.2 Compliance with Human Rights

Companies are important social stakeholders and have an original responsibility to promote human rights. FTSAM respects internationally recognized human rights, takes its responsibility to comply with legal requirements seriously, and avoids human rights violations in the course of its business activities.  

Complying with human rights includes, in particular, the following rights and obligations:  

• We reject all forms of child labor.  We strictly reject any form of forced labor as well as all forms of slavery or slave-like practices, servitude or other forms of domination or oppression in the work environment.
• We respect the fundamental right to the freedom of association and the right resulting from this to collective bargaining to regulate general labor conditions in the Group within the framework of national laws.
• We ensure appropriate wages – compensation at FTSAM is under no circumstances lower than the applicable legal minimum standards.
• We undertake to comply with the relevant legal provisions and applicable occupational standards on working hours, paid vacation, and legal holidays.

Diversity

As an open-minded company, we value the diversity and variety of our workforce. This allows different perspectives and experiences to flow into our work. With this diversity lived in everyday life, we can develop solutions with our customers that are innovative for them. The appreciation and recognition of the diversity of our employees makes a major contribution to FTSAM’s economic success.

Equal Opportunities and Equal Treatment

FTSAM encourages diversity in its workforce and pursues the objective of rejecting any form of discrimination. The principle of mutual appreciation and respect is an essential part of the FTSAM values culture: FTSAM stands for fair, respectful, and cooperative relationships.

These principles form the basis of our actions:

• We are committed to not distinguishing, excluding, or favoring people on the basis of their ethnic, national or social origin, race, color, gender, age, religion, or belief.
• We prohibit any discrimination based on constitutional political activity, membership in an employee's organization, disability, or sexual orientation.  

2.3 Environmental Protection

FTSAM undertakes to adopt a sustainable, considerate and careful approach to natural resources and the environment. It is our goal to minimize the negative impacts of our activities on people and the environment. Noise abatement and climate protection play a special role in this.
Our environmental policy is based among others on the following principles:

• We are committed to conducting our business activities in an environmentally friendly manner. We strive to protect the environment and to ensure safe and healthy working conditions for our employees.  
• We encourage our employees to use natural resources responsibly.
• We work towards the development and dissemination of environmentally friendly technologies by applying ecological criteria in the selection of products and services.
• As part of our responsibility, we strive to limit emissions of climate-relevant gases and air pollutants to an unavoidable minimum.
  

3.1 Prevention of Corruption
Corruption is generally defined as the abuse of entrusted power for personal or private gain. Corruption not only causes material damage but also obstructs the economic, political, and social development of a country and thus ultimately undermines the foundations of a society.

Integrity in business dealings and the prevention of corruption are important principles for FTSAM. We do not bribe and do not allow ourselves to be bribed. We do not tolerate any form of corruption and avoid even the mere appearance of undue influence.

Gifts and Invitations

Benefits in the form of gifts and invitations are part of the usual forms of social contact in business life. Nevertheless, inappropriate benefits can be understood as inadmissible forms of influence, which may also be punishable by law.  

All employees undertake not to offer or accept any gifts or invitations in business dealings that could influence a business relationship in an inadmissible manner.

We observe the following principles regarding gifts and invitations:

• Appropriateness:  Gifts or invitations must be in accordance with local customs and socially acceptable behavior. They may be made as a gesture of courtesy and appreciation but must not be of an unreasonably high value.
• Connection with business activity:  A benefit may never be accepted or granted in order to influence a specific business decision. Even the appearance of such influence must be avoided.
• Frequency:  The giving or acceptance of gifts and invitations must be limited to sporadic occasions.
• Invitations or gifts to public officials entail a higher risk and are generally prohibited.  Exceptions are to be regulated in coordination with Compliance.
• Documentation:  The internal rules, approval and documentation processes must be observed.

Conflicts of Interest

Our success is based on business decisions being made solely in the interests of FTSAM. Employees must not pursue personal interests that conflict with FTSAM's interests or take personal advantage of business opportunities to which FTSAM is entitled.

Conflicts of interest can arise in many ways, e.g. through financial interests in suppliers, customers or business partners, in the context of secondary employment or through personal relationships between employees at work and with business partners.

If a conflict of interest exists or could exist, we implement the following  measures:

• The affected employee shall notify his or her superior in writing.
• The superior shall take appropriate measures to adequately reduce the risks to the company arising from the conflict of interest.
• We document the conflict of interest, the decision whether and which measures are necessary, and the measures taken.

Donations and Sponsoring

We assume social responsibility. As a trusted partner for our community, we promote culture, education, sports, and ecological and social matters.

In doing so, we take the following  principles  into account:

• We use donations and sponsoring only for purposes compliant with integrity requirements and avoid even the appearance of undue influence.
• Donations and sponsoring are awarded on the basis of transparent and clear criteria.  

3.2 Fair and Free Competition

The protection of free competition is an essential requirement for wealth, growth and employment. FTSAM is committed to unrestricted and fair competition. We deal fairly with our business partners. Our aim is to prevail in competition by means of our values and expertise, when participating on the market. FTSAM does not tolerate any anti-competitive behavior.

The following  principles  apply in particular:

• We do not enter into any unlawful agreements with competitors, in particular on prices, market segments, capacities and/or customers.
• We do not exchange sensitive/strategic information such as prices, price components, costs or investments with competitors.
• We do not agree on unlawful restrictions with customers or suppliers, and we do not unlawfully exclude anyone.
• We deal fairly and responsibly with strong market positions.
• We do not manipulate tender procedures or submit sham bids.

If you are uncertain whether a planned approach is compatible with legal requirements or internal rules, always contact the responsible legal department in a timely manner.

3.3 Prohibition of Insider Trading

A condition for the efficient functioning of the capital markets is that all persons trading on the capital market have the same information. No person should gain an advantage at the expense of others because he or she has an information advantage (insider information) over the general public that allows him or her to make predictions about the price trend of shares and other securities.

The prohibitions and obligations of the EU Market Abuse Regulation apply to our parent company - Fraport AG, its executive bodies and employees. Bodies and employees of Group companies and even external third parties may also be subject to obligations and restrictions when trading shares and other securities due to their relationship with Fraport AG.

Insider information  is information that

• is not publicly known,
• is precise,
• relates directly or indirectly to an issuer (e.g. Fraport AG) or a financial instrument (e.g. the Fraport AG share), and
• if it were made public, would be likely to have a significant effect on the price of the financial instrument.

It is prohibited to use insider information to acquire or sell, directly or indirectly, for one's own account or for the account of a third party, shares and other securities to which the insider information relates.

As a matter of principle, insider information must also be treated confidentially within the company. It may be disclosed only if there is a specific, verifiable reason, i.e. if disclosure is necessary in the regular course of employment and performance of the employee's respective task.

3.4 Prohibition of Money Laundering and Terrorist Financing

Money laundering (covert introduction of illegally acquired assets into the legal economic cycle) and terrorist financing (providing assets to carry out terrorist activities) are a serious threat and are therefore prohibited in many countries around the world.  

FTSAM supports the fight of states against money laundering and terrorist financing and observes national and international economic sanctions.  

The following  measures  are to be implemented in this connection:

• We conduct risk-based checks on the identity of business partners. It is our goal to maintain business relationships only with reputable partners who act with integrity and whose operating resources originate from legitimate business transactions.
• If there are any suspicions of money laundering or terrorist financing, we inform Compliance immediately. FTSAM reports suspicious cases to the relevant authorities.
• To reduce money laundering and other compliance risks, cash transactions must be kept to a minimum.
• We observe legally binding sanctions.

4.1 Cooperation between Employees

The principle of respect is a key component of our culture of values. FTSAM stands for fair, respectful dealings with one another in a spirit of partnership. We do not tolerate any form of bullying or verbal, physical or sexual coercion, violence or harassment. Racist, anti-Semitic, anti-religious and sexist attacks will not be tolerated.

The demands made on our employees are as follows:

• We all are Fraport, regardless of where and in which Group company we operate. Together, we achieve our goals.
• We identify with our work and are ambassadors for our company.
• We are service providers and know who our customers are. Every day, we all make our contribution to the sustainable development of the Bulgarian Black Sea coast and thus to the success of the company. Our company supports us in this and sets the framework for development and qualification.
• We value and use the diversity of our colleagues and look for mutual exchange. We treat each other openly and respectfully and value each other's work.

4.2 Occupational Health and Safety

Holistic, integrated occupational health and safety is a key element of our overall corporate responsibility. FTSAM takes preventive measures to protect employees from accidents, work-related health risks, and occupational diseases.

The guiding principles for occupational health and safety are binding for all employees:

• Operational processes must be designed in such a way as to ensure safe and healthy operations. Safety and health are integral components in the planning and implementation of activities.
• Superiors are obligated to act responsibly and in an exemplary manner in terms of occupational health and safety.
• By taking appropriate measures and assuming suitable behavior, managers and employees are obliged to create safe working conditions that do not impair health.

4.3 Secure Handling of Data and Business Secrets

FTSAM considers the security and integrity of data and confidential information in business dealings as one of the basic principles of business activity.
Personal DataThe collection and processing of personal data is only permitted for a specific purpose and requires the consent of the affected person (data subject) or another legal basis.  

FTSAM has published its “DATA PROTECTION POLICY” (the Policy). The document is available at the following link: http://ftsportal/SitePages/FTS_GDPR.aspx

By applying this Policy, FTSAM aims to ensure compliance with its obligations and responsibilities as a data controller, as well as to verify and demonstrate that the processing of personal data is carried out in accordance with the principles of data protection under GDPR (accountability).

This Policy applies to any processing of personal data within the Company, including for purposes of ground handling operations, civil aviation security, employment relationships, accounting, property management, security and access control, video surveillance, etc., with the exception of processing of personal data from Company’s employees in the course of purely personal activities. In the latter hypothesis, if employees use information or communication tools owned by FTSAM, they are required to comply with the information security requirements.

If you have any questions regarding the application of the Policy, please do not hesitate to contact the Data Protection Officer on tel. 052/573 567 or at dpo@fraport-bulgaria.com.

FTSAM complies with legal requirements and protects the personal data of employees, customers, suppliers, and other affected persons.

"Personal data" means any information relating to an identified or identifiable natural person.Every employee must: – treat personal data confidentially and only disclose such data to colleagues to the extent necessary for the performance of his or her duties. – refrain from collecting or further processing personal data without authorization and, in case of doubt, seek data protection advice. – delete personal data within the scope of responsibility and on the basis of departmental deletion concepts if the purpose of processing no longer applies. – inform his or her superior and the data protection management/data protection officer immediately in the event of a data security breach.

Every employee must:

• treat personal data confidentially and only disclose such data to colleagues to the extent necessary for the performance of his or her duties.
• refrain from collecting or further processing personal data without authorization and, in case of doubt, seek data protection advice.
• delete personal data within the scope of responsibility and on the basis of departmental deletion concepts if the purpose of processing no longer applies.
• inform his or her superior and the data protection management/data protection officer immediately in the event of a data security breach.

Information and Business Secrets

Information determines our success and the success of our customers. For this reason, the protection of data integrity, data availability and the confidentiality of information are vital objectives.  

FTSAM provides for legitimate and protectable confidentiality in business dealings and ensures the protection of business secrets against unauthorized acquisition, use and disclosure.

Employees shall maintain confidentiality about matters whose secrecy is provided for by legal regulations or ordered by the employer; this shall also apply beyond the termination of the employment relationship.

4.4 Social Media

In communicating with our customers, employees and the general public, we use social media such as Facebook, LinkedIn, Instagram, Twitter and internal communication platforms.

We also treat each other fairly and positively in digital space. In doing so, we bear in mind that anything published on the Internet cannot simply be taken back.  

It is prohibited to make posts that:

• discriminate against or insult other persons
• reproduce unconstitutional or inflammatory content
• harm our reputation and that of our employees
• endanger the climate of peace within the Group

Furthermore, no contributions are permitted that misuse the intellectual property of others or publish confidential or internal data or information.

4.5 Protection of Assets

FTSAM operates efficiently and cost-consciously – thus, the protection of corporate assets is an integral part of our responsibility at work.

The protection of assets, in particular property, also relates to valuables that have been entrusted to FTSAM by customers, business partners, or passengers

The following principles apply to the protection of assets:

• Employees are obliged to protect FTSAM property and assets from loss, damage and misuse.
• Organizational measures for the control of invoices and the release of payments must be observed.
• Objects and other assets provided by FTSAM are only to be used for operational purposes, unless otherwise regulated; they shall be treated with care and consideration.
• Employees shall treat third-party assets and objects entrusted to them with consideration and care.

5.1 Contacts for Your Questions

The Code of Conduct does not contain detailed instructions on how to act in all situations that arise in everyday working life but offers a basis for dealing responsibly with the challenges of day-to-day business.

Questions on the interpretation and application of these rules in working practice or on more extensive guidelines can be answered by executives, Miglena Varbanova – Head of the Legal and Compliance Department of FTSAM (tel. 052 573 227 or miglena.varbanova@fraport-bulgaria.com) or Ombudsman Elitsa Manolova (tel. 052 573 232 or ombudsman@fraport-bulgaria.com).

5.2 Dealing with Mistakes and Rule Violations

The corporate culture at FTSAM is characterized by the values of competence, reliability, openness, courage, commitment, and trust. The value of courage is to make decisions, take responsibility, and endure opposition. Mistakes can occur doing so. It is crucial that these mistakes are recognized and corrected. FTSAM promotes an open approach to mistakes. This is the only way we can learn from our mistakes and continue to develop.  

A key requirement for our success is ensuring integrity in all business processes. Employees are obliged to comply with the applicable laws, this Code of Conduct and the internal rules. In the event of violations, they must expect consequences under labor law in addition to the possible consequences under criminal and liability law.  

5.3 Reporting Channels for Suspected Compliance Violations

In the case of violations of laws or internal rules, FTSAM is interested in receiving information on such misconduct. We are grateful for any information that helps to identify and remedy irregularities. This is essential to prevent economic disadvantages and damage to our reputation.

We expect all employees to act responsibly and promote open interaction in the sense of a culture of trust between employees and the respective executives who are available as the first point of contact.

If employees wish to report suspected compliance violations or actions that may harm the company they can do so anonymously.  

At FTSAM, reports are accepted by our electronic reporting system.

Detailed information on further reporting channels can be found on the corporate website www.fraport-bulgaria.com.

FTSAM encourages all the employees to report suspected violations of this Code of Conduct and guarantees their protection.  

This Code of Conduct for Employees of Fraport Twin Star Airport Management AD was adopted by Decision of the Management board on May 31st 2022 and enters into force on July 1st 2022.